DOCKET NO: A-98-49; II-A4-196 EPA AIR E-DOCKET NO: EPA-HQ-OAR-2001-0012-0448

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

EPA TIER 1 EVALUATION OF THE CENTRAL CHARA CTERIZATION PROGRAM REMOTE-HANDLED TRANSURANIC WA STE CHARACTERIZATION PROGRAM FOR THE SAVANNAH RIVER SITE: ADDITION OF DRUM NUMBER BC0152

U.S. Environmental Protection Agency Radiation Protection Division Center for Waste Management & Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

December 2014i TABLE OF CONTENTS Section Page Acronyms and Initializations .................................................................................................. ........ ii
1.0 Introduction .................................................................................................................. ........1
2.0 Purpose of Tier 1 Evaluations ..............................................................................................2
3.0 Purpose of This Report ........................................................................................................ 3
4.0 Scope of the Tier 1 Evaluation.............................................................................................3
5.0 EPA Evaluation Personnel ...................................................................................................3
6.0 Technical Evaluation .......................................................................................................... .4
6.1 Acceptable Knowledge ........................................................................................... 5
6.2 Radiological Characterization ................................................................................. 6
7.0 Findings and Concerns .......................................................................................................12
8.0 Conclusions ................................................................................................................... .....12

TABLES

Table 1. EPA Tier 1 Evaluation Team Members ............................................................................ 3

FIGURES
Figure 1. Characterization of Drum No. BC0152 ........................................................................... 9

ATTACHMENTS
Attachment A: Approval Summary for Sava nnah River Site Remote-Handled Waste Characterization Program
Attachment B: List of Documents Re viewed by EPA during T1 Evaluationii ACRONYMS AND INITIALIZATIONS
AK acceptable knowledge AKSR acceptable knowledge summary report
Am americium
BCLDP Battelle Columbus Laborat ories Decommissioning Project BDR batch data report
CBFO Carlsbad Field Office CCP Central Characterization Program CFR Code of Federal Regulations
CH contact-handled
Ci curie
Co cobalt
Cs cesium DOE U.S. Department of Energy
DTC dose-to-curie EA expert analyst EPA U.S. Environmental Protection Agency ISOCS In Situ Obje ct Counting System LWR light water reactor
MCNP5 Monte Carlo N-Particle Tran sport Code RSICC Computer Code Collection, Oak Ridge National Laboratory mrem/hr millirem per hour NABC Non Destructive Assay Box Counter NDA nondestructive assay Pu plutonium
RH remote-handled SC&A S. Cohen and Associates (SC&A, Inc.) SCG summary category group SF scaling factor
SRS Savannah River Site
T1 Tier 1
T2 Tier 2 TMU total measurement uncertaintyiii TRU transuranic
U uranium
WIPP Waste Isolation Pilot Plant1 1.0 INTRODUCTION
This report supports the U.S. E nvironmental Protection Agency’s (EPA’s) approval of a Tier 1 (T1) change to characterize Drum No. BC 0152 under the approved remote-handled (RH) transuranic (TRU) waste characterization program at the U.S. Department of Energy’s (DOE’s) Savannah River Site (SRS). In April 2012, EPA approved the Central Characterization Program (CCP) 1 to characterize RH TRU waste at SRS. EP A concludes that by using the EPA-approved RH radiological waste characteri zation program elements discussed in this report, SRS-CCP can characterize the TRU sludge waste container, Drum No. BC0152, genera ted at the Battelle Columbus Laboratory (BCL) for disposal at th e Waste Isolation Pilot Plant (WIPP). This container is added to an RH sludge/debris waste stream, SR-BCLDP .003, which EPA approved in September 2010 as a T1 change.
On May 30, 2014, as a T1 change request, the Ca rlsbad Field Office (CBF O) requested EPA to approve the radiological charac terization of Drum No. BC0152. Because SRS-CCP did not use new equipment or processes for radiological characterization of the subject waste, EPA conducted a desktop review of this change. This waste container originally belonged to SRS Contact-Handled (CH) Waste Stream SR-B CLDP.003.001. However, due to the surface dose rate measured above 200 millirem per hour, the cont ainer was classified as a RH waste container and was subjected to radiological characteri zation to confirm the designation and quantify radiological contents re quiring EPA approval.

