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: REDUCE D 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 2012i 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 Conc erns
................................ ................................ ................................ ....... 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 Characterizati on Program Attachment B: List of Documents Reviewed by EPA during T1 Evaluationii ABBREVIATIONS AND ACRONYMS
A/G alpha

- gamma AGHCF Alpha Gamma Hot Cell Facility AK acceptable knowledge AKE Acceptable Knowledge Expert AKSR acceptable knowledge summary rep ort 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 Cod e 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 Inven tory Management System g/cm 3 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 houriii mR/hr/Ci milliro entgens 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 yttrium1 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 remo te

- 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 pack aged in 30

- gallon containers 2 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 Base line 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 b aseline f inal i nspection r eport (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 t hat 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 CCP

AK

- ANLE

- 501, “Central Characterization Project Remote

- Handled Transuranic Radiological Characterization Technical Report for Remote

- Handled Trans uranic 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 de pending 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 othe r 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 . B ecause Appendix C to CCP

- AK

- ANLE

- 501 has not changed since that approval, EPA limited the radiological characterization and VE sco pe 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 si zes 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 reque st, 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 id entify any findings or concerns during this evaluation. Freeze files 3 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 t o 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 , E PA 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

- AK

ANLE

- 501, Revision 8, Appendix E

. (4) The VE process to identify waste material parameters ( WMPs ) and confirm physical charac teristics of AGHCF RERTR FEW and A GHCF 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 inspection

related 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 contr ol 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 contai ners of AGHCF RERTR FEW or AGHCF second batch of fuel pin FEW in waste stream AERHDM provided the waste in those containers fit s the waste pedigree and is characterized using the radiological characterization process es discussed in this report. Characteriz ation 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 radiol ogical 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 E PA 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 attachm ent, 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 s ections 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 AE RHDM 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 pote ntial 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 f uel 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 R H 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) Noti fication 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 Vall ey 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 v olume(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 ot her 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 u pdated 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 Addi tion 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 c hanges to EPA quarterly. ** Excluding changes that are editorial in nature or are required to address administrative concerns. New references that are in cluded 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 ty pe of measurement instrument or the use of the high

- range probe as described for CCP

- TP

- 504 for radiological characterization. † A NL

- CCP will report this T2 change immediately.6 2.0 PURPOSE OF TIER 1 EV ALUATIONS 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 t he 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 (V ol. 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 th e 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 baselin e 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 REPO RT This report presents the resu lts 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 Summar y Report for Argonne Remote

- Handled Debris Waste, Waste Stream: AERHDM,” Revision 10, dated May 22, 2012, and Appendices E and F to CCP

- AK

ANLE

- 501, Revision 8. This report presents the technical basis for and results of EPA’s approval decision. EPA’s appr oval 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 fol lowing 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, Jan uary 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 batc h 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 AG HCF 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 PERSO NNEL The EPA evaluation team members consisted of the personnel listed in Table 2 with their t echnical areas of expertise. EPA relied primarily on reviews of documents and information provided by ANL

- CCP. When additional information or clarifications were needed, EPA had8 discussions with Irene Quintana, the ANL

- E RH Project Manager, who served as t he 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 fue l 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 P2 032 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 sec tions (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 (Ref erence 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 h ot 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 p rogram is a nuclear nonp roliferation program that was established at ANL in 1978 by DOE t o 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 fab ricated 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 p rogram. ANL

- CCP identified 352 RERTR plates that contribute to this p opulation 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 pr eparation 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 verif y that the materials were free of any unreacted sodium contamination

. The reactor fuels as sociated 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 fue l 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)

. Pa ckaging 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 b e 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 an d 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

- AK

ANLE

- 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 f ormal 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 p rogrammatic 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 th e 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 traceabilit y.

