DOCKET NO: A-98-49; II-A4-167

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

ADDITION OF TWO POPULATIONS OF ALPHA GAMMA HOT CELL FACILITY 

30-GALLON CONTAINERS TO REMOTE-HANDLED DEBRIS WASTE STREAM 

AERHDM AT THE ARGONNE NATIONAL LABORATORY:

REDUCED ENRICHMENT RESEARCH AND TEST REACTOR PROGRAM FUEL 

EXAMINATION WASTE AND 

DEBRIS FROM A SECOND BATCH OF FUEL PIN FUEL EXAMINATION WASTE 

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Federal Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

October 2012
i

TABLE OF CONTENTS

Section Page

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

2.0 Purpose of Tier 1 Evaluations..............................................................................................6

3.0 Purpose of This Report ........................................................................................................6

4.0 Scope of The Tier 1 Evaluation ...........................................................................................7

5.0 EPA Evaluation Personnel...................................................................................................7

6.0 Technical Evaluation ...........................................................................................................8

6.1 Acceptable Knowledge ........................................................................................... 9

6.2 Radiological Characterization............................................................................... 20

6.3 Visual Examination............................................................................................... 29

7.0 Findings and Concerns.......................................................................................................30

8.0 Conclusions........................................................................................................................30

TABLE OF TABLES

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP....... 4

Table 2. EPA Tier 1 Evaluation Team Members............................................................................ 8

Table 3. Alpha Gamma Hot Cell Facility Fuel Examination Waste Data Tracking Summary.... 16

TABLE OF FIGURES

Figure 1. Flow Diagram of the Characterization Process: AGHCF RERTR Fuel Examination 

Waste............................................................................................................................................. 23

Figure 2. Flow Diagram of the Characterization Process: AGHCF Second Batch of Fuel Pin 

Fuel Examination Waste............................................................................................................... 24

ATTACHMENTS

Attachment A: Approval Summary for ANL RH Waste Characterization Program

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

ABBREVIATIONS AND ACRONYMS

A/G alpha-gamma

AGHCF Alpha Gamma Hot Cell Facility

AK acceptable knowledge

AKE Acceptable Knowledge Expert

AKSR acceptable knowledge summary report

Am americium

ANL Argonne National Laboratory

ANL-E Argonne National Laboratory-East

ANL-W Argonne National Laboratory-West

ATR Advanced Test Reactor

Ba barium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

Ci curie

Cs cesium

DOE U.S. Department of Energy

DQO data quality objective

DTC dose-to-curie

EBR-II Experimental Breeder Reactor-II

EPA U.S. Environmental Protection Agency

Eu europium

FEW fuel examination waste

FIMS Fissile Inventory Management System

g/cm3 grams per cubic centimeter

HLW high-level waste

ITR Independent Technical Reviewer

MCNP Monte Carlo N-Particle Transport Code

MCNP5 Monte Carlo N-Particle Transport Code, Version 5

mR/hr milliroentgens per hour
iii

mR/hr/Ci milliroentgens per hour per curie

MTR Material Test Reactor

ORR Oak Ridge Reactor

Pu plutonium

RERTR Reduced Enrichment Research and Test Reactor Program

RH remote-handled

SNF spent nuclear fuel

SPM Site Project Manager

Sr strontium

T1 Tier 1

T2 Tier 2

TMU total measurement uncertainty

TRU transuranic

U uranium

VE visual examination

VEE Visual Examination Expert

WCPIP Waste Characterization Program Implementation Plan

WIPP Waste Isolation Pilot Plant

WMC Waste Matrix Code

WMP waste material parameter

Y yttrium
1

1.0 INTRODUCTION

This report supports the U.S. Environmental Protection Agency’s (EPA’s) decision to approve a 

Tier 1 (T1) change to add two populations of Alpha Gamma Hot Cell Facility (AGHCF) fuel 

examination waste (FEW) to the previously-approved remote-handled (RH) transuranic (TRU) 

debris Waste Stream AERHDM at the U.S. Department of Energy’s (DOE’s) Argonne National 

Laboratory (ANL).1 In January 2007, EPA approved the Central Characterization Project (CCP) 

to characterize RH waste at ANL. On August 1, 2012, the Carlsbad Field Office (CBFO) 

requested EPA approval of a T1 change to include AGHCF Reduced Enrichment Research and 

Test Reactor (RERTR) FEW and AGHCF debris FEW from a second batch of fuel pins 

packaged in 30-gallon containers in Waste Stream AERHDM. Using the EPA-approved waste 

characterization processes discussed in this report, ANL-CCP can characterize (1) RERTR 

AGHCF FEW and (2) debris FEW from the processing of a second batch of fuel pins in the 

AGHCF. This AGHCF RERTR and debris FEW packaged in 30-gallon containers2 and thus 

characterized can be added to the ANL Waste Stream AERHDM for disposal 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-ANL-CCP-RH-9.06-8 of the CCP waste 

characterization program at ANL on September 12–14, 2006. The January 2007 baseline 

approval applied to 45 containers of legacy RH debris waste drums. The ANL baseline final 

inspection report (see EPA Docket No. A-98-49; II-A4-73) documents EPA’s approval of the 

acceptable knowledge (AK), radiological characterization using dose-to-curie (DTC) and visual 

examination (VE) processes specific to ANL-CCP’s RH waste characterization program. Table 1 

of that report defined the inclusion of any additional containers of debris to the approved waste 

stream as a T1 change that requires EPA approval before implementation. Since the baseline 

approval, ANL-CCP added containers to the approved AERHDM waste stream as shown in 

Attachment A.

The AGHCF RERTR FEW will be characterized by DTC, as described in Appendix E to CCPAK-ANLE-501, “Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from Argonne 

National Laboratory-East,” Revision 8, dated June 1, 2012. The AGHCF debris FEW from a 

second batch of fuel pins (hereafter referred to as “AGHCF second batch of fuel pin FEW”) will 

be characterized by one of two methods depending on the size of the debris. AGHCF second 

batch of fuel pin FEW that are less than 1⁄2-inch long will be characterized by DTC, as described 

in Appendix F to CCP-AK-ANLE-501, Revision 8, and the AGHCF second batch of fuel pin 

FEW that are greater than 1⁄2-inch long will be characterized by dimensional analysis, as 

described in Appendix C to CCP-AK-ANLE-501, Revision 8. 

 1 ANL was initially designated ANL-E (ANL-East) to distinguish it from ANL-West (ANL-W). In 2009, 

ANL-W was renamed the Materials and Fuel Complex, and ANL-E has since been referred to as ANL. Both 

designations are found in the documents that EPA reviewed for this evaluation, and these terms are interchangeable 

in this report.

2 “Containers” is a generic term that applies to cans, canisters, drums and any other types of waste 

packaging units that may be characterized individually for their radiological and physical contents.
2

In November 2010, EPA approved a T1 change to add AGHCF fuel pin FEW to Waste Stream 

AERHDM (EPA Docket No: A-98-49; II-A4-140). This T1 change approval included approval 

of the dimensional analysis method described in Appendix C to CCP-AK-ANLE-501, Revision 

3. Because Appendix C to CCP-AK-ANLE-501 has not changed since that approval, EPA 

limited the radiological characterization and VE scope of this T1 evaluation and approval to the 

AGHCF RERTR FEW and the AGHCF second batch of fuel pin FEW less than 1⁄2-inch long 

(Appendices E and F to CCP-AK-ANLE-501, Revision 8). The scope of the AK evaluation and 

approval includes the RERTR FEW and all sizes of the AGHCF second batch of fuel pin FEW

because the size of the second batch of fuel pin FEW does not impact the AK process or pedigree 

distinction.

Since there were no new equipment or additional new processes on site at ANL as part of the T1 

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

use the EPA-approved system of controls to characterize the 30-gallon containers of AGHCF 

RERTR FEW and AGHCF second batch of fuel pin FEW was acceptable. EPA did not identify 

any findings or concerns during this evaluation. Freeze files3 for the revised documents were 

provided to EPA before the conclusion of this T1 evaluation. EPA expects formal revisions of 

CCP-AK-ANLE-500, Revision 10 and CCP-AK-ANLE-502, Revision 6 to be completed prior to 

the ANL-CCP’s 2013 first quarter submission of Tier 2 (T2) changes to EPA for review and 

concurrence. Attachment B is a list of all documentation reviewed, including BDRs and 

calculation packages.

As a result of this evaluation, EPA approves the T1 change request to add 30-gallon containers 

of the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW to ANL-CCP’s 

previously approved AERHDM waste stream. Specifically, EPA approves:

(1)The AK process for adding AGHCF RERTR FEW and the AGHCF second batch of fuel 

pin FEW to Waste Stream AERHDM.

(2)The radiological characterization process using DTC and scaling factors to characterize 

AGHCF RERTR FEW, as described in CCP-AK-ANLE-501, Revision 8, Appendix E.

(3)The radiological characterization process using DTC and scaling factors to characterize 

AGHCF second batch of fuel pin FEW less than 1⁄2-inch long, as described in CCP-AKANLE-501, Revision 8, Appendix E.

(4)The VE process to identify waste material parameters (WMPs) and confirm physical 

characteristics of AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW less 

than 1⁄2-inch long.

 3 In the course of the evaluation, CCP may be required to revise a document as a result of an inspectionrelated EPA issue. CCP makes the required change(s) and provides the revised document to EPA as a freeze file to 

serve as objective evidence that the revisions are appropriate. EPA has agreed to accept the revised documents as 

freeze files to expedite EPA review while CCP’s document control process generates an official version of the 

revised document that will be provided at a later date.
3

Based on this evaluation, EPA has made one change to the AK T1 designations and two changes

to the AK T2 designations. ANL-CCP may characterize any number of containers of AGHCF 

RERTR FEW or AGHCF second batch of fuel pin FEW in waste stream AERHDM provided the

waste in those containers fits the waste pedigree and is characterized using the radiological 

characterization processes discussed in this report. Characterization of any AGHCF FEW other 

than the RERTR FEW or second batch of fuel pin FEW discussed in this report or the fuel pin 

FEW approved previously is a T1 change. That is, characterization of any AGHCF FEW with 

different pedigrees, scaling factors, or radiological characterization processes from the FEW 

approved in this report and previous T1 evaluation reports (see Appendix A to this report) is a T1 

change. Specifically, characterization of AGHCF crucibles and melts FEW remains a T1 change. 