The Battelle Columbus Laboratories Decommi ssioning Project (BCLDP) at BCL, Columbus, Ohio, generated more than 100 waste containers as part of laboratory dismantling activities and partially characterized them. El even of which belonged to hydr aulic sludge and debris waste stream with seven RH, three CH and one low- level containers. In 2005, when BCL ceased TRU waste operations, BCL shipped all of the BCLDP c ontainers to SRS for st orage, characterization and disposal at WIPP. As of 2010, all BCL waste containers except the su bject waste container, BC0152, in storage at SRS since 2005, have been characterized and shipped to WIPP for disposal. Once this container in this T1 change leaves SRS, no additional BCL waste characterization at SRS is necessary.
In August 2008, EPA issued a baseline approval of the SRS-CCP RH TRU waste characterization program where BCL RH debris waste stream was characterized (see EPA Docket No. A-98-49; II-A4-104). Subsequentl y, SRS-CCP sought two T1 change approvals listed in Attachment A. The September 2010 T1 change approval consisted of six RH waste streams, SR-BCLDP.003 being one of those (s ee EPA Docket No. A-98-49; II-A4-129). The August 2008 SRS-CCP RH baseline approval stated th at if SRS-CCP were to characterize any non-BCL waste for WIPP disposal, a new baselin e inspection and approva l would be necessary. In April 2012, EPA approved the SRS-CCP RH TR U waste characterization program (see EPA Docket No. A-98-49: II-A4-161). Attachment A lis ts subsequent tiering changes to the April 2012 RH baseline approval.

1 The Central Characterization Program was formerly known as the Central Char acterization Project, and both names are used in the documentation reviewed for this evaluation.2 EPA conducted a continued compliance insp ection of SRS-CCP’s CH and RH waste characterization programs that were operationa l in August 2014. This inspection did not cover the RH TRU waste characterization program for BCL waste as no BCL-originated waste remains at SRS requiring to maintain an active BCL wa ste-specific program. EPA concluded that SRSCCP continues to adequately implement the CH and RH TRU waste characterization processes, procedures and equipment at SRS that EPA a pproved as July 2006 and April 2012 baselines and subsequent tiering changes listed in Attachment A.
EPA did not identify any findings or concerns during this eval uation. As a result of this evaluation, EPA did not make any changes to the SRS-CCP RH T1 and Tier 2 (T2) designations established during the baseline approval and modi fied during subsequent T1 evaluations and the 2014 continued compliance inspection. The tiering de signations, therefore, presented in Table 2 of the final report for EPA’s 2014 continued compliance inspection of SRS-CCP (see EPA Docket No. A-98-49; II-A4-195; report forthcoming) remain in effect.
Based on the information provided, EPA concl uded that SRS-CCP used the EPA-approved system of controls to character ize Drum No. BC0152. This single container of TRU waste is the subject of this T1 report, and EP A’s approval is limited to this waste container. Characterization of any RH solid/sludge waste (S3000) by SRS-CCP remains a T1 change.
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 Title 40 of the Code of Federal Regulations [40 CFR 194.8(b)(3)].

2.0 PURPOSE OF TIER 1 EVALUATIONS
Certain changes to the waste characterization act ivities from the date of the site’s baseline inspection must be reported to and, if a pplicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulatio ns and incorporated into the SRS-CCP RH baseline final report (see EPA Docket No. A-98-49; II-A4-161).
Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must perf orm a single baseline inspection of a TRU waste generator site’s waste characteri zation program. The purpose of EPA’s baseline inspection is to approve the site’s waste char acterization program, based on the demonstration that the program’s components, with applicable conditions and limitations, can adequately characterize TRU wastes and comply with the re gulatory requirements imposed on TRU wastes destined for disposal at the WIPP.
Following EPA’s baseline approval, EPA is author ized to evaluate and approve changes, if necessary, to the site’s approved waste char acterization program by conducting additional inspections under the authorit y 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 in spection reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes fo r approval, EPA may conduct a site inspection to observe implementation of the change or can opt to conduct a desktop review of information3 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.

3.0 PURPOSE OF THIS REPORT
This report presents the results of EPA’s evalua tion of a T1 change to add Drum No. BC0152 to SRS-CCP’s approved waste char acterization program as partof RH Waste Stream SRBCLDP.003. This report presents the technical ba sis for and results of EPA’s approval. EPA’s approval decision of the addition of Drum No. BC0152 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).
Any of the T1 change request-specific documents me ntioned in this report can be requested from the following address:
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 EPA’s T1 evaluation is the acceptable knowledge (AK) and radiological characterization approach used to characte rize BCLDP RH Drum N o. BC0152. Section 6.0 of this report details the AK and radiological char acterization technical elements assessed during this evaluation.