• 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 A KSR, 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 Enrichme nt Research and Test Reactor fuel examination waste and s econd b atch of f uel p in f uel e xamination w aste and were found to be adequate. This T1 change requests approval of the radiological characterization approaches for the 30

- gallon containers of AGHCF R ERTR 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. ANL

CCP representatives stated that one drum of each population had been characterized at the time of the T1 request. A NL

- 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 r adiological 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 i s (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 wa ste 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. I n early 2010, ANL

- CCP determined that AGHCF FEW packaged in 30

- gallon containers should be included in Waste Stream AERHDM based on r eview 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 AERHD M 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 A GHCF 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, inc luding 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 stre am, 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.

• Characterizatio n 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 characteriza tion 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 determ ine 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

- d erived 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 Sept ember 14, 2012, freeze file that EPA reviewed

. EPA expects a formal revision of the certification plan to be completed before ANL

CCP’s first

- quarter 2013 submission of T2 changes to EPA for review and concurrence.13 Notification to EPA when formal revisio ns 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 p lan, 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

- TP

005 attachments; note that future changes to any attachments should reflect the version of CCP

TP

- 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 f ound 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 resu lt 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 Attac hment 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 rep ort (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 A dd Container Memoranda for Waste Stream AERHDM. ANL

- CCP indicated that one container from each of the T1

- subject population s 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 c ontains an Add Container Memorandum , dated March 14, 2012, that includes AGHCF second batch of fuel pin FEW C ontainer No. 1108 (Reference C2029). EPA also found that Source Document C2029 did not seem to contain an Add Container Memorandum for AGHCF RERTR FEW C ontainer 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 transcrip tion 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 Contai ner 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 t racking s preadsheet. (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 s ource d ocuments in conjunction with the descriptions of the radiological characterizatio n processes for the AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW . ANL

- CCP identified Source Document s P615, P804 and U 344 as examples of records that contain the AK used in development of the ORIGEN2.2 modeling inputs for radiological characteriz ation (see s ection 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 AKS R

. 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 pla ns. 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 revisio n 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 chan ge (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) , d ated 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 document s [see Item ( 6 ) for additional discussion about th e s e document s ] 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. Notificat ion 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 Enrichmen t 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 oper ators 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 W aste 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 evalua tion 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 r eview 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 macrophotogra phy . 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 process es for these contai ners are discussed in section 6.2

. Second Batch of Fuel Pin Fuel Examination Waste
T he 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 M TR and E BR

- II (References C046, C812, P2035, U040, U307 and U1003). Production of metallograp hic 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 ra diological 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 radiologica l 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 wa ste 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 o riginal data packaging sheets or other generator documentation associated with individual containers. However, t he AGHCF RERTR FEW and AGHCF second batch of fuel pin FEW packaged in the containers ha ve been stored in the AGHCF as accountable materials ; 7 th erefore, there are historic al 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 ge nerated and undergone ANL

- CCP VE and radiological characterization. ANL

- CCP provided EPA with VE BDR No. ANL RH VE12001 for AGHCF RERTR FEW C ontainer No. 1089 and VE BDR No. ANL RH VE12010 for AGHCF second batch of fuel pin FEW C ontainer No. 1108. 8 Examination of these data indicated that each drum contains two 7

- gallon cans, each of which h olds one shield pot containing multiple fuel specimens

. The shield pot, can and drum numbers are correlated in Table 3.
Table 3 . Alpha Gamma Hot Ce ll 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 t racking f orms for each shield pot that identif y the specific specimens packaged into each shield pot (see Table 3). The FEW t racking f orms also identify the reactor that irradiated the test materials, include brief descri ptions 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 AGHC F 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 t racking f orms by performing a br ief 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 s ection 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 u sed in ORIGIN 2.2 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 fa ctor development (see section 6.2). ANL

- CCP identified an ANL

- developed spreadsheet as the primary source of information used by ANL

- CCP for the ORIGEN 2.2 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 a nd 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 a dded 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 identif ied AK records for three of the fuel pin specimens identified in Source Docum ent 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 knowled ge accuracy reports, characterization reconciliation reports and characterization information summaries were examined and found to be adequate.
ANL

- CCP provided separate draft AK accuracy reports, c haracterization r econciliation r eports and c haracterizat ion i nformation s ummaries 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 review ed the draft c haracterization r econciliation r eports and draft c haracterization i nformation s ummaries, 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 Tabl e 1 ). Notification to EPA when modifications are made to the c haracterization r econciliation r eports and c haracterization i nformation s ummaries remains a T2 change (Table 1 has been modified to clarify this T2 requirement ). (8) Personnel training was evaluat ed 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 t he 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 w aste 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 developme nt, 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 n uclear 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 RERT R 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 cont ainers that are added to Waste Stream AERHDM meet the WIPP requirement of defense

- related waste.