Notification to EPA when the source document containing compiled information supporting 

Source Document U344 is available is a new T2 change. Also, this report explicitly identifies 

characterization information summaries as an example of a waste stream profile form 

attachment, revision of which continues to require T2 notification to EPA. Table 1 shows the 

revised T1 and T2 changes in bold text. All of the T1 and T2 changes that were established 

during the baseline approval remain in effect and are listed as applicable in sections 6.1, 6.2 and 

6.3.

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

evaluation. This information will be provided through the EPA website and by emails to the 

WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
4

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP

(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated September 2012)

RH Waste Characterization

Process Elements ANL-CCP RH Waste Characterization Process - T1 Changes ANL-CCP RH Waste Characterization Process - T2 Changes*

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline

Modification of the approved Waste Stream AERHDM to include 

additional containers beyond the approximately 45 included in 

CCP-AK-ANLE-500, Revision 1, if new or different radionuclide 

scaling factors are required

Substantive modification(s)*** to CCP-AK-ANLE-500 or 

CCP-AK-ANLE-502 that have the potential to affect the 

characterization process

Implementation of load management for any remote-handled (RH) 

waste stream

Characterization of any Alpha Gamma Hot Cell Facility 

(AGHCF) or K-Wing fuel examination wastes (FEWs) other 

than the AGHCF and K-Wing fuel pin FEW, AGHCF Reduced 

Enrichment Research and Test Reactor FEW and AGHCF 

second batch of fuel pin FEW—specifically, characterization of 

AGHCF crucibles and melts FEW—is a T1 change

Notification to EPA that the final DTC determination is complete for RH 

containers in the approved waste stream

Notification to EPA when updates are made to AK documentation as a 

result of Waste Characterization Program Implementation Plan revisions**

Notification that updates have been completed to the following documents:

• All future revisions of CCP-AK-ANLE-500, CCP-AK-ANLE-501, 

and CCP-AK-ANLE-502, including freeze file changes

• Listing of the references that document the assembly of fuel pin data 

and review process 

Notification to EPA that the data package for this debris waste stream is 

completed, including any modifications or change notifications to the 

waste stream profile form, including the characterization reconciliation 

report, characterization information summary and acceptable 

knowledge summary report (AKSR)

Notification to EPA when AK accuracy reports are completed, prepared 

annually at a minimum

Notification to EPA when Attachment 4 of CCP-TP-005 is generated to 

reflect the updated AKSR Source Document Reference List

Notification to EPA when Attachment 8 of CCP-TP-005 has been formally 

updated or when Add Container Memoranda have been added to Source 

Document C2029

Notification to EPA when ANL-CCP decides on the disposition path for 

vitrified HLW from Savannah River Site (SRS) and vitrified sludge from 

West Valley

Notification to EPA when the source document containing compiled 

information supporting Source Document U344 is available

Notification to EPA of the intention to add containers to Waste Stream 

AERHDM, including the approximate number of containers and volume(s) 

of waste, the timeframe for waste generation, characterization, and disposal

and submission of an updated AKSR documenting that the pedigree of the 

additional containers is the same as those covered by the baseline and/or 

subsequent T1 approvals†
5

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP

(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated September 2012)

RH Waste Characterization

Process Elements ANL-CCP RH Waste Characterization Process - T1 Changes ANL-CCP RH Waste Characterization Process - T2 Changes*

Submission of a list of fully characterized containers from a population of 

additional containers proposed as a T2 change, above†

Radiological Characterization, 

including Dose-To-Curie (DTC) 

Use of any alternate radiological characterization procedure other 

than DTC with sampling-derived scaling factors as documented in 

CCP-TP-504 and CCP-AK-ANLE-501, Revision 0, respectively

Substantive modification(s)*** to CCP-AK-ANLE-501 or 

CCP-TP-504 that have the potential to affect the characterization 

process 

Any new waste stream not approved under this baseline or addition 

of containers to Waste Stream AERHDM that require changing the 

established radionuclide scaling factors

Application of new scaling factors for isotopic determination other 

than those documented in CCP-AK-ANLE-501

Implementation of gravimetric analysis for waste other than debris 

will require EPA approval as a T1 change

Notification to EPA that revisions of CCP-AK-ANLE-501 or CCP-TP-504 

that require CBFO approval** are complete

Submission of an updated CCP-AK-ANLE-501 documenting that the 

radiological characterization process(s) used for the additional containers is 

the same as those covered by the baseline and/or subsequent T1 approvals†

Submission of DTC batch data reports (BDRs) or calculation packages for 

containers selected by EPA from a list of fully characterized containers 

provided by ANL-CCP†

Visual Examination (VE) VE by reviewing existing audio/visual recordings for any waste 

summary category group not covered by this approval

VE by any new process for S5000 debris wastes

Submission of VE BDRs for containers selected by EPA from a list of fully 

characterized containers provided by ANL-CCP†

Notification to EPA that revisions of any VE procedure that require CBFO 

approval are complete

Addition of new S5000 debris waste streams

Real Time Radiography (RTR) Any use of RTR requires EPA approval Submission of RTR BDRs for containers selected by EPA from a 

list of fully characterized containers provided by ANL-CCP†

WIPP Waste Data System (WDS) None Changes made to WDS procedure(s) that require CBFO approval

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

* ANL-CCP will report all unmarked T2 changes to EPA quarterly. 

** Excluding changes that are editorial in nature or are required to address administrative concerns. New references that are included as part of the document revision may be 

requested by EPA.

*** “Substantive modification” refers to a change with the potential to affect ANL’s RH waste characterization process, e.g., the use of an inherently different type of 

measurement instrument or the use of the high-range probe as described for CCP-TP-504 for radiological characterization.

† ANL-CCP will report this T2 change immediately.
6

2.0 PURPOSE OF TIER 1 EVALUATIONS

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 into the ANL-CCP RH 

baseline final report (see EPA Docket No. A-98-49; II-A4-73).

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

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

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization program, based on the demonstration 

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

characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes 

destined for disposal at the WIPP. 

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

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

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

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

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

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

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

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

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

subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and may conduct 

continued compliance inspections to evaluate implemented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluation of a T1 change to include AGHCF RERTR 

FEW and AGHCF second batch of fuel pin FEW packaged in 30-gallon containers in Waste 

Stream AERHDM, as described in CCP-AK-ANLE-500, “Central Characterization Project 

Acceptable Knowledge Summary Report for Argonne Remote-Handled Debris Waste, Waste 

Stream: AERHDM,” Revision 10, dated May 22, 2012, and Appendices E and F to CCP-AKANLE-501, Revision 8. This report presents the technical basis for and results of EPA’s approval 

decision. EPA’s approval decision regarding the inclusion of the AGHCF RERTR FEW and 

AGHCF second batch of fuel pin FEW has been conveyed to DOE separately by letter. EPA will 

also announce the decision on its website at www.epa.gov/radiation/wipp, in accordance with 

40 CFR 194.8(b)(3). 

The DOE documents that EPA reviewed for this evaluation are cited in different sections 

throughout the report and are listed in Attachment B. Any of these documents can be requested 

from the following address:
7

Manager, National TRU Program

Carlsbad Field Office

U.S. Department of Energy

P O Box 3090

Carlsbad, NM 88221-3090

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of ANL-CCP’s T1 request was for EPA approval of the radiological approaches used 

to characterize AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW less than 

1⁄2-inch long as part of Waste Stream AERHDM. However, based on criteria set forth by EPA 

during Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 (Docket No. A-98-49; II-A4-73, 

January 2007) and the subsequent T1 evaluation (Docket No. A-98-49; II-A4-140, November 22, 

2010), a T1 request is required for both AK and radiological characterization of any AGHCF 

FEW other than the fuel pins. Therefore, the scope of EPA’s T1 evaluation is in three parts:

• The overall inclusion of AGHCF RERTR FEW in Waste Stream AERHDM, as specified 

in CCP-AK-ANLE-500, Revision 10; CCP-AK-501, Revision 8, Appendix E; and as 

described in a VE BDR.

• The radiological characterization and VE of AGHCF second batch of fuel pin FEW less 

than 1⁄2-inch long in Waste Stream AERHDM, as specified in CCP-AK-ANLE-501, 

Revision 8, Appendix F; and a VE BDR.

• The AK process for including AGHCF second batch of fuel pin FEW of all sizes in 

Waste Stream AERHDM, as described in CCP-AK-ANLE-500, Revision 10. 

Sections 6.1, 6.2 and 6.3 of this report detail the three technical areas assessed during this 

evaluation:

• Programmatic requirements and AK.

• Radiological characterization.

• VE.

Throughout the report, the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW

populations are discussed together under each Item in each technical area when issues, 

conditions or processes are similar, and separately when they differ. 

This evaluation involved expanding an existing waste stream to incorporate new drums and not 

the addition of a new summary category group or waste stream; therefore, inspection checklists 

were not used.

5.0 EPA EVALUATION PERSONNEL

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

technical areas of expertise. EPA relied primarily on reviews of documents and information 

provided by ANL-CCP. When additional information or clarifications were needed, EPA had 
8

discussions with Irene Quintana, the ANL-E RH Project Manager, who served as the point of 

contact for this T1 evaluation.

Table 2. EPA Tier 1 Evaluation Team Members

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Ed Feltcorn Inspector, U.S. EPA 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A 

Dorothy Gill Technical Evaluator – Visual Examination, SC&A

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 

6.0 TECHNICAL EVALUATION

Waste-Generating Activities

There are over 3,000 samples containing fuel-bearing material within the AGHCF of Building 

212. This material consists of nuclear irradiated fuel specimens (fuel pins), metallography 

mounts, and other fuel-bearing materials (RERTR plates and crucibles and melts). FEW 

generated during examination of the RERTR plates and a second batch of fuel pins is the subject 

of this T1 evaluation (References P2032 and U076). Sodium-bonded fuel examination materials 

stored in the AGHCF will be packaged and transferred to Idaho National Laboratory and are not 

included in Waste Stream AERHDM (References C2025, P2032 and U076). The sodium-cooled 

reactor assembly sections (also referred to as loops) containing unreacted sodium metal will be 

included in this waste stream after a procedure is developed to neutralize any unreacted sodium 

associated with these materials before they are included in Waste Stream AERHDM (Reference 

C2029).