5.0 EPA EVALUATION PERSONNEL

The EPA evaluation team member s consisted of the personnel listed in Table 2 with their affiliations and functions. EPA relied primarily on reviews of documents and information provided by SRS-CCP. When additional informati on or clarifications were needed, EPA had discussions with Irene Joo, the CCP RH Project Manager, who served as the point of contact for this T1 evaluation.

Table 1. EPA Tier 1 Evaluation Team Members

Name Affiliation & Function Rajani Joglekar Lead Inspector, EPA Kira Darlow Technical Evaluato r – Acceptable Knowledge, 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&A4 6.0 TECHNICAL EVALUATION
BCLDP Hydraulic Sludge and Debris Generation and Evaluation Timeline
Between 1988 and 1997, BCLDP decontamination and demolition operations generated approximately 50 small bags of debris and ab sorbed sludge while cleaning out waste from historic hydraulic oil leaks in to the pump room with dose rate ranging 20-2000 mR/hr. In 2002, 11 hydraulic sludge and debris dr ums (Sludge/debris Waste Stream S3212) were generated. The measured dose rate for seven of these contai ners ranged from 80 to 600 mR/hr. In 2003, the measured dose rate for the four remaining drums ranged from 30 to 1,250 mR/hr. In 2002, the BCLDP Health Physics Survey Report for BC 0152 identified a maximum dose rate of 150 mR/hr, therefore it was classified as a CH dr um. The Discrepancy Report (DR017) prepared by SRS-CCP in February 2008, delineated 11 hydrauli c sludge and debris as seven RH waste (SRBCLDP.003), three CH (including BCL0152) a nd one low-level wa ste containers.

RH Waste Overview
Drum No. BC0152 is part of Waste Stream SR-BCLDP.003, which consists of absorbed hydraulic sludge and debris waste generated dur ing decontamination and demolition of the hot cells in the Building JN-1 Hot Cell Laboratory at the Battelle West Jefferson North Facility. Each drum in Waste Stream SR-BCLDP.003, incl uding Drum No. BC0152, contains greater than 50 percent by volume absorbed hydraulic sludge.

Based on historical BCLDP characterization and survey results, Drum No. BC0152 was originally included in co ntact-handled TRU Waste St ream SR-BCLDP.003.001, and was characterized under the SRS-CCP CH TRU prog ram including non-destructive assay (NDA). However, when SRS-CCP was readying the cont ainer for shipment to WIPP the contact dose 2 rate surveys indicated that at leas t one part of the container (a “ hot spot”) measured in excess of 200 millirem per hour (mrem/hr). SRS-CCP, therefor e, reassigned this drum to RH TRU Waste Stream SR-BCLDP.003. The reason for two diff erent contact dose rate measurements on the same BCL container is speculated as shifting of waste material during movement and handling of the container for characterization. SRS-CCP determ ined that the hot spot (or spots) corresponded to pieces of concrete floor that were generated during demolition of the JN-1 hot cell. AK indicated that the floor had been washed repeatedly over the year s of operation using a variety of cleaning fluids, including water, solvents and chelating agents.

Documents Provided

EPA evaluated the SRS-CCP documentation that supported the additi on of Drum No. BC0152. Initially, AK document, CCP-AK-SR-530, for RH hydraulic sludge and de bris waste had only seven drums in waste stream SR-BCLDP.003. In 2012, this document was revised to include three additional drums including BCL0152 as a new CH hydraulic sludg e and debris waste

2 Rem or millirem is a unit of dose equivalent, which is often called dose or when it is expressed per unit time, a dose rate . The criterion for RH determination is expressed in terms of a dose rate in rem, which, while technically incorrect, is commonly used. In this report, the terms dose and dose rate are used in place of the technically correct term dose equivalent or dose equivalent rate , and the terms R and rem are used interchangeably

. The actual differences among these values for the purpose of this report are negligible.5 stream SR-BCLDP.003.001 with a CCP Waste Stream Evaluation Report C1002. SRS-CCP prepared a new AK Re-evaluation Checklist and Discrepancy Report DR1002 to justify the inclusion of BCL0152 in RH waste stream RH-B CLDP.003, based on the fact that the physical and radiological properties for this drum is consistent with and bounded by this RH waste stream. The AK Summary report did not require additional changes as the AKE’s evaluation confirmed that the waste aligns with the existing description in the AK Summary report; only the contact dose rate required the containe r to be placed in the RH program.
SRS-CCP provided CCP-AK-SRS-530, Revision 4; CCP-AK-SRS-532, Revision 1; and CCPAK-SRS-531, Revision 1, to EPA as the main documen ts for review, as well as other calculation packages, reports and memoranda. The documents that EPA reviewed for this evaluation are cited in different sections throughout the report and are listed in Attachment B.