9 CCP

- QP

- 005, “CCP TRU Nonconform ing 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 separat ion of defense

related 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 A ERHDM 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 f uel 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 s tream 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 de signations and two changes to the AK T2 designation s. Characterization of any AGHCF20 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, charact erization 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 c haracteri zation 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 change s 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 techn ical adequacy to support the inclusion of the AGHCF RERTR FEW and AGHCF secon d 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 conju nction 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, a nd 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 AG HCF 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 fo llowing:

• 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 centi meter (g/cm 3 ) 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 ( 137 Cs), 134 Cs, and europium

- 154 ( 154 Eu) for RERTR FEW.

• Determination of dose ra te per curie of 137 Cs [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, an d 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 p ersonnel involved in the RH waste characterization program. The EPA inspection team evaluated the following:

• Development of the DTC correlation factors for 137 Cs and four drum configurations, determined by the type of shield pot in the lower and upper dru m 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 137 Cs.

• 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 proces s 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 (do se) 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, s hown 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 Wast e 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. Th e 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 technical ly 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 le vels and reactor discharge dates for the RERTR fuel plates

Calculate 137 Cs

- based scaling factors by dividing the total curies of each radionuclide by the total curies of 137 Cs in a metric ton of fuel Two 7

- gallon cans are placed in a 30

- gallon drum in on e 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 po t in each can

For each configuration, use MCNP5 to separately model th r e e gamma dose rate s at one meter from the drum surface, based on a 1

- Ci source of 137 Cs, 134 Cs , and 154 Eu, as the DTC correlation factor s (mR/hr/Ci) for these three gamma emitters

F ind the mean gamma dose rate (mR/hr) based on four 1

- meter, 90 o measurements at the mid

- height of the 30

- gallon drum

Divide the 137 Cs mean dose rate by the DTC correlation factor corresponding to the drum configuration to find the 137 Cs activity in c urie s Multiply the 137 Cs activity by t he 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 fue l compositions (radionuclide mass/curie distribution)

For each configuration, partition the dose for the three gamma emitters to determine the dose rate per curie of 137 Cs (mR/hr/Ci) using the corresponding DTC correlation factors and scaling factors Det ermine Scaling Factor s :

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: A GHCF Second Batch of Fuel P in F uel E xamination W aste For each configuration, use MCNP5 to separately model the 1

- meter gamma dose rate based on a 1

- Ci source of 137 Cs as the DTC co rrelation 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 137 Cs mean dose rate by the DTC correlation factor corresponding to the drum configuration to fin d the 137 Cs 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.

s hielded 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

- gall on can. Using FIMS, identify the fuel specimens that make up the second batch of fuel pins

Retrieve available AK and determine the 235 U enrichment, U/Pu ratio, 240 Pu enrichment, burnup , and reactor discharge date for each fuel segment of the second batch of fuel pins

Calculate the 137 Cs

- based scaling factors by dividing the total curies of each radionuclide by the total curies of 137 Cs in a metric ton of fuel

Multiply the 137 Cs activity by the scaling factors to determine activities of the other radio nuclides 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 Determi ne 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 correc tly 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 ( 239 Pu), to an easily measured radionuclide, in this case 137 Cs. Assuming that the container’s measured gamma dose rate is attributable essentially to 137 Cs, the container’s gamma dose rate and 137 Cs concentration can be correlated. Using radionuclide