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste 

The AGHCF RERTR FEW consists of residual RERTR fuel specimens and remnants from the 

irradiated materials involved in research experiments conducted in the AGHCF hot cells. The 

activities conducted involved sectioning, grinding, and polishing RERTR plates for 

metallography, gamma spectrometry, high-temperature examination, fission gas collection and 

analysis, and macrophotography. The RERTR program is a nuclear nonproliferation program 

that was established at ANL in 1978 by DOE to minimize the use of highly enriched uranium in 

civil nuclear programs and, therefore, limit the amount of highly enriched uranium available for 

weapons production. Numerous fuel samples fabricated at ANL-W and irradiated in reactors,

including the Advanced Test Reactor (ATR) and the Oak Ridge Reactor (ORR), have been 

received and examined at the AGHCF as part of the RERTR program. ANL-CCP identified 352 

RERTR plates that contribute to this population of waste (References P012, P373, P374, P520, 

P551, P575, P816 and U076).
9

Second Batch of Fuel Pin Fuel Examination Waste 

The AGHCF second batch of fuel pin FEW consists of metallurgical mounts and associated 

powdered fuel removed during the preparation grinding, as well as a few segments or remnants 

of fuel specimens. This population was initially set aside from the other fuel pin FEW until ANL

could verify that the materials were free of any unreacted sodium contamination. The reactor 

fuels associated with this second batch of fuel pin FEW were primarily carbide fuels irradiated in 

the Material Test Reactor (MTR) and Experimental Breeder Reactor-II (EBR-II). A total of 179 

discrete fuel specimens were identified in the AGHCF second batch of fuel pin FEW. The 

specimens were separated into two groups: one that included met mounts and fuel segments with 

lengths less than 1⁄2 inch and a second group with fuel segments with lengths greater than 1⁄2 inch

(References C046, C812, P2035, U040 and U307).

Packaging Configuration

The AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW will be placed into 1-

gallon steel lead-shielded containers or shield pots; each of these containers will be loaded into a 

7-gallon can. Each set of two 7-gallon cans will be loaded (stacked) into a 30-gallon can fitted 

with a 140-mil polyethylene liner and overpacked in a 55-gallon drum for shipment to the WIPP. 

Each 30-gallon drum will contain either two 7-gallon cans of AGHCF RERTR FEW or two 7-

gallon cans of AGHCF second batch of fuel pin FEW. The types of waste will not be mixed 

within the drums.

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

Provided

EPA evaluated the ANL-CCP documentation that supported inclusion of the AGHCF RERTR

FEW and AGHCF second batch of fuel pin FEW in Waste Stream AERHDM. ANL-CCP 

provided CCP-AK-ANLE-500, Revision 10, CCP-AK-ANLE-502, Revision 6, and CCP-AKANLE-501, Revision 8, to EPA for review. EPA’s review identified several technical issues that 

necessitated the revision of CCP-AK-ANLE-500, Revision 10, some of the associated AK 

documentation (see section 6.1), and CCP-AK-ANLE-502, Revision 6. Freeze files for the

revised documents were provided to EPA before the conclusion of this T1 evaluation. EPA 

expects formal revisions of CCP-AK-ANLE-500, Revision 10 and CCP-AK-ANLE-502, 

Revision 6, to be completed before ANL-CCP’s first-quarter 2013 submission of T2 changes to 

EPA for review and concurrence. Attachment B is a list of all documentation reviewed, including

BDRs and calculation packages.

6.1 Acceptable Knowledge

EPA examined the programmatic requirements and AK process and associated information to 

assess the technical adequacy of the information to support the inclusion of the AGHCF RERTR

FEW and AGHCF second batch of fuel pin FEW in ANL-CCP RH Waste Stream AERHDM. 
10

Waste Characterization Element Description

EPA has evaluated Waste Stream AERHDM several times. Therefore, as part of this evaluation, 

EPA limited the review to the following elements regarding programmatic requirements and the 

use of AK for RH waste characterization: 

• Evaluation scope and waste stream identification. 

• Identification of the Waste Characterization Program Implementation Plan (WCPIP)

4

waste characterization process.

• Adequacy of the certification plan and other WCPIP documentation. 

• Waste stream definition, including radiological and physical characteristics.

• Verification that the subject waste is of defense origin and is not high-level waste (HLW) 

or spent nuclear fuel (SNF).

• Role of AK in the characterization methodology, including radionuclide scaling factors.

• Adequacy of the AK procedure and its implementation, including attachments and AK 

accuracy reports.

• Adequacy of the AKSR and associated source documents.

• AK data traceability.

• Personnel training.

• Attainment of data quality objectives (DQOs).

Technical Evaluation

EPA evaluated the adequacy of AK information specific to adding AGHCF RERTR FEW and 

AGHCF second batch of fuel pin FEW to Waste Stream AERHDM, as described in the AKSR, 

Revision 10; CCP-AK-ANL-501, Revision 8; and CCP-AK-ANL-502, Revision 6.

(1) The scope of the Tier 1 request and the waste stream determination were examined for 

Waste Stream AERHDM, including the additional Alpha Gamma Hot Cell Facility 

Reduced Enrichment Research and Test Reactor fuel examination waste and second 

batch of fuel pin fuel examination waste and were found to be adequate.

This T1 change requests approval of the radiological characterization approaches for the 30-

gallon containers of AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW in Waste 

Stream AERHDM, as specified in CCP-AK-ANLE-501, Revision 8, Appendices E and F. ANLCCP representatives stated that one drum of each population had been characterized at the time 

of the T1 request. ANL-CCP identified 352 RERTR plate specimens that contributed to the 

 4 All references to the WCPIP in this report refer to Revision 2, unless specified otherwise. 

U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste Characterization Program 

Implementation Plan,” Revision 2, Carlsbad, New Mexico, April 21, 2011.
11

AGHCF RERTR FEW population and identified 179 discrete specimens that contributed to the 

AGHCF second batch of fuel pin FEW population. ANL-CCP limited the scope of the T1 

request to the radiological characterization processes for the containers of AGHCF RERTR FEW 

and AGHCF second batch of fuel pin FEW. EPA explicitly excluded the RERTR FEW from a 

previous T1 approval (see section 4.0 and below); therefore, EPA expanded the scope of this T1

evaluation to include the AK, radiological and VE characterization performed to support 

inclusion of the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW populations 

in Waste Stream AERHDM.

The WCPIP defines a waste stream as “waste material that is (1) generated from a single 

process/activity and (2) similar in material, physical form, and radiological properties” (p. 13). 

Waste Stream AERHDM is a debris waste stream generated by ANL in two locations: the 

AGHCF and the K-Wing Hot Cell Facility.5 As part of the baseline and subsequent T1 

approvals, EPA concluded that the waste stream was adequately defined but did not at that time 

include AGHCF RERTR FEW or the AGHCF second batch of fuel pin FEW in the waste 

stream. Specifically, the population of waste approved during the Waste Stream AERHDM 

baseline inspection consisted of 45 30-gallon drums of RH TRU debris waste generated in the 

AGHCF, but the waste stream did not at the time include any of the AGHCF FEW. The AGHCF 

FEW, historically designated as “sweeps,” “high-level scrap” or “recoverable material,” was 

originally segregated from the Waste Stream AERHDM materials. In early 2010, ANL-CCP 

determined that AGHCF FEW packaged in 30-gallon containers should be included in Waste 

Stream AERHDM based on review of additional AK information (Reference DR023), and on 

July 29, 2010, ANL-CCP and CBFO requested EPA approval to include all of the AGHCF FEW 

in Waste Stream AERHDM. However, EPA only approved inclusion of the AGHCF fuel pin 

FEW in Waste Stream AERHDM for reasons related to radiological characterization processes. 

Prior to EPA’s separation of the FEW populations, ANL and ANL-CCP had managed all of the 

FEW, including fuel pin and RERTR FEW, as one population “including irradiated fuel test 

materials and residues (debris, fuel pin fragments, samples, capsules, and swarf) previously 

stored as accountable materials in the AGHCF. This waste has been generated at the AGHCF 

during the examination of irradiated and un-irradiated fuel pins and other reactor materials from 

various reactor programs at ANL-W and other DOE reactors.”6 The AGHCF RERTR FEW and 

second batch of fuel pin FEW were generated as a result of some of the same hot cell activities 

that generated the previously approved AGHCF debris (see EPA Docket No. A-98-49; II-A4-73) 

and AGHCF fuel pin FEW containers (see EPA Docket No. A-98-49; II-A4-140). 

Based on this information, the processes that generated the source material within the waste and 

the waste itself are well understood and represent a single process or waste stream. The 

radiological and physical compositions of the waste stream are addressed in Item (5). This 

approval is limited to containers of AGHCF RERTR FEW characterized using scaling factors 

 5 The AGHFC and the K-Wing Hot Cell Facility are distinct facilities located in the 200 Area of ANL-E 

that were used for similar purposes.

6 “Accountable materials” are items that are tracked and controlled in accordance with DOE M 435.1-1, 

“Radioactive Waste Management Manual,” because of their special nuclear material content.
12

developed according to CCP-AK-ANLE-501, Revision 8, Appendix E, and containers of 

AGHCF second batch of fuel pin FEW characterized using scaling factors developed according 

to CCP-AK-ANLE-501, Revision 8, Appendices C and F. Characterization of any AGHCF FEW 

other than the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW discussed in 

this report or the AGHCF fuel pin FEW previously approved is a revised T1 change. 

Specifically, characterization of AGHCF crucibles and melts FEW remains a T1 change (see 

Table 1).

(2) The certification plan, including description of the waste characterization process, was 

examined and found to be complete and technically adequate. 

The WCPIP requires that the certification plan (CCP-AK-ANL-502, Revision 6) describe the 

process for certification of the waste stream, including a description of the following: 

• AK qualification and/or characterization methods selected to meet the DQOs, including 

the justification for the selection of the methods.

• Quality assurance objectives for the selected methods.

• Characterization and testing methods not included in the WCPIP in sufficient detail to 

allow for CBFO approval prior to implementation.

• Summary of the program documents to be prepared during the characterization and 

qualification methods.

EPA examined the certification plan and found that the document did not accurately describe the 

radiological characterization process for either the AGHCF RERTR FEW or the AGHCF second 

batch of fuel pin FEW. ANL-CCP’s original plan was to characterize all of the AGHCF FEW 

using the same process; however, it was later determined that different subpopulations of 

AGHCF FEW would be characterized using different processes. CCP-AK-ANLE-502, Revision 

6, did not reflect this change in plans.