6.1 Acceptable Knowledge
EPA examined SRS-CCP’s programmatic requi rements, the AK process and associated information relative to characte rization of RH SRS debris (SCG S5000), (2) CH SRS debris, soil and solid (SCG S5000, S4000 and S3000) waste dur ing the continued comp liance inspection in August 2014 (see EPA Docket No. A-98-49; II-A4-195; report forthcoming). Specifically, EPA evaluated applicable CCP procedures; traini ng for all personnel i nvolved with RH TRU characterization; the processe s of AK compilation, AK verification, AK accuracy assessment and AK discrepancy resolution; comp letion and adequacy of requir ed forms and reports; and the SRS-CCP waste stream certification process. SRS-CCP initially characterized Drum No. BC0152 as part of CH Wast e Stream SR-BCLDP.003.001.
EPA approved SRS-CCP CH waste characteriza tion program processes to characterize solids/sludge (S3000) waste in March 2010 (see EPA Docket No. A-98-49; II-A4-123). The remaining containers in CH Waste Stream SR -BCLDP.003.001 were certified as meeting all CH characterization requirements and were em placed at WIPP in June 2013. Drum No. BC0152, however, fell out of Waste Stream SR-BCL DP.003.001 because contact dose rate surveys indicated that the container shoul d be reclassified as RH wast e due to a surface dose rate of greater than 200 mRem/hr. It was not reclassifi ed due to any type of discrepancy in waste generation or contents. SRS-CCP AK personnel prepared necessary documentation supporting this reclassification included in Source Documents C1002 and DR 1002, which EPA reviewed and concluded as technically ade quate. The historical AK used to characterize CH Waste Stream SR-BCLDP.003.001 and RH Waste Stream SR-BCLDP.003 is id entical. Therefore, EPA determined that the historical AK for Drum No. BC0152 did not need to be reevaluated and reapproved based on the recla ssification from CH to RH.
EPA also evaluated and approved the historic al AK, including the AK summary report (AKSR; CCP-AK-SRS-530, Revision 2) fo r Waste Stream SR-BCLDP.003 during a T1 evaluation in 2010 (see EPA Docket No. A-98-49; II-A4-129). SR S-CCP did not significantly alter the AKSR when moving Drum No. BC0152 from Waste Stream SR-BCLDP.003.001 to Waste Stream SRBCLDP.003. EPA’s requirement that the SRS-CCP RH program undergo a baseline inspection prior to adding any additional containers to Wa ste Stream SR-BCLDP.003 was an administrative control and not an indication of inadequate AK process implementation. Therefore, EPA6 determined that the AK for Waste Stream SR-BCLDP.003 did not need to be reapproved based on the inclusion of Drum No. BC0152.
CCP as a whole, including SRS-CCP, applies the same procedures, including AK compilation, AK verification, AK accuracy assessment, AK discrepancy resolution processes, report compilation and revision, and waste stream certif ication to all RH wast e regardless of the applicable SCG. Additionally, the same AK and Site Project Management personnel are responsible for characterization a nd certification of all RH waste irrespective of the applicable SCG. Therefore, EPA determined that the review and continued approval of SRS-CCP’s implementation of the AK process relative to char acterization of RH debris (SCG S5000) also applies to characteriza tion of Drum No. BC0152.
Summary of Acceptable Knowle dge Findings and Concerns
The EPA evaluation team did not identify any AK-re lated findings or concerns relative to the characterization of Drum No. BC0152 during this T1 ch ange evaluation.
Acceptable Knowledge Approval
Based on the results of this evaluation, EPA approves the characterizat ion of Drum No. BC0152 consistent with the limitations specified in this report.
Based on this evaluation, there ar e no changes to the AK T1 or T2 designations. Characterization of any additional SCG S3000 waste remains a T1 ch ange. T1 and T2 changes that were initiated during the baseline approval and subsequent T1 evaluations and continued compliance inspections remain in effect.