- specific scaling factors, 238 Pu, 240 Pu, uranium

- 233 ( 233 U), 234 U and other radionuclides are quantified by scaling them to the 137 Cs 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, App endix 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 inter est in a metric ton of fuel were summed and divided by the calculated 137 Cs activity within the same amount of fuel to determine the 137 Cs

based scaling factor for that radionuclide

. Records ( 235 U enrichment, burnup, date of discharge from reactor) to be u sed 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 137 Cs activity within the same amount of fuel to determine the 137 Cs

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

- E included 235 U enrichment, U/Pu ratio, 240 Pu 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 bo ttom 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, 137 Cs, 134 Cs and 154 Eu, were considered to be present in the fuel. The model used a nominal value for the effective fuel density of 4.34 g/cm 3 ; 1 curie of radionuclide source, one source in each model, uniformly distributed in the shield pots, was used. F or each configuration, dose partitioning was performed to determine the dose rate per curie of 137 Cs (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 Examin ation Waste For each of the above configurations, the DTC correlation factor (mR/hr/Ci) for 137 Cs was determined via MCNP using a nominal value for the effective fuel density and a 1 Ci of 137 Cs as source, uniformly distributed in the shield pots. (4) C orrelation 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 137 Cs, calculated in Item (3) above, to determine the 137 Cs concentration in the drum. ANL

- CCP used the dose measurements with radionuclide

- specific scaling factors to quantify the fol lowing radionuclides : 233 U, 234 U, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am, 137 Cs, barium

- 137m ( 137m Ba) ( 137 Cs progeny), strontium

- 90 ( 90 Sr), and yttrium

- 90 ( 90 Y) ( 90 Sr progeny). This list includes other non WIPP

- tracked radionuclides because a ll 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 137m Ba and 90 Y 10

. 137m Ba and 90 Y are typica lly 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, 235 U must be considered for criticality purposes and 241 Pu is calculated but not included in the TRU alpha activity concentration. The determination of radio nuclide 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 contribution s of the following:

• 137 Cs activity measurement

– dose rate measurement uncertainty and uncertainty due to the contribution of other gamma

- emitting radionuclides.

• 137 Cs DTC correlation

– MCNP5 code and MCNP5 modeling uncertainties.

• Scaling factor uncerta inty

– 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.
Fo r 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

- RH

53, Revision 0 (Reference U955)

. For the second batch of fuel pin FEW , a general treatment of TMU is presented in CCP

- AK

ANLE

- 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 documentati on 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 f ollowing:

• “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 sta tistical 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.”

• “Attachm ent 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 revi sion 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 M anager (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 “2 nd Batch Debris” for ANLRHDTC12002 and “RERTR” for ANLRHDTC12001, meaning that t he 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 c oncerns 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

- g allon w aste d rum d ata 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 d efense waste determination d iscussed earlier in Item ( 9 ) of s ection 6.1 confirms that RERTR debris and debris from second batch of fuel pin s were derived from defense related activities. Summary of Radiological Characterization Findings and Concerns
The EPA evaluation team did n ot 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 a nd 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 RERT R FEW BDR ANLRHVE12001 were generated between May 2010 and December 2011 in accordance with procedure CCP

TP

- 500, Revisions 8 or 11, “CCP Remote

- Handled Waste Visual Examination,” effective date s July 24, 2008, and April 21, 2011, respectively.

• The data sh eets 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 o n 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 BD Rs 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 C an No. 853 contained a single shield pot, No. 7105. The waste description section of the data sheet for S hield P ot No. 7003 listed individual RERTR plates, including identifi cation numbers. Shield P ot 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

- 5 00 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 level s
.30 Second Batch of Fuel P in FEW BDR ANLRHVE12010
This BDR contained VE data from one 30

- gallon container , No. 1108. This container included two 7

- gallon cans, Nos. 9 35 and 936. Can No. 935 contained a single shield pot, No. 7211 , and C an 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 requ ired by the operating procedure. The BDR had been reviewed at the ITR and SPM levels.
Both B atch D ata R eport s No nonconformance reports were generated for these two BDRs. The EPA inspector reviewed selected l ist s of q ualified i ndividuals for various da tes