ANL-CCP revised the certification plan and provided EPA with a freeze file of the changes on 

September 14, 2012. EPA found that CCP-AK-ANLE-502, Revision 6, in conjunction with the 

freeze file, contained the basic information summarized above. The certification plan states that a 

combination of characterization methods from WCPIP sections 4.2 and 4.3 has been employed to 

characterize Waste Stream AERHDM and, specifically, the AGHCF RERTR FEW and second 

batch of fuel pin FEW. These methods include AK, VE and radiological characterization. AK is 

used to determine and describe the waste stream and to define Land Withdrawal Act DQOs such 

as the defense status of the waste and the absence of HLW and SNF. VE is used to verify the 

physical composition of the waste stream [Item (5) and section 6.3]. ANL-CCP used AK-derived 

scaling factors combined with DTC to determine the radiological composition (section 6.2). EPA 

finds that the characterization process will be adequately described in the certification plan upon 

inclusion of the revisions as demonstrated in the September 14, 2012, freeze file that EPA 

reviewed. EPA expects a formal revision of the certification plan to be completed before ANLCCP’s first-quarter 2013 submission of T2 changes to EPA for review and concurrence.
13

Notification to EPA when formal revisions of the certification plan are available remains a T2 

change (see Table 1). Substantive modification of CCP-AK-ANLE-502 that has the potential to 

affect the characterization process remains a T1 change (see Table 1).

(3) The acceptable knowledge procedure was examined and found to be adequate and 

appropriately implemented (WCPIP, section 4.1, pp. 32–33).

CCP-TP-005, Revision 24, “CCP Acceptable Knowledge Documentation,” became effective 

November 28, 2011. The preparation dates for the AKSR, certification plan, radiological 

characterization report and all revised supporting documentation postdate CCP-TP-005, Revision 

24. Therefore, CCP-TP-005, Revision 24, is the appropriate revision for preparation of CCP-TP005 attachments; note that future changes to any attachments should reflect the version of CCPTP-005 in place at the time the changes are made. EPA examined CCP-TP-005, Revision 24, 

during the T1 evaluation to add K-Wing FEW to Waste Stream AERHDM (Docket No. A-98-

49; II-A4-158, February 13, 2012) and found the procedure to be adequate.

CCP-TP-005, Revision 24, includes 15 attachments and also requires development and 

maintenance of an AK tracking spreadsheet that presents a running compilation of containers 

within each waste stream at a site. As a result of the inspection, ANL-CCP created new 

Attachment 13s (i.e., waste stream characterization checklists) to account for updated 

information about the inclusion of AGHCF RERTR FEW and AGHCF second batch of fuel pin 

FEW in Waste Stream AERHDM. The new Attachment 13s were adequate as presented to EPA. 

See Item (4) for a discussion of Attachment 4. ANL-CCP also provided Attachments 1, 6 and 8 

to EPA. These attachments were not revised and remain adequate.

As discussed in the ANL-CCP K-Wing FEW T1 approval report (Docket No. A-98-49; 

II-A4-158), CCP has implemented a new approach to tracking the addition of containers to 

approved waste streams. For all waste streams, Attachment 8 will no longer be updated after the 

initial waste stream approval or, as for Waste Stream AERHDM, after the first T1 approval 

following this change in CCP policy. Add Container Memoranda will be filed in a single source 

document and will serve as the official record for additional containers. Source Document C2029 

is the collection of Add Container Memoranda for Waste Stream AERHDM. ANL-CCP 

indicated that one container from each of the T1-subject populations has been generated and 

undergone ANL-CCP VE and radiological characterization: AGHCF RERTR FEW Container 

No. 1089 and AGHCF second batch of fuel pin FEW Container No. 1108. EPA confirmed that 

Source Document C2029 contains an Add Container Memorandum, dated March 14, 2012, that 

includes AGHCF second batch of fuel pin FEW Container No. 1108 (Reference C2029). EPA 

also found that Source Document C2029 did not seem to contain an Add Container 

Memorandum for AGHCF RERTR FEW Container No. 1089. ANL-CCP explained by email

that the AGHCF RERTR FEW container was added in an Add Container Memorandum dated 

February 16, 2012, but that a transcription error listed the container number as 1098 instead of 

1089. ANL-CCP added a note explaining the error to an Add Container Memorandum, dated 

August 24, 2012, that was added to Source Document C2029 on August 27, 2012. Notification to 

EPA when Add Container Memoranda have been added to Source Document C2029 remains a 

T2 change (see Table 1). 
14

EPA also confirmed that both of the characterized containers are listed in the AK tracking 

spreadsheet.

(4) The acceptable knowledge summary report was examined, along with the reference list 

and associated source documents, and found to be adequate.

EPA examined Revision 10 of the AKSR and found that the document did not cite any source 

documents in conjunction with the descriptions of the radiological characterization processes for 

the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW. ANL-CCP identified 

Source Documents P615, P804 and U344 as examples of records that contain the AK used in 

development of the ORIGEN2.2 modeling inputs for radiological characterization (see section 

6.2), but did not add these references to the AKSR. ANL-CCP determined that lists of specific 

records used for radiological characterization should be part of the radiological characterization 

documentation and not a component of the AKSR. EPA accepts this explanation.

EPA also found that the AKSR did not accurately describe the radiological characterization 

process for either the AGHCF RERTR FEW or the AGHCF second batch of fuel pin FEW. 

ANL-CCP’s original plan was to characterize all of the AGHCF FEW using the same process; 

however, it was later determined that different subpopulations of AGHCF FEW would be 

characterized using different processes. Section 5.4.3.1.4 of the CCP-AK-ANLE-500, Revision 

10, did not reflect this change in plans. ANL-CCP provided EPA with a freeze file on September 

14, 2012 correcting this section of text. EPA finds that the AKSR will be sufficient upon 

inclusion of the revisions as demonstrated in the freeze file that EPA reviewed, and expects a 

formal revision of the AKSR to be completed prior to the ANL-CCP’s first-quarter 2013 

submission of T2 changes to EPA for review and concurrence. Substantive modification of the 

AKSR that has the potential to affect the characterization process continues to be a T1 change 

(see Table 1). Notification to EPA upon minor revisions of the AKSR continues to be a T2 

change (see Table 1).

EPA also examined the “Acceptable Knowledge Source Document Information List, Waste 

Stream AERHDM” (CCP-TP-005, Revision 24, Attachment 4), dated March 6, 2012, and noted 

that it did not include references matching the description of AK records used in the radiological 

characterization process for the AGHCF second batch of fuel pin FEW. ANL-CCP identified the 

appropriate documents [see Item (6) for additional discussion about these documents] and added 

them to the AK record. EPA expects a formal revision of Attachment 4 to be completed prior to 

the ANL-CCP’s first-quarter 2013 submission of T2 changes to EPA for review and 

concurrence. Notification to EPA when a new Attachment 4 has been prepared remains a T2 

change (see Table 1).

(5) The radiological and physical properties of the waste stream were examined and found to 

be adequately described for the Alpha Gamma Hot Cell Facility Reduced Enrichment 

Research and Test Reactor fuel examination waste and for the second batch of fuel pin 

fuel examination waste based on acceptable knowledge.

The physical characteristics of each container are recorded in VE BDR Nos. ANLRHVE12001 

and ANLRHVE12010. VE operators assigned Waste Matrix Code (WMC) S5400, 
15

“Heterogeneous Debris,” to the examined AGHCF RERTR FEW and AGHCF second batch of 

fuel pin FEW containers, which is the same WMC that was assigned to the previously approved 

AGHCF debris and FEW containers in Waste Stream AERHDM. This is one indication that the 

AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW containers have the same 

physical characteristics as those in the approved waste stream.

EPA previously reviewed and found adequate ANL-CCP’s evaluation of the impact of including 

the AGHCF FEW, consisting of primarily metal debris, on the WMPs previously calculated for 

Waste Stream AERHDM (References CCP-AK-ANLE-500, Revision 10; CCP-TP-005, 

Revision 24, Attachment 6; C2026; and U2013). ANL-CCP found that including the AGHCF 

FEW in Waste Stream AERHDM would have a negligible impact on the waste stream WMPs. 

Based on the results of this evaluation, EPA agrees with ANL-CCP’s conclusion that the 

AGHCF FEW, including the RERTR FEW and the second batch of fuel pin FEW, is physically 

similar to the AGHCF debris waste, and that the WMPs published in the AKSR for the AGHCF 

debris waste are comparable and bounding. VE will be performed at the time of packaging to 

confirm the absence of prohibited items. EPA’s review of the VE BDRs is in section 6.3.

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

The AGHCF RERTR FEW consists of residual RERTR fuel specimens and remnants from the 

irradiated materials involved in research experiments conducted in the AGHCF hot cells (see 

section 6.0). The research activities involved sectioning, grinding and polishing RERTR plates 

for metallography; gamma spectrometry; high-temperature examination; fission gas collection 

and analysis; and macrophotography. The fuel specimens were from reactors including the ATR 

and ORR (References P012, P373, P374, P520, P551, P575, P816, U076 and U1003). These are 

the same activities and some of the same reactor fuels that produced the AGHCF debris waste. 

Therefore, as EPA has previously determined, the AK record sufficiently describes the 

radiological characteristics of the AGHCF RERTR FEW (see EPA Docket No. A-98-49; 

II-A4-73). The radiological characterization and scaling factor development processes for these 

containers are discussed in section 6.2.

Second Batch of Fuel Pin Fuel Examination Waste

The AGHCF second batch of fuel pin FEW consists of metallographic mounts and associated 

powdered fuel removed during the preparation grinding, as well as a few segments or remnants 

of fuel specimens (see section 6.0). The reactor fuels associated with this second batch of fuel 

pin FEW were primarily carbide fuels irradiated in the MTR and EBR-II (References C046, 

C812, P2035, U040, U307 and U1003). Production of metallographic mounts produced some of 

the previously approved AGHCF debris waste, and the fuel specimens in the AGHCF second 

batch of fuel pin FEW were separated from the previously approved AGHCF fuel pin FEW to 

resolve sodium concerns, not due to differences in radiological content. Therefore, as EPA has 

previously determined, the AK record sufficiently describes the radiological characteristics of the 

AGHCF second batch of fuel pin FEW (see EPA Docket Nos. A-98-49; II-A4-73 and A-98-49; 

II-A4-140). The radiological characterization and scaling factor development process for these 

containers are discussed in section 6.2.
16

(6) Container data are adequately traceable and are in the acceptable knowledge record.