6.2 Radiological Characterization
EPA examined SRS-CCP’s programmatic requireme nts, the In Situ Object Counting System (ISOCS), the Non Destructive Assay Box Counter (NABC), the dose-to-curie (DTC) process and associated information during the continue d compliance inspection in August 2014 (see EPA Docket No. A-98-49; II-A4-195; report forthcom ing). Specifically, EPA evaluated training for all personnel involved with CH and RH TRU characterization, the SRS-CCP measurement control program for CH and RH TRU instruments and th e SRS-CCP CH and RH TRU procedures and technical documents. Therefore, EP A limited the scope of this evaluation to the technical adequacy of the information s upporting the addition of BCLDP Drum No. 0152.
Waste Characterization Element Description
EPA evaluated the radiological characterization of Drum No. BC0152 in terms of technical adequacy, as supported by the documents, proc edures and controls, and the knowledge and understanding of the personnel involved in the RH waste characterization program. During this RH evaluation, EPA evaluated the following elements of the SRS-CCP radiological characterization program:

 Overall radiological characterization.7  Development of cesium-137 ( 137 Cs)-based radionuclide scal ing factors via comparison with the original RH Waste Stream SR-BCL DP.003 scaling factors and CH NDA results from the NABC.

 Representativeness and technical adequacy of the analytical data used to support the scaling factors.

 Uncertainty analysis.

Each of these is discussed in the sections that follow.

Technical Evaluation

The EPA evaluation team evalua ted the following aspects:
(1) EPA evaluated the overall radiological char acterization process a nd its documentation and found them to be adequate.
Drum No. BC0152 was generated at BCLDP. It was later moved to SRS for storage and initially was characterized as CH waste by SRS-CCP. SR S-CCP later determined Drum No. BC0152 to be RH waste. SRS-CCP performe d a valid assay of this drum as CH waste using the EPAapproved NABC prior to determining that it wa s RH waste. The NABC is not approved for formal assays of RH waste, pr eventing SRS-CCP from using the NABC data to characterize this drum directly.
Because Drum No. BC0152 is part of Wast e Stream SR-BCLDP.003, SRS-CCP considered using the scaling factors previ ously approved for this waste. 3 This would be a reasonable approach if the drum’s radionuclide contents we re entirely consistent with those previously established for this waste stream. However, the presence of the concrete floor chunks discussed above invalidates the technical basis for using the previously established scaling factors to characterize Drum No. BC0152 because the repeated washings of the hot cell floor would have affected the concrete’s 137 Cs and actinide concentrations. The AK did not provide sufficient information to quantify the extent of these chan ges and derive a meaningf ul isotopic distribution for this drum.
For these reasons, SRS-CCP used the hybridized approach represen ted in Figure 1 to generate radionuclide-specific scaling factors for Dr um No. BC0152. The original SR-BCLDP.003 scaling factors were modified by the NABC assay results, as discussed in Item 2, below. SRSCCP then applied the historical DTC reco rd from Waste Stream SR-BCLDP.003 to the hybridized container scaling fact ors to generate the radionucl ide content of the drum, as

3 These scaling factors were based on the analysis of 69 swipe samples in co mbination with ORIGEN2.2 modeling of the Light Water Reactor (LWR) fuel pins that were examined in th e BCLDP hot cells. SRS-CCP generated these scaling factors for Waste Stream SR-RL-BCLDP.001 (see EPA Docket No.A-98-49; II-A4-104,August 2008) and later applied the same scaling factors to Waste Stream SR-BCLDP.003 (see EPA Docket No. A98-49; II-A4-129, September 2010). In this report, the debris scaling factors (SF Debris ) and the initial scaling factors for Waste Stream SR-BCLDP.003 are the same.8 discussed in Item 4, below. These radionuclide valu es were decay corrected to reflect the drum’s current activities.
During the course of this T1 evaluation, SRS-CC P revised the documents supporting radiological characterization in response to EPA’s commen ts and discussions between SRS-CCP and EPA technical personnel. EPA determined that the ra diological characterizati on process for Drum No. BC0152 was technically adequate and appropria tely documented in the revised documents. There were no outstanding issues regarding the radiological char acterization process for Drum No. BC0152.
Consistent with the T1 and T2 designations th at EPA established during the baseline approval, any new RH waste stream not approved to date or the addition of drums to Waste Stream SRBCLDP.003 remains a T1 change. Similarly, a ny change to CCP-AK-SRS-531 that requires CBFO approval remains a T2 change.9 (2) EPA found that SRS-CCP correctly derive d and appropriately documented cesium-137- based radionuclide scaling factors.
SRS-CCP described the development of scali ng factors for Drum No. BC0152 in CCP-AK-SRS531, Revision 1, Attachment A. This process in corporated several t ypes of measurements resulting in the use of hybr idized scaling factors.
Prior to determining that the drum was RH , SRS-CCP assayed it on the NABC. While the NDA Expert Analyst (EA) determined that the NABC assay was acceptable in that it met all the measurement acceptance criteria, it was barely ab ove detection and had a large uncertainty (the SRS-CCP obtained a valid assay for Drum No. BC0152 on the NABC