. T hese 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 ac cordance with CCP requirements. The EPA inspector also verified that a Visual E xamination Expert (VEE ) had been appointed as required. The VEE performed the ITR review of both BDRs. The EPA did not identify any c oncerns or f indings when reviewing these VE data.
7.0 FINDINGS AND CONCERN S Summary of Findings and Concerns
The EPA i nspection t eam 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 AE RHDM 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 RE R TR FEW and AGHCF second batch of fuel pin FEW

. Characterization of any AGHCF FEW other th an 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 sou rce document containing compiled information supporting Source Document U344 is available is a new T2 change. Also, this report explicitly identifies c haracterization information summaries as an example of a waste stream profile form attachment, revision o f which continues to require T2 notification to EPA. Table 1 shows the revised T1 and T2 change s 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 s 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 t he 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 AN L 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 cont inue 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

- C CP may not be able to continue to characterize the wastes discussed in this report. CBFO must notify EPA when ANL

CCP begins this effort.A

- 1 ATTACHMENT A APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION PROGRAM
Specific ANL RH Approval Date EPA Docket N umber 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

– Additi on 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 Str eam 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

- 162B

- 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 A ddition 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 Au gust 24, 2012 CCP

- AK

- ANLE

- 500 , Central Characterization Project Acceptable Knowledge Summary Report f

or Argonne Remote

- Handled Debris Waste, Waste Stream: AERHDM, Revision 5, January 14, 2010, Revision 10, May 22, 2012 CCP

- AK

- ANLE

- 501, Central Characteriza tion Project Remote

- Handled Transuranic Radiological Characterization Technical Report for Remote

- Handled Transuranic Debris Waste f rom Argonne National Laboratory

- East, Revision 8, June 1, 2012 CCP

- AK

- ANLE

- 502, Central Characterization Project RH TRU Wast e 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, 2012B

- 2 CCP

- TP

- 005, Revision 24, CCP Ac ceptable 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, Atta chment 13

– CCP Waste Stream Characterization Checklist, Waste Stream AERHDM, Lot 2 nd Batch Debris, p rovided August 8, 2012 CCP

- TP

- 005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13

– CCP Waste Stream Characterization Checklist, Waste Stream AERHDM, Lot RERTR, p rovided 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 Septemb er 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, 2012B

- 3 Int er - 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
P 012, 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 RERT R

- 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 th e 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 Ap ril 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 Supplemental Instruction 153, R.V. Strain, Bob Strain, IPS

- 375

- 00

- 00,

- 01

- 00, IPS

- 376

- 00

- 00, March 16, 2001, April 12, 2001 , and March 26, 2001 P575, Work Plan for the Examination of Fuel Plates from the RERTR

- 4 Experiment in ATR, Revision 1, R.V. Strain, IPS

- 400

- 01

- 00, February 22, 2002 P599, The Defense Programs Origin of T ransuranic Waste at Argonne National Laboratory

West, H.F. McFarlane, ANL

- NT

- 192, November 2001 P615 , Information on Fuel Elements Examined at the AGHCF at ANL from November 1971 to August 7, 1995 Based on Waste Consolidation Records, P. Kuan, EDF

- 6685, Re vision 0, May 19, 2006 P804, Summary Report on the HFED Miniplate Irradiations for the RERTR Program ANL ID 41175, R.L. Senn, ORNL

- 6539, April 1989 P816, IPS

- 269

- 04

- 01, Metallography on an Additional RERTR

- 1 Microplate, A/G 549V ANL ID 1210, R.V. Strain, I PS

- 269

- 04

- 01, September 25, 1998 P2032, Building 212 Alpha Gamma Hot Cell Facility Deactivation Project Plan with Appendix 1, 2 and 3, D. Pancake, M. Sodaro, D. Hodge, NOD

- 190

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- 00, 191

- 00

- 00, 192

- 00

- 00, 194

- 00

- 00, August 26, 2009, August 14, 2009, August 21, 2009 P2035, Results of Testing Metallographic (Met) Mounts for the Presence of Sodium, Performed in the Alpha Gamma Hot Cell Facility (AGHCF), D. Pancake, NOD