EPA examined the traceability of AK data to understand the waste generation, packaging, 

processing, transport and characterization processes up to and including the characterization 

activities performed by ANL-CCP. The AGHCF RERTR FEW and second batch of fuel pin 

FEW containers are newly generated, so there are no original data packaging sheets or other 

generator documentation associated with individual containers. However, the AGHCF RERTR 

FEW and AGHCF second batch of fuel pin FEW packaged in the containers have been stored in 

the AGHCF as accountable materials;

7 therefore, there are historical records for the contents of 

the individual containers. 

ANL-CCP indicated that one container from the AGHCF RERTR FEW population and one 

container from the AGHCF second batch of fuel pin FEW less than 1⁄2-inch long have been 

generated and undergone ANL-CCP VE and radiological characterization. ANL-CCP provided 

EPA with VE BDR No. ANLRHVE12001 for AGHCF RERTR FEW Container No. 1089 and 

VE BDR No. ANLRHVE12010 for AGHCF second batch of fuel pin FEW Container No. 1108.8

Examination of these data indicated that each drum contains two 7-gallon cans, each of which 

holds one shield pot containing multiple fuel specimens. The shield pot, can and drum numbers 

are correlated in Table 3.

Table 3. Alpha Gamma Hot Cell Facility Fuel Examination Waste Data Tracking 

Summary

Drum Can Shield 

Pot

AGHCF 

Population

FEW Tracking 

Form Record

Fuel 

Specimens 

(A/G No.)

Reactor

1089 844 7003 RERTR FEW SP7003.pdf 549 ATR

1089 853 7105 RERTR FEW SP7105.pdf 306, 335, 342, 

356 ORR

1108 935 7211

Second Batch

of Fuel Pin 

FEW

SP7211.pdf 043, 057

EBR-II

1108 936 7107

Second Batch 

of Fuel Pin

FEW

SP7107.pdf 029, 033, 044, 

048, 049

MTR

Although the VE BDRs contain some information about the contents of each shield pot, the 

records are incomplete. ANL-CCP provided FEW tracking forms for each shield pot that identify

the specific specimens packaged into each shield pot (see Table 3). The FEW tracking forms also 

identify the reactor that irradiated the test materials, include brief descriptions of the FEW 

specimens, and note whether the current descriptions match the historic description in the Fissile 

Inventory Management System (FIMS) database (Reference U076). EPA spot-checked the 

 7 See footnote 5.

8 EPA did not explicitly evaluate data for AGHCF second batch of fuel pin FEW specimens longer than 1⁄2 

inch because the smaller AGHCF second batch of fuel pin FEW specimens are considered to be representative of the 

whole AGHCF second batch of fuel pin FEW population.
17

information in the FEW tracking forms by performing a brief comparison of this information 

with the data from the FIMS database (Reference U076). As a result of this analysis, EPA finds 

that the contents of each characterized container are traceable through the AK record from 

generation through characterization.

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

As mentioned in Item (4) above, several AK source documents contain historical fuel specimen 

information that was used to develop the inputs for ORIGEN2.2 modeling and scaling factor 

development (see section 6.2). Source Document P804 is an example of one of the records that 

contains information about the AGHCF RERTR FEW (Reference P804). EPA examined this 

source document and confirmed that it contains some of the information used in ORIGIN2.2

modeling. 

Second Batch of Fuel Pin Fuel Examination Waste

As mentioned in Item (4) above, several AK source documents contain historical fuel specimen 

information that was used to develop the inputs for ORIGEN2.2 modeling and scaling factor 

development (see section 6.2). ANL-CCP identified an ANL-developed spreadsheet as the 

primary source of information used by ANL-CCP for the ORIGEN2.2 modeling inputs. This 

spreadsheet was initially missing from the AK record and Attachment 4 [see Item (4)] but was 

added to the AK record as Source Document U344 during the course of EPA’s evaluation 

(Reference U344). EPA requested that ANL-CCP identify the AK source documents used to 

develop Source Document U344 so that EPA could verify the information and confirm data 

traceability in the AK record. ANL-CCP representatives stated that the information was from 

numerous AK source documents and that the easiest way to compile a list would be to compile 

the information and create a new source document to be added to the AK record. Notification to 

EPA when this new source document is available is a new T2 change (see Table 1). 

Independent of ANL-CCP’s new source document, EPA identified AK records for three of the 

fuel pin specimens identified in Source Document U344: alpha-gamma (A/G) Nos. 356ZZ-1, 

356ZZ-2 and 356ZZ-3 (References P615 and U344). Based on this limited comparison, EPA 

determined that the information in Source Document U344 is traceable to and supported by the 

AK record.

(7) The acceptable knowledge accuracy reports, characterization reconciliation reports and 

characterization information summaries were examined and found to be adequate. 

ANL-CCP provided separate draft AK accuracy reports, characterization reconciliation reports 

and characterization information summaries for the AGHCF RERTR FEW and the AGHCF 

second batch of fuel pin FEW. CCP-AK-ANLE-502, Revision 6, describes how AK accuracy is 

to be evaluated for Waste Stream AERHDM. EPA examined the draft AK accuracy reports, 

provided August 8, 2012, and found that both reports contained identical erroneous text that had 

not been updated to reflect the subject waste streams. ANL-CCP provided revised draft AK 

accuracy reports on September 14, 2012, which EPA found to be adequate. 
18

EPA also reviewed the draft characterization reconciliation reports and draft characterization 

information summaries, all four provided August 8, 2012, and found them to be adequate. 

Notification to EPA when AK accuracy reports are completed remains a T2 change (see 

Table 1). Notification to EPA when modifications are made to the characterization reconciliation 

reports and characterization information summaries remains a T2 change (Table 1 has been 

modified to clarify this T2 requirement).

(8) Personnel training was evaluated and was found to be adequate.

Personnel responsible for the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW

are the same as for the previously approved populations in Waste Stream AERHDM. ANL-CCP 

modified the nonconformance and corrective action procedure since EPA’s last evaluation of 

Waste Stream AERHDM. ANL-CCP provided documentation that Kevin Peters [AK Expert 

(AKE)] and Steve Schafer (AKE) are familiar with CCP-QP-005, Revision 21, March 5, 2012.9

Other aspects of the training requirements (i.e., current qualification cards, knowledge of the 

AKSR, trained to the current revision of CCP-TP-005, and training in determination of 

radiological contents of containers) were not impacted by inclusion of the AGHCF RERTR FEW 

and AGHCF second batch of fuel pin FEW.

(9) The waste stream information was examined and indicates that the waste stream 

including the Alpha Gamma Hot Cell Facility Reduced Enrichment Research and Test 

Reactor fuel examination waste and the second batch of fuel pin fuel examination waste 

is defense in origin. 

EPA previously evaluated and approved the defense waste determination of Waste Stream 

AERHDM for the AGHCF waste during the baseline inspection and subsequent T1 evaluations 

(see EPA Docket Nos. A-98-49; II-A4-73 and A-98-49; II-A4-140). EPA determined that the 

AK record contains sufficient evidence to demonstrate that all of the TRU wastes generated by 

AGHCF operations are contaminated with materials from atomic energy defense activities 

associated with naval reactor development, materials security and safeguards, and defense 

research and development activities.

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

The RERTR program is a defense program. As stated in section 6.0, the RERTR program is a 

nuclear nonproliferation program that was established at ANL in 1978 by DOE to minimize the 

use of highly enriched uranium in civil nuclear programs and, therefore, limit the amount of 

highly enriched uranium available for weapons production. The AGHCF RERTR FEW consists 

of residual RERTR fuel specimens and remnants from the irradiated materials involved in 

research experiments conducted in the AGHCF hot cells (References P012, P373, P374, P520, 

P551, P575, P816 and U076). Therefore, the AGHCF RERTR FEW containers that are added to 

Waste Stream AERHDM meet the WIPP requirement of defense-related waste.

 9 CCP-QP-005, “CCP TRU Nonconforming Item Reporting and Control,” Revision 21, March 5, 2012.
19

Second Batch of Fuel Pin Fuel Examination Waste

ANL has played an integral role supporting the underlying historical and ongoing defense 

missions associated with DOE test and research reactor programs. As stated in section 6.0, the 

reactor fuels associated with the AGHCF second batch of fuel pin FEW were primarily carbide 

fuels irradiated in the MTR and EBR-II. The EBR-II supported ongoing defense experiments 

throughout its 30-year operating life, including the Liquid Metal Fast Breeder Reactor Program 

and operations to support the Naval Nuclear Propulsion Program at Bettis Atomic Power 

Laboratory (Reference P599). ANL-CCP representatives indicated that separation of defenserelated contamination from nondefense-related contamination was not done and cannot be done 

during waste packaging. EPA accepts this determination. Therefore, the AGHCF second batch of 

fuel pin FEW containers that are added to Waste Stream AERHDM meet the WIPP requirement 

of defense-related waste.

(10) Several items reviewed by EPA as part of this technical evaluation were determined to 

not be impacted by the addition of Alpha Gamma Hot Cell Facility Reduced Enrichment 

Research and Test Reactor fuel examination waste and second batch of fuel pin fuel 

examination waste containers to Waste Stream AERHDM. See the EPA Tier 1 approval 

report for Alpha Gamma Hot Cell Facility fuel pin fuel examination waste (EPA Docket 

No. A-98-49; II-A4-140) for a full discussion of each of the items listed below. 

• The presence of SNL and HLW was not impacted by inclusion of the AGHCF RERTR 

FEW and AGHCF second batch of fuel pin FEW, and both SNL and HLW remain absent 

from Waste Stream AERHDM.

• Additional nonconformance documentation (nonconformance reports) and discrepancy 

resolution forms were not prepared for the AGHCF RERTR FEW and AGHCF second 

batch of fuel pin FEW, and implementation of the process for preparation of this 

documentation remains adequate.

• The waste stream profile form was not impacted by inclusion of the AGHCF RERTR 

FEW and AGHCF second batch of fuel pin FEW and remains adequate.

• Attainment of DQOs was evaluated and found to be adequate.

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team did not identify any AK-related findings or concerns relative to the 

inclusion of AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW in Waste Stream 

AERHDM during this T1 change evaluation.