SRS-CCP attempt to confirm NABC results with ISOCS were not successful SRS-CCP obtained original SFs from RH Waste Stream SR-BCLDP.003

SRS-CCP modified original RH SFs using NABC results to create drum-specific hybridized SFs

SRS-CCP obtained historical DTC assays for Drum No. BC0152 SRS-CCP decay corrected drum-specific SFs corrected to the date of the historical DTC measurements

SRS-CCP determined drum activity at the time of the historical DTC

SRS-CCP decay-corrected drum activity for current radiological content
Figure 1. Characterization of Drum No. BC0152 BCLDP generated Drum No. BC0152 and SRS stored/ managed it as CH waste10 EA stated that the spectrum wa s “marginal”). The NABC scaling factors for both plutonium-239 ( 239 Pu) and americium-241 ( 241 Am) differed considerably from the initial scaling factors for Waste Stream SR-BCLDP.003. Ad ditionally, the assay only provided useable values for 137 Cs, 239 Pu, 241 Am, europium-152 and cobalt-60 ( 60 Co).
The NABC is an EPA-approved assay modality for CH waste but is not approved to provide the assay of record for RH wastes. The ISOCS is a WIPP-certified system at SRS for the determination of isotopic distri bution (ratios) in RH TRU waste. 4 Therefore, after SRS-CCP determined the drum to be RH, SRS-CCP personnel attempted to confirm e ither the initial Waste Stream SR-BCLDP.003 scaling factors or the NABC-measured radionuclide values using the ISOCS. However, the ISOCS assay provided useable data only for 137 Cs, so it was not helpful for comparing scaling factors.
Since SRS-CCP was unable to definitively es tablish the radionuclide results of Drum No. BC0152 by applying either the initial Waste Stre am SR-BCLDP.003 scaling factors or using the NABC results directly, SRS-CCP developed a hybrid set of scaling factors based on the original Waste Stream SR-BCLDP.003 scaling factors thatwere modified by the NABC results. SRSCCP determined that the Pu to uranium (U) ratio s should remain constant, and adjusted them to account for the 239 Pu to 137 Cs ratio determined by the NABC using the equation:

SF i =SF iDebris *( 239 Pu SF NABC )/( 239 Pu SF Debris )

SRS-CCP used the 241 Am ratio provided by the NABC wit hout adjustment and quantified the fission/activation products using the scaling factors from the original Waste Stream SRBCLDP.003 without modification. SR S-CCP and EPA technical personn el discussed this issue at length. EPA determined that SRS-CCP’s sca ling factor development approaches were technically adequate and appropriately documented.
(3) EPA previously evaluated computer modeling to develop the dose-to -curie correlation and found it to be adequate.

SRS-CCP used MicroShield ® to develop the original DTC correlation for Waste Stream SRBCLDP.003 based on the packaging configuratio n of BCLDP waste. This modeling assumed there were independent, 1-cu rie (Ci) sources of both 137 Cs and 60 Co that were uniformly distributed within the drum. Using waste density and the DTC correlation allows calculation of the activity attributable to 137 Cs, which is then used with decay-corrected scaling factors (excluding 60 Co) to determine the activities of the ra dionuclides of interest . The activities for 137 Cs and 60 Co are calculated directly from thei r corresponding DTC correlations. SRS-CCP described the DTC correlation in CCP-AK-SRS- 531, Revision 1, and detailed it in SRS-RH-02. EPA did not identify any issues regarding the use of Microshield ® to support the DTC correlation for Drum No. BC0152.
Consistent with the T1 and T2 designations th at were established during the SRS-CCP baseline approval, the use of any method to determine sc aling factors other than those documented in CCP-AK-SRS-531, Revision 1, remains a T1 change.