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- 00

- 00, Revision 0, May 1, 2010B

- 4 Radioactive Waste Management Manual, U.S. Department of E nergy, DOE M 435.1

- 1, June 19, 2001 Training documentation for K. Peters and S. Schafer, provided August 8, 2012 U040, Spreadsheet Correlating Number Quota with Quota Title and Number Project, July 31, 2001 U076, AGHCF Fissile Inventory Management System D atabase, July 16, 2001 and October 2009 U307, Report 105

– Custodian Batch Balance (Pure), Report 105, December 1, 2004 U344, AGHCF Fuel Pins

– Second Batch U903, CCP Calculation Package: AGHCF Fuel Information Input Check, J. Vance, ANLE

- RH

20, Revision 0 , July 8, 2010 U905, CCP Calculation Package: ORIGEN2.2 Analysis of AGHCF FEW, J. Holderness, ANLE

RH

- 22, Revision 0, July 8, 2010 U908, CCP Calculation Package: Determination of Reportable Radionuclides, J. Holderness, ANLE

- RH

- 25, Revision 0, July 8, 20 10 U926, CCP Calculation Package: DTC Correlation for Debris in Shielded Containers, J. Holderness, ANLE

- RH

- 30, Revision 0, January 24, 2011 U927, CCP Calculation Package: Surface Dose Rate Multiplier AGHCF FEW Drums, J. Holderness, ANLE

- RH

- 31, Revision 0, January 24, 2011 U953, CCP Calculation Package: Comparison of SFs from T wo S ets of Fuel Pins for ANLE Debris Waste, J. Vance, ANLE

- RH

- 51, Revision 0, June 6, 2011 U954, CCP Calculation Package: Development of SFs for RERTR FEW Debris, J. Vance, ANLE

- R H

- 52, Revision 0, June 6, 2011 U955, CCP Calculation Package: AGHCF Uncertainty for Drums with RERTR Plates, J. Holderness, ANLE

- RH

- 53, Revision 0, June 6, 2011 U956, CCP Calculation Package: DTC Values for RERTR in Shielded Containers, J. Holderness, AN LE

- RH

- 54, Revision 0, June 6, 2011 U957, CCP Calculation Package: DTC and Related Calcs for RERTR Drum Characterization, J. Holderness, ANLE

- RH

- 55, Revision 0, August 2, 2011 U963, CCP Calculation Package: AGHCF Fuel Information Input Check

- 2 nd Batch of Pins, J. Vance, ANLE

- RH

- 61, Revision 0, July 22, 2011B

- 5 U964, CCP Calculation Package: ORIGEN2.2 Analysis of 2 nd Batch of FEW, J. Holderness, ANLE

- RH

- 62, Revision 0, July 27, 2011 U965, CCP Calculation Package: Scaling Factor Developmen

- 2 nd Batch of Pins, J

. Vance, ANLE

- RH

- 63, Revision 0, July 27, 2011 U966, CCP Calculation Package: Uncertainty for Shielded Debris from 2 nd Batch of Fuel, J. Holderness, ANLE

- RH

- 64, Revision 0, July 27, 2011 U967, CCP Calculation Package: 2 nd Fuel Batch Determination of Repo rtable Radionuclides, J. Vance, ANLE

- RH

- 65, Revision 0, July 27, 2011 U968, CCP Calculation Package: DTC and Related Calcs for 2 nd Batch of Debris, J. Holderness, ANLE

- RH

- 66, Revision 0, July 27, 2011 U1003, Argonne Special Material Receipt and Transfer Documentation by A/G Number, Various Authors, 1964

– 1997 U2013, 30 Gallon Drum (Spec 7A) RH

- TRU Debris + FEW Configuration Update for WIPP Operating Record (Change Notice #1) Remote Handled Heterogeneous Debris from the Argonne National Laboratory (AERHDM ), September 21, 2010 VE BDR ANLRHVE12001, January 30, 2012 VE BDR ANLRHVE12010, March 12, 2012