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA approves the AGHCF RERTR FEW and AGHCF 

second batch of fuel pin FEW for inclusion in Waste Stream AERHDM and finds that all 

procedural requirements have been met. Based on this evaluation, there is one change to the AK 

T1 designations and two changes to the AK T2 designations. Characterization of any AGHCF 
20

FEW other than the RERTR FEW and second batch of fuel pin FEW discussed in this report or

the fuel pin FEW approved previously is a revised T1 change. Specifically, characterization of 

AGHCF crucibles and melts FEW remains a T1 change. Notification to EPA when the source 

document containing compiled information supporting Source Document U344 is available is a 

new T2 change. Also, this report explicitly identifies characterization information summaries as 

an example of a waste stream profile form attachment, revision of which continues to require T2 

notification to EPA. Table 1 shows the revised T1 and T2 changes in bold text. Some T1 and T2 

changes that were initiated during the baseline approval remain in effect; these are listed as 

applicable in section 6.1.

6.2 Radiological Characterization

EPA examined the radiological processes to assess the technical adequacy to support the 

inclusion of the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW in ANL-CCP 

RH Waste Stream AERHDM.

Waste Characterization Element Description

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

The radiological characterization of AGHCF RERTR FEW relies on DTC in conjunction with 

radionuclide-specific scaling factors that were developed for this waste stream based on two 

sources of information: 

• AK for RERTR FEW, including the ACCESS Database application FIMS, as 

summarized in CCP-AK-ANLE-501, Revision 8, Appendix E, and associated source 

documents.

• Radionuclide-specific results from the ORIGEN2.2 analysis based on the pre-irradiation 

composition, burnup and irradiation time for 354 RERTR fuel plates. 

EPA evaluated the radiological characterization methods used for AGHCF RERTR FEW in 

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

and the knowledge and understanding of the personnel involved in the RH waste characterization 

program. The EPA inspection team evaluated the following:

• Development of the DTC correlation factors for three gamma-emitting radionuclides and 

four drum configurations, determined by the type of shield pot in lower and upper 

locations within the drum. Using a waste density of 4.34 grams per cubic centimeter 

(g/cm3

) and Monte Carlo N-Particle Transport Code, Version 5 (MCNP5), separate 

modeling of the drum’s gamma dose rate was performed for each 1-curie source of 

cesium-137 (137Cs), 134Cs, and europium-154 (154Eu) for RERTR FEW.

• Determination of dose rate per curie of 137Cs [milliroentgens per hour per curie 

(mR/hr/Ci)] based on dose partitioning involving the DTC correlation factors and the 

scaling factors for the three gamma emitters considered. 

• Scaling factors developed based on ORIGEN2.2 modeling.
21

Second Batch of Fuel Pin Fuel Examination Waste

The radiological characterization of the AGHCF second batch of fuel pin FEW from the second 

batch of fuel pins relies on DTC in conjunction with radionuclide-specific scaling factors that 

were developed for this waste stream based primarily on the following two sources of 

information: 

• AK for second batch of fuel pin FEW including the ACCESS Database application 

FIMS, and the ANL spreadsheet (U344) as summarized in CCP-AK-ANLE-501, 

Revision 8, Appendix F, and support documents.

• Radionuclide-specific results from the ORIGEN2.2 analysis based on input from the 

ANL spreadsheet (U344), i.e., pre-irradiation composition, burnup and irradiation time 

for 103 of 104 specimen entries representing the inventory of the debris waste. 

EPA evaluated the radiological characterization methods used for the second batch of fuel pin 

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

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

characterization program. The EPA inspection team evaluated the following:

• Development of the DTC correlation factors for 137Cs and four drum configurations, 

determined by the type of shield pot in the lower and upper drum locations, using a 

nominal value for the waste density, based on MCNP5 modeling of the drum’s gamma 

dose rate using a 1-curie source of 137Cs.

• Scaling factors developed based on ORIGEN2.2 modeling.

Technical Evaluation

The EPA inspection team evaluated the following aspects:

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

and found to be adequate.

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

The radiological characterization process for AGHCF RERTR FEW was comparable to the 

processes observed at previous RH TRU sites. The main components consisted of: determining 

isotopic distributions to develop radionuclide-specific scaling factors; measuring each 

container’s external exposure (dose) rate; and computer modeling to correlate the container’s 

dose rate and radionuclide concentration. Each of these components is discussed in the 

subsequent parts of this section. The EPA inspection team prepared a flow diagram documenting 

the process, shown in Figure 1, below, based on CCP-AK-ANLE-501, Revision 8, Appendix E. 

The radiological characterization process for the AGHCF RERTR FEW was found to be 

technically adequate and appropriately documented. 
22

Second Batch of Fuel Pin Fuel Examination Waste

The radiological characterization process for the AGHCF second batch of fuel pin FEW was 

similar to that for the AGHCF RERTR FEW, with the same main components stated above. 

Each of the components is discussed in the subsequent parts of this section. The EPA inspection 

team prepared a flow diagram documenting the process, shown in Figure 2 below, based on 

CCP-AK-ANLE-501, Revision 8, Appendix F. The radiological characterization process for the 

AGHCF second batch of fuel pin FEW was found to be technically adequate and appropriately 

documented. 
23

 

 

 

 

 

Source: Based on CCP-AK-ANLE-501, Revision 8, Appendix E.

Figure 1. Flow Diagram of the Characterization Process: 

AGHCF RERTR Fuel Examination Waste

Using FIMS, identify the RERTR fuel plates 

that make up the waste stream 

Retrieve available records to determine the 

pre-irradiation fuel compositions, fuel burnup 

levels and reactor discharge dates for the 

RERTR fuel plates

Calculate 137Cs-based scaling factors by dividing 

the total curies of each radionuclide by the total 

curies of 137Cs in a metric ton of fuel

Two 7-gallon cans are placed in a 30-gallon drum in one the 

following configurations:

• One 1-in. shielded pot in each can

• One 3⁄4-in. shielded pot in the top can and one 1-in. 

shielded pot in the bottom can

• One 1-in. shielded pot in the top can and one 3⁄4-in. 

shielded pot in the bottom can

• One 3⁄4-in. shielded pot in each can

For each configuration, use MCNP5 to separately model three

gamma dose rates at one meter from the drum surface, based on 

a 1-Ci source of 137Cs, 134Cs, and 154Eu, as the DTC correlation

factors (mR/hr/Ci) for these three gamma emitters

Find the mean gamma dose rate (mR/hr) based on four 1-meter, 

90o measurements at the mid-height of the 30-gallon drum

Divide the 137Cs mean dose rate by the DTC correlation factor 

corresponding to the drum configuration to find the 137Cs 

activity in curies

Multiply the 137Cs activity by the scaling factors 

to determine activities of the other radionuclides 

of interest

Determine the uncertainties 

in the reported activities 

and masses of the 

radionuclides

Use ORIGEN2.2 to determine post-irradiation 

fuel compositions (radionuclide mass/curie 

distribution)

For each configuration, partition the dose for the three gamma 

emitters to determine the dose rate per curie of 137Cs (mR/hr/Ci) 

using the corresponding DTC correlation factors and scaling 

factors

Determine Scaling Factors: 

Determine and Execute DTC Correlation Factor:

Waste Packaging:

Waste is packaged in 1-in. or 3⁄4-in. shielded pots. Each pot is 

then packaged into a 7-gallon can.

Characterized 30-gallon drum is placed inside a 

55-gallon drum for shipment to WIPP

Determine Uncertainty: 
24

 

 

 

 

Source: Based on CCP-AK-ANLE-501, Revision 8, Appendix F.

Figure 2. Flow Diagram of the Characterization Process: 

AGHCF Second Batch of Fuel Pin Fuel Examination Waste

For each configuration, use MCNP5 to separately model the 

1-meter gamma dose rate based on a 1-Ci source of 137Cs as the 

DTC correlation factor in mR/hr/Ci

Find the mean gamma dose rate in mR/hr based on four 90°, 

1-meter measurements at mid-height of the 30-gallon drum

Divide the 137Cs mean dose rate by the DTC correlation factor 

corresponding to the drum configuration to find the 137Cs 

activity in curies

Determine and Execute DTC Correlation Factor:

Two 7-gallon cans are placed in a 30-gallon drum in one the 

following configurations:

• One 1-in. shielded pot in each can 

• One 3⁄4-in. shielded pot in the top can and one 1-in. 

shielded pot in the bottom can

• One 1-in. shielded pot in the top can and one 3⁄4-in. 

shielded pot in the bottom can

• One 3⁄4-in. shielded pot in each can

Waste Packaging:

Waste is packaged in 1-in. or 3⁄4-in. shielded pots. Each pot is 

then packaged in a 7-gallon can.

Using FIMS, identify the fuel specimens that 

make up the second batch of fuel pins

Retrieve available AK and determine the 235U 

enrichment, U/Pu ratio, 240Pu enrichment, 

burnup, and reactor discharge date for each fuel 

segment of the second batch of fuel pins

Calculate the 137Cs-based scaling factors by 

dividing the total curies of each radionuclide by 

the total curies of 137Cs in a metric ton of fuel

Multiply the 137Cs activity by the scaling factors 

to determine activities of the other radionuclides 

of interest

Determine the uncertainties 

in the reported activities 

and masses of the 

radionuclides

Use ORIGEN2.2 to determine post-irradiation 

fuel compositions (radionuclide mass/curie 

distribution) for the second batch of fuel pins

Determine Scaling Factors: 

Characterized 30-gallon drum is placed inside a 

55-gallon drum for shipment to WIPP

Determine Uncertainty: 
25

(2) The development of scaling factors based on cesium-137 was found to be technically 

adequate and correctly documented.

In the context of the ANL-CCP RH characterization program, a scaling factor is the ratio of the 

activity of a typically difficult-to-measure radionuclide, e.g., plutonium-239 (239Pu), to an easily 

measured radionuclide, in this case 137Cs. Assuming that the container’s measured gamma dose 

rate is attributable essentially to 137Cs, the container’s gamma dose rate and 137Cs concentration 

can be correlated. Using radionuclide-specific scaling factors, 238Pu, 240Pu, uranium-233 (233U), 

234U and other radionuclides are quantified by scaling them to the 137Cs content as represented by 

the container’s measured gamma dose rate. This allows the determination of multiple 

radionuclides by virtue of a single gamma dose-rate measurement of a container. 