4 The SRS-CCP ISOCS is described in detail in EPA Docket No.A-98-49-A4-161, August 2012.11 (4) EPA assessed radionuclide documentation in th e dose-to-curie dete rmination and found it to be adequate.
SRS-CCP did not generate the radionuclide va lues summarized in CCP-AK-SRS-531 using DTC procedure CCP-TP-504. SRS-CCP stated that the DT C approach they used was consistent with what had been done previously for Waste Stre am SR-BCLDP.003, i.e., using the two dose rates generated by BCLDP in 2002. EPA approved this approach in 2008. 5 Performing DTC in accordance with CCP-TP-504 would have requir ed SRS-CCP to generate new MCNP5 or Microshield ® models for the drum’s configuration. EPA agreed that the historical DTC approach was technically adequate for this drum. However, EPA expects all future DTC measurements for SRS RH waste or RH waste from other TRU gene rator sites to be comp liant with the current revision of CCP-TP-504 or an equi valent procedure. Regardless of previous approvals, all future DTC measurements for SRS-CCP RH TRU wast e containers must be completed under a currently approved procedure. EPA did not id entify any concerns regarding SRS-CCP’s determination of radionuclides in DTC BDRs for Drum No. BC0152.
(5) EPA evaluated the remote-handled determinations and found them to be adequate.
SRS-CCP initially managed Drum No. BC0152 as CH waste. Based on contact dose-rate surveys performed in September 2013, SRS-CCP identified that the drum had contact dose rates in excess of 200 mrem/hr, making it RH waste. EPA did not identify any concerns regarding SRSCCP’s RH determination for Drum No. BC0152.
(6) EPA evaluated the determination the determin ation that this waste was transuranic and found it to be adequate.

SRS-CCP documented the TRU determination in the DTC conversion record listed in Table A6- 3 in CCP-AK-SRS-531, Revision 1. Drum No. BC0152 meets the requirements of TRU waste, i.e., has TRU alpha activity concentrations gr eater than 100 nanocuries per gram. EPA did not identify any concerns regarding SRS-CCP’s determination that Drum No. BC0152 is TRU waste.
(7) EPA evaluated the technical basis and docum entation of total measurement uncertainty and found them to be adequate.
The total measurement uncertainty (TMU) for Dr um No. BC0152 is based on the propagation of uncertainties present in the dete rmination of the waste stream’s radiological constituents. These aspects are assumed to be independent, whic h allows them to be added in quadrature. 6 The TMU determination included contri butions of the following:

 137 Cs DTC correlation

5 See EPA Docket No.A-98-49-A4-104, August 2008.

6 Adding in quadrature is a standard statistical techni que that allows one to combine the square root of the sum of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values were simply added. For example, the TMU for 137 Cs is derived by taking the square root of (25%) 2 plus (10%) 2 plus (19.69%) 2 plus (45.61%) 2 , which equals 56.5%, which is less than the value obtained by simply summing the individual uncertainty values (i.e., 100.3%), as shown in CCP-AK-SRS-531, Revision 1, Table A6-2.12  137 Cs activity measurement

 Scaling factor development, including modifi cations for the use of a hybridized factor

 MCNP5 Model

 Other gamma emitters
A general treatment of TMU for Drum No. BC 0152 is presented in Table A6-2, CCP-AK-SRS531, Revision 1, and is detailed in SRS-RH-05. Th e overall uncertainties are consistent with what EPA has observed for RH determinations at other RH TRU generator sites. EPA did not identify any concerns regarding SRS-CCP’s determination of TMU for Drum No. BC0152.
Summary of Radiological Characte rization Findings and Concerns
The EPA evaluation team did not identify any ra diological characterization-related findings or concerns relative to the characte rization of Drum No. BC0152 duri ng this T1 cha nge evaluation.
Radiological Character ization Approval
Based on the results of this evaluation, EPA approves the characterizat ion of Drum No. BC0152, consistent with the limitations specified in this report.
Based on this evaluation, there are no changes to the radiological characterization T1 or T2 designations. Characterization of any new waste stream not previ ously approved or addition of containers to an approved waste stream that requires changing the established radionuclide scaling factors remains a T1 change. T1 and T2 changes that were initia ted during the baseline approval remain in effect.

7.0 FINDINGS AND CONCERNS
Summary of Findings and Concerns
The EPA inspection team did not identify a ny findings or concerns relative to the characterization of Drum No. BC0152 during this T1 ch ange evaluation.