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

Scaling factors for the RERTR FEW were calculated using ORIGEN2.2 to develop radionuclide 

distributions for each of the fuel plates documented in CCP-AK-ANLE-501, Revision 8, 

Appendix E. This is detailed in Calculation Package ANLE-RH-52, Revision 0, dated June 6, 

2011 (Reference U954).

The fuel plate segments were identified and ORIGEN2.2-generated data for each segment were 

gathered. The activities of each radionuclide of interest in a metric ton of fuel were summed and 

divided by the calculated 137Cs activity within the same amount of fuel to determine the 137Csbased scaling factor for that radionuclide. Records (235U enrichment, burnup, date of discharge 

from reactor) to be used as input data for ORIGEN2.2 runs were not available for 24 of the 354 

fuel plates comprising RERTR FEW. Representative data were used for the missing information.

Second Batch of Fuel Pin Fuel Examination Waste

Scaling factors for the second batch of fuel pins that generated the FEW debris were calculated 

using ORIGEN2.2 to develop radionuclide distributions for each of the 103 fuel pins identified, 

as stated in CCP-AK-ANLE-501, Revision 8, Appendix F. This is documented in Calculation 

Package ANLE-RH-63, Revision 0 (Reference U965).

The fuel pins were identified and ORIGEN2.2-generated data for each fuel pin were gathered. 

The activities of each radionuclide of interest in a metric ton of fuel were summed and divided 

by the calculated 137Cs activity within the same amount of fuel to determine the 137Cs-based 

scaling factor for that radionuclide. Typical ORIGEN input data supplied by ANL-E included 

235U enrichment, U/Pu ratio, 240Pu enrichment, burnup, and date of discharge from reactor 

(U344). 
26

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

found to be adequate.

To develop the DTC correlation factors, MCNP5 was used to model the following drum 

configurations, where each shield pot is in a 7-gallon can, two cans stacked inside a 30-gallon 

drum, overpacked by a 55-gallon drum:

• One 1-inch shield pot in each can. 

• One 3⁄4-inch shield pot in the top can and one 1-inch shield pot in the bottom can.

• One 1-inch shield pot in the top can and one 3⁄4-inch shield pot in the bottom can.

• One 3⁄4-inch shield pot in each can.

Reduced Enrichment Research and Test Reactor Program Fuel Examination Waste

For each of the above configurations, three DTC correlation factors (mR/hr/Ci) were determined 

via MCNP because three gamma emitters, 137Cs, 134Cs and 154Eu, were considered to be present 

in the fuel. The model used a nominal value for the effective fuel density of 4.34 g/cm3; 1 curie 

of radionuclide source, one source in each model, uniformly distributed in the shield pots, was 

used. For each configuration, dose partitioning was performed to determine the dose rate per 

curie of 137Cs (mR/hr/Ci), using the three determined DTC correlation factors and the scaling 

factors for the three gamma emitters

 

Second Batch of Fuel Pin Fuel Examination Waste

For each of the above configurations, the DTC correlation factor (mR/hr/Ci) for 137Cs was 

determined via MCNP using a nominal value for the effective fuel density and a 1 Ci of 137Cs as 

source, uniformly distributed in the shield pots. 

(4) Correlation of radionuclide values to the cesium-137 concentration for each drum was 

evaluated and was found to be technically adequate and appropriately documented.

Using the arithmetic mean of four 1-meter dose measurements made at the vertical midpoint at 

four 90-degree intervals, ANL-CCP applied the dose rate per curie of 137Cs, calculated in Item 

(3) above, to determine the 137Cs concentration in the drum. ANL-CCP used the dose 

measurements with radionuclide-specific scaling factors to quantify the following radionuclides: 

233U, 234U, 235U, 238U, 238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 241Am, 137Cs, barium-137m (137mBa) (137Cs 

progeny), strontium-90 (90Sr), and yttrium-90 (90Y) (90Sr progeny). This list includes other non 

WIPP-tracked radionuclides because all radionuclides that contribute to at least 95% of the 

radionuclide hazard, at least 95% of the thermal loading, and any radionuclide that contributes 

greater than 1% of the total must be reported, which includes 137mBa and 90Y10. 137mBa and 90Y 

are typically in secular equilibrium with their progenitors and are included for completeness. 

 10 Transportation is not within EPA’s regulatory purview; however, this information may be useful in 

understanding a container’s radionuclide composition.
27

Additionally, 235U must be considered for criticality purposes and 241Pu is calculated but not 

included in the TRU alpha activity concentration. The determination of radionuclide activities by 

ANL-CCP is technically adequate and correctly documented.

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

and found to be adequate.

The development of total measurement uncertainty (TMU) is based on the propagation of 

uncertainties present in 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.11

The TMU determination included contributions of the following:

• 137Cs activity measurement – dose rate measurement uncertainty and uncertainty due to 

the contribution of other gamma-emitting radionuclides.

• 137Cs DTC correlation – MCNP5 code and MCNP5 modeling uncertainties.

• Scaling factor uncertainty – ORIGEN2.2 benchmark uncertainty, uncertainty in the 

contribution of each RERTR plate for the RERTR FEW (or each fuel segment for the 

second batch of fuel pin FEW) to the radionuclide inventory, and drum-to-drum 

variations in the scaling factors.

For RERTR FEW, a general treatment of TMU is presented in CCP-AK-ANLE-501, Revision 8, 

Appendix E, and the detailed treatment of TMU is provided in Calculation Package ANLE-RH53, Revision 0 (Reference U955).

For the second batch of fuel pin FEW, a general treatment of TMU is presented in CCP-AKANLE-501, Revision 8, Appendix F, and the detailed treatment of TMU is provided in 

Calculation Package ANLE-RH-64, Revision 0 (Reference U966).

(6) The application of the dose-to-curie procedure and its documentation were evaluated, and 

both aspects were acceptable.

The DTC process was evaluated based on BDR Nos. ANLRHDTC12001 and 

ANLRHDTC12002, both of which documented the process for a single drum. The EPA 

evaluation team verified that the DTC BDR contained the following:

• “Attachment 1 – Measurement Control Report,” with all parameters acceptable.

• “Attachment 2 – Container Data Sheets” for all drums.

• “Attachment 4 – Batch Data Report Cover Sheet.” 

 11 Adding in quadrature is a standard statistical technique that allows one to use the square root of the sum 

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

contributing values were simply added. 
28

• “Attachment 5 – Batch Data Report Table of Contents.” 

• “Attachment 6 – Batch Data Report Narrative Summary.” 

• “Attachment 7 – ITR Checklist.” 

• “Attachment 8 – SPM Checklist.” 

• Waste container DTC conversion records with all required parameters for all drums, 

including TRU determinations.

• Evidence that the correct revision of CCP-TP-504, “CCP Dose-to-Curie Survey 

Procedure for Remote-Handled Transuranic Waste,” was used; Revision 11 was in effect 

when measurements were made.

• All forms had the correct signatures, i.e., Independent Technical Reviewer (ITR), Site 

Project Manager (SPM), DTC Operators and NCR Originators.

• The DTC conversion record (spreadsheet) indicated that the appropriate version of the 

AERHDM spreadsheet was used, i.e., for “2nd Batch Debris” for ANLRHDTC12002 and 

“RERTR” for ANLRHDTC12001, meaning that the appropriate scaling factors were 

used.

• “Relative Percent Difference”, CCP-TP-504, Attachment 10.

The EPA evaluation team verified that all DTC Operators and ITRs were on the list of qualified 

individuals for the applicable time periods. There were no concerns regarding the adequacy of 

the DTC BDRs.

(7) The determinations of the waste status as remote-handled and transuranic waste were 

evaluated and were found to be acceptable.

EPA reviewed the AGHCF RH-TRU 30-gallon waste drum data sheet for Container No. 1108, 

which showed the method of calculating a surface dose. This drum had a maximum dose rate on 

the 30-gallon container of 1,200 milliroentgens per hour (mR/hr), which calculated to 16,920 

mR/hr according to the dose rate multiplier. The form stated the drum number, the survey 

instrument that was used, the survey date and gamma readings in mR/hr. All forms were signed, 

as required. Measurements were taken at the drum surface on the side and top or bottom and 

middle and at a distance of 30 centimeters. The DTC BDRs discussed in Item (6) above 

indicated that all drums had TRU alpha activity concentrations greater than 100 nanocuries per 

gram. There were no concerns regarding the RH or TRU determinations of these wastes. The 

defense waste determination discussed earlier in Item (9) of section 6.1 confirms that RERTR 

debris and debris from second batch of fuel pins were derived from defense related activities. 

Summary of Radiological Characterization Findings and Concerns

The EPA evaluation team did not identify any radiological characterization-related findings or 

concerns relative to the inclusion of AGHCF RERTR FEW and AGHCF second batch of fuel pin 

FEW in Waste Stream AERHDM during this T1 change evaluation.
29

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the AGHCF RERTR FEW and AGHCF 

second batch of fuel pin FEW for inclusion in Waste Stream AERHDM and finds that all 

procedural requirements have been met. Based on this evaluation, there are no changes to the 

radiological characterization T1 or T2 designations. Characterization of any AGHCF FEW by 

application of new scaling factors for isotopic determination other than those documented in 

CCP-AK-ANLE-501 and approved by EPA remains a T1 change. Some T1 and T2 changes that 

were initiated during the baseline approval remain in effect.

6.3 Visual Examination

EPA performed a T1 review of two VE BDRs generated by CCP-ANL. The VE data were 

generated on the following dates:

• The data sheets contained in AGHCF RERTR FEW BDR ANLRHVE12001 were 

generated between May 2010 and December 2011 in accordance with procedure CCPTP-500, Revisions 8 or 11, “CCP Remote-Handled Waste Visual Examination,” effective 

dates July 24, 2008, and April 21, 2011, respectively.

• The data sheets contained in AGHCF second batch of fuel pin FEW BDR 

ANLRHVE12010 were generated between June 2011 and February 2012 in accordance 

with procedure CCP-TP-500, Revision 11, effective date April 21, 2011.

EPA has previously reviewed procedure CCP-TP-500 and determined it to be adequate and 

effective for the generation of VE data on RH waste. The process for generating the VE BDRs 

was unusual because the VE data sheets were generated some months before they were 

assembled into the BDR. It is unusual for BDRs not to be prepared at or close to the time of data 

generation, but this practice is not prohibited by procedure CCP-TP-500. 

RERTR BDR ANLRHVE12001

This BDR contained VE data from one 30-gallon container, No. 1089. The container included 

two 7-gallon cans, Nos. 844 and 853. Can No. 844 contained a single shield pot, No. 7003, and 

Can No. 853 contained a single shield pot, No. 7105. The waste description section of the data 

sheet for Shield Pot No. 7003 listed individual RERTR plates, including identification numbers. 

Shield Pot No. 7105 also contained RERTR plates, but these were generically referenced as 

“RERTR plates” with no identifying numbers. Although the inconsistent amount of detail used to 

identify waste items is not a contravention of CCP-TP-500 requirements, it does highlight how 

recording of VE data varies from operator to operator and over time. The VE events for these 

two shield pots were separated by over a year (May 5, 2010, to August 25, 2011). Data sheets 

were signed by two operators as required by the operating procedure. The BDR had been 

reviewed at the ITR and SPM levels. 
30

Second Batch of Fuel Pin FEW BDR ANLRHVE12010

This BDR contained VE data from one 30-gallon container, No. 1108. This container included 

two 7-gallon cans, Nos. 935 and 936. Can No. 935 contained a single shield pot, No. 7211, and 

Can No. 936 contained a single shield pot, No. 7107. The waste in each shield pot included “met 

mounts” and “cladding pieces” and “fines.” Data sheets were signed by two operators as required 

by the operating procedure. The BDR had been reviewed at the ITR and SPM levels. 

Both Batch Data Reports

No nonconformance reports were generated for these two BDRs.

The EPA inspector reviewed selected lists of qualified individuals for various dates. These 

demonstrated that VE data were generated by qualified personnel. EPA reviewed selected 

training records for the VE operators generating the data contained in BDRs ANLRHVE12001 

and ANLRHVE12010 and determined that the operators were trained in accordance with CCP 

requirements. The EPA inspector also verified that a Visual Examination Expert (VEE) had been 

appointed as required. The VEE performed the ITR review of both BDRs.

The EPA did not identify any concerns or findings when reviewing these VE data.

7.0 FINDINGS AND CONCERNS

Summary of Findings and Concerns

The EPA inspection team did not identify any findings or concerns relative to the addition of 30-

gallon containers of AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW to Waste 

Stream AERHDM during this T1 change evaluation.

8.0 CONCLUSIONS

Changes to Tiering

Table 1 was modified to update the list of approved AGHCF FEW populations to include 

AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW. Characterization of any 

AGHCF FEW other than the RERTR FEW and second batch of fuel pin FEW discussed in this 

report or the fuel pin FEW approved previously is a revised T1 change. Specifically, 

characterization of AGHCF crucibles and melts FEW remains a T1 change. Notification to EPA 

when the source document containing compiled information supporting Source Document U344 

is available is a new T2 change. Also, this report explicitly identifies characterization 

information summaries as an example of a waste stream profile form attachment, revision of 

which continues to require T2 notification to EPA. Table 1 shows the revised T1 and T2 changes

in bold text. Some T1 and T2 changes that were initiated during the baseline approval remain in 

effect; these are listed as applicable in sections 6.1, 6.2 and 6.3.
31

EPA concluded that the waste characterization processes of AK, radiological characterization 

and VE used to characterize RH TRU AGHCF RERTR FEW and AGHCF second batch of fuel 

pin FEW as part of ANL Waste Stream AERHDM are adequate, as evidenced by the records 

evaluated. There are no open issues relative to this T1 evaluation

Approval

This T1 change consisted of the use of AK, VE and radiological characterization for AGHCF 

RERTR FEW and AGHCF second batch of fuel pin FEW to be included as part of ANL Waste 

Stream AERHDM. Based on the results of this evaluation, EPA approves this T1 change to 

include AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW in Waste Stream 

AERHDM, consistent with the limitations specified in this report. ANL-CCP may continue to 

characterize previously approved RH AGHCF fuel pin FEW and debris waste and RH K-Wing 

FEW and debris waste consistent with the restrictions specified with the approvals listed in 

Appendix A to this report. In FY 2013, depending on the funding ANL-CCP may not be able to 

continue to characterize the wastes discussed in this report. CBFO must notify EPA when ANLCCP begins this effort.
A-1

ATTACHMENT A

APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION PROGRAM

Specific ANL RH Approval Date EPA Docket Number

ANL RH Baseline Approval January 2007 A-98-49; II-A4-73

Tier 1 Change – Approval of WIPP Waste Information System January 2007 A-98-49; II-A4-74

Tier 1 Change – Approval of Visual Examination for Newly 

Generated Waste June 2008 A-98-49; II-A4-102

Tier 1 Change – Approval of 100 additional drums of AGHCF debris 

waste to Waste Stream AERHDM October 2008 A-98-49; II-A4-136

Tier 1 Change – Addition of K-Wing debris waste to Waste Stream 

AERHDM September 2010 A-98-49; II-A4-132

Tier 1 Change – Addition of 120 containers of AGHCF debris waste 

to Waste Stream AERHDM September 2010 A-98-49; II-A4-134

Tier 1 Change – Addition of AGHCF fuel pin FEW to Waste Stream 

AERHDM November 2010 A-98-49; II-A4-140

Tier 1 Change – Addition of K-Wing FEW to Waste Stream 

AERHDM February 2012 A-98-49; II-A4-158

Tier 1 Change – Addition of K-Wing Solidified Liquid Waste to 

Waste Stream AERHDM June 2012 A-98-49; II-A4-162
B-1

ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION

ANL RH AK Container Tracking Spreadsheet, April 25, 2012

C046, Intra-Laboratory Memo to D.C. Parzyck re: DOE request for Information Regarding 

Materials Not Classified as Waste, Aubrey C. Smith, MCT/MSD Environmental Compliance, 

March 13, 1991

C812, Memo from T.S. Bray & R.V. Strain to M. Goldberg re: Characterization of N-Reactor 

Fuel Samples ANL ID 3983, T.S. Bray and R.V. Strain, October 4, 2000

C2025, Communication with Dan Pancake: Inventory Update and the Management of Potentially 

Reactive and Pyrophoric Materials, Kevin Peters, November 13, 2009, November 30, 2009

C2026, WMP Evaluation for the Addition of 100 FEW Containers, K. Peters, December 4, 2009

C2029, Waste Container Evaluation Memorandum for Waste Stream AERHDM, K.J. Peters, 

July 13, 2011, and additions dated through August 24, 2012

CCP-AK-ANLE-500, Central Characterization Project Acceptable Knowledge Summary Report 

for Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM, Revision 5, January 14, 

2010, Revision 10, May 22, 2012

CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste 

from Argonne National Laboratory-East, Revision 8, June 1, 2012

CCP-AK-ANLE-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, 

Revision 6, December 28, 2011

CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, New Mexico, Washington 

TRU Solutions, LLC, Revision 24, November 28, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers, Waste Stream AERHDM, July 12, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 –

Acceptable Knowledge Document Checklist, Waste Stream AERHDM, March 6, 2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 –

Acceptable Knowledge Source Document Information List, Waste Stream AERHDM, March 6, 

2012
B-2

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream AERHDM, 

and additional memorandum, February 20, 2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist, Waste Stream AERHDM, Lot 2nd Batch Debris, 

provided August 8, 2012

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist, Waste Stream AERHDM, Lot RERTR, provided 

August 8, 2012

Characterization Information Summary for AERHDM, Lot 33, Draft for Audit Purposes, 

Provided August 8, 2012

Characterization Information Summary for AERHDM, Lot 34, Draft for Audit Purposes, 

Provided August 8, 2012

Characterization Reconciliation Report, CRR-ANL-AERHDM-0033, Draft for Audit Purposes, 

Provided August 8, 2012

Characterization Reconciliation Report, CRR-ANL-AERHDM-0034, Draft for Audit Purposes, 

Provided August 8, 2012

DR023, Waste Stream AERHDM Volume Projection Corrections, K.J. Peters, June 23, 2010

DTC BDR ANLRHDTC12001, March 28, 2012

DTC BDR ANLRHDTC12002, March 28, 2012

FEW Tracking Form, Shield Pot 7003, May 6, 2010

FEW Tracking Form, Shield Pot 7105, November 15, 2011

FEW Tracking Form, Shield Pot 7107, August 15, 2011

FEW Tracking Form, Shield Pot 7211, November 10, 2011

Freeze File for CCP-AK-ANLE-500, Revision 10, Section 5.4.3.1.4, Provided September 14, 

2012

Freeze File for CCP-AK-ANLE-502, Revision 6, Section 3.1.2, Provided September 14, 2012

Inter-Office Correspondence, from Irene Quintana to CCP Records Custodian, Acceptable 

Knowledge Accuracy Report: Argonne National Laboratory Waste Stream Number AERHDM, 

Lot 33 RERTR Fuel Examination Waste, Audit Purposes Only, June 23, 2012
B-3

Inter-Office Correspondence, from Irene Quintana to CCP Records Custodian, Acceptable 

Knowledge Accuracy Report: Argonne National Laboratory Waste Stream Number AERHDM, 

Lot 34 Debris Waste from a Second Batch of Fuel Pins, Audit Purposes Only, June 23, 2012

P012, The Status of Uranium-Silicon Alloy Fuel Development for the RERTR Program, 

R.F. Domagala, T.C. Wiencek, H.R. Thresh and D. Stahl, Argonne National Laboratory Material 

Science Division, November 1, 1980

P373, Metallographic Analysis of Irradiated RERTR-3 Fuel Test Specimens, Meyer, Hofman, 

Strain, Clark and Stuart, ANL/NT/CP-103306, October 1–6, 2001

P374, The RERTR Program: A Status Report, A. Travelli, ANL/TD/CP-97495, September 28, 

1999

P520, Work Plan for the Examination of Fuel Nano-plates from the RERTR-3 Experiment in 

ATR; and Supplemental Instruction 305 for PIE of RERTR-3 on Rod/Specimen A/G 580AB, 

and Supplemental Instruction 286 Repolish Sample and Specimen Ring for EMPA, R.V. Strain, 

ET/IPS, IPS-338-00-00 and SI 305, January 20, 2000, and April 5, 2002

P551, Work Plan for the Examination of Fuel Plates from the RERTR-4 Experiment in ATR; 

Work Plan for Cutting H.B. Robinson Rod Sections and Loading into Shipping Tubes, and 

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