8.0 CONCLUSIONS
Changes to Tiering
As a result of this evaluation, EPA did not ma ke any changes to the SRS-CCP RH T1 and T2 designations that were establis hed during the baseline approval a nd modified during subsequent T1 evaluations and the 2014 continued complian ce inspection. The tiering designations presented in Table 2 of the final report for EPA’s 2014 c ontinued compliance inspection of SRS-CCP (see EPA Docket No. A-98-49; II-A4-195; report forthcomi ng) remain in effect and are listed as applicable in sections 6.1 and 6.2.13 Approval

EPA concluded that the waste ch aracterization processes of AK a nd radiological characterization used to characterize Drum No. BC0152 are adeq uate, as evidenced by the records evaluated. There are no open issues rela tive to this T1 evaluation.
Based on the results of this evaluation, EPA a pproves this T1 change consistent with the limitations specified in this report. Specifi cally, EPA’s approval in cludes Drum No. BC0152 only. Characterization of additional RH S3000 waste remains a T1 change. SRS-CCP may continue to characterize previ ously approved RH TRU waste cons istent with the restrictions specified with the approvals listed in Appendix A to this report.A-1 ATTACHMENT A

APPROVAL SUMMARY FOR SAVANNAH RIVER SITE REMOTE-HANDLED WASTE CHARACTERIZATION PROGRAM

Approved Activity Approval Dates EPA Docket Number SRS RH Baseline Approval of BCL Waste August 21, 2008 A-98-49; II-A4-104 T1 Change – Addition of Six (6) Waste Streams: SR-BCLDP.001.001 – Homogenous Waste SR-BCLDP.001.002 – Composite Filter Debris SR-BCLDP.002- Cemented Sludge SR-BCLDP.003 – Hydraulic Sludge and Debris SR-BCLDP.004.001 – Cartridge Water Filter SR-BCLDP.004.003 – TRI-NUC Vacuum Filters September, 9, 2010 A-98-49; II-A4-129

T1 Change – Addition of BCO148 (simulated HL waste) to SR-RL-BCLDP.002 June 8, 2011 A-98-49; II-A4-149
SRS RH non-BCL Baseline Approval April 2012 A-98-49; II-A4-161 T1 Change – Addition of Waste Stream SR-RH- 235F.01 February 11, 2013 A-98-49; II-A4-170 T1 Change – Addition of Waste Stream SR-RH-221H.01 August 20, 2013 A-98-49; II-A4-177 T1 Change – Addition of Waste Stream SR-RH-SDD.01 May 22, 2014 A-98-49; II-A4-184 2014 Continued Compliance Inspection Report forthcoming A-98-49; II-A4-195B-1 ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION
Memorandum from Kevin Peters to I. Joo, Wa ste Stream Container Evaluation Memorandum, September 11, 2012 CCP-AK-SRS-530, Central Characterization Progr am Acceptable Knowledge Summary Report for Battelle Columbus Laboratories Deco mmissioning Project (BCLDP) Homogeneous Transuranic Waste from the Building JN-1 H ydraulic Room, Waste Streams: SR-BCLDP.003 – Hydraulic Sludge and Debris and SR-BCLDP .003.001 - CH Hydraulic Sludge and Debris, Revision 4, October 29, 2012 CCP-AK-SRS-531, Central Characterization Program Remote-Handled Transuranic Radiological Characterization T echnical Report for Remote-Handled Transuranic Hydraulic Sludge and Debris from Battell e Columbus Laboratories Decomm issioning Project at the West Jefferson North Facility, Revision 1, April 7, 2014 CCP-AK-SRS-532, Central Characterization Program RH TRU Certification Plan for 40 CFR Part 194 Compliance for BCLDP RH Waste Stream: SR-BCLDP.003, Revision 1, April 29, 2014 Memorandum to EPA, Radiolog ical Characterization Approa ch for Drum BC0152 in Waste Stream BCLDP Hydraulic Sludge and Debris, January 29, 2014 Memorandum to I. Joo, Response to EPA Comments Regarding the Characterization of BC0152, Derek Ott, June 12, 2014 Email from I. Joo, to Rajani Joglekar, provi ding BCLDP Hydraulic Slud ge and Debris Waste Timeline, December 3, 2014 SRS-RH-01, Scaling Fact or Development (P727), Revision 2, November 6, 2007 SRS-RH-02, Dose-to-Curie Co rrelation for Cs-137 and Co-60 (P728), November 9, 2007 SRS-RH-05, Dose to Curie Spreadsheet (P731), June 24, 2008 SRS-RH-06, Uncertainty Analysis (P732), November 9, 2007 SRS-RH-32, DTC Spreadsheet for Drum BC0152, Revision 0, Derek Ott, May 12, 2014 SRLBC0742, NDA Batch Data Report , SRS E-Area, September 26, 2012 SRLBR0098, SRS RTR Batch Data Report, RH, July 9, 2013 DR1002, CCP-TP-005, Rev. 24, CCP Acceptable K nowledge Documentation, November 28, 2011 C1002, CCP-TP-005, Rev. 24, CCP Acceptable Know ledge Documentation, November 28, 2011