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 CHARACTERIZATION PROGRAM 

REMOTE-HANDLED TRANSURANIC WASTE 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 2014
i 

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 Savannah River Site Remote-Handled Waste 

Characterization Program 

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

ACRONYMS AND INITIALIZATIONS 

AK acceptable knowledge 

AKSR acceptable knowledge summary report 

Am americium 

BCLDP Battelle Columbus Laboratories 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 Object Counting System 

LWR light water reactor 

MCNP5 Monte Carlo N-Particle Transport 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 uncertainty 
iii 

TRU transuranic 

U uranium 

WIPP Waste Isolation Pilot Plant 
1 

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 

(T1) change to characterize Drum No. BC0152 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. EPA concludes that by using the EPA-approved 

RH radiological waste characterization program elements discussed in this report, SRS-CCP can 

characterize the TRU sludge waste container, Drum No. BC0152, generated at the Battelle 

Columbus Laboratory (BCL) for disposal at the 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 Carlsbad Field Office (CBFO) requested EPA to 

approve the radiological characterization 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-BCLDP.003.001. However, due to the surface dose 

rate measured above 200 millirem per hour, the container was classified as a RH waste container 

and was subjected to radiological characterization to confirm the designation and quantify 

radiological contents requiring EPA approval. 

The Battelle Columbus Laboratories Decommissioning Project (BCLDP) at BCL, Columbus, 

Ohio, generated more than 100 waste containers as part of laboratory dismantling activities and 

partially characterized them. Eleven of which belonged to hydraulic 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 containers to SRS for storage, characterization 

and disposal at WIPP. As of 2010, all BCL waste containers except the subject 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). Subsequently, 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 (see EPA Docket No. A-98-49; II-A4-129). The 

August 2008 SRS-CCP RH baseline approval stated that if SRS-CCP were to characterize any 

non-BCL waste for WIPP disposal, a new baseline inspection and approval would be necessary. 

In April 2012, EPA approved the SRS-CCP RH TRU waste characterization program (see EPA 

Docket No. A-98-49: II-A4-161). Attachment A lists subsequent tiering changes to the April 

2012 RH baseline approval. 

 1

 The Central Characterization Program was formerly known as the Central Characterization Project, and 

both names are used in the documentation reviewed for this evaluation. 
2 

EPA conducted a continued compliance inspection of SRS-CCP’s CH and RH waste 

characterization programs that were operational 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 waste-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 approved 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 evaluation. 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 modified during subsequent T1 evaluations and the 

2014 continued compliance inspection. The tiering designations, 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 concluded that SRS-CCP used the EPA-approved 

system of controls to characterize Drum No. BC0152. This single container of TRU waste is the 

subject of this T1 report, and EPA’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 activities from the date of the site’s baseline 

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

requirements set forth in 40 CFR 194.8 regulations and incorporated into the 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 perform a single baseline inspection of a 

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

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

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

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

destined for disposal at the WIPP. 

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

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

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

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

are identified in the site-specific baseline inspection reports and subsequent T1 evaluation 

reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection 

to observe implementation of the change or can opt to conduct a desktop review of information 
3 

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 evaluation of a T1 change to add Drum No. BC0152 to 

SRS-CCP’s approved waste characterization program as part of RH Waste Stream SRBCLDP.003. This report presents the technical basis 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 mentioned 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 characterize BCLDP RH Drum No. BC0152. Section 6.0 of 

this report details the AK and radiological characterization technical elements assessed during 

this evaluation. 

5.0 EPA EVALUATION PERSONNEL 

The EPA evaluation team members 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 information 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 Evaluator – 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&A 
4 

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 absorbed sludge while cleaning out waste from 

historic hydraulic oil leaks into the pump room with dose rate ranging 20-2000 mR/hr. In 2002, 

11 hydraulic sludge and debris drums (Sludge/debris Waste Stream S3212) were generated. The 

measured dose rate for seven of these containers 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 BC0152 identified a maximum dose rate of 150 

mR/hr, therefore it was classified as a CH drum. The Discrepancy Report (DR017) prepared by 

SRS-CCP in February 2008, delineated 11 hydraulic sludge and debris as seven RH waste (SRBCLDP.003), three CH (including BCL0152) and one low-level waste 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 during 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, including 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 contact-handled TRU Waste Stream SR-BCLDP.003.001, and was 

characterized under the SRS-CCP CH TRU program including non-destructive assay (NDA). 

However, when SRS-CCP was readying the container for shipment to WIPP the contact dose2

rate surveys indicated that at least one part of the container (a “hot spot”) measured in excess of 

200 millirem per hour (mrem/hr). SRS-CCP, therefore, reassigned this drum to RH TRU Waste 

Stream SR-BCLDP.003. The reason for two different 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 determined 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 years 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 addition of Drum No. BC0152. 

Initially, AK document, CCP-AK-SR-530, for RH hydraulic sludge and debris 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 sludge 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-BCLDP.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 container 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 documents 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 requirements, the AK process and associated 

information relative to characterization of RH SRS debris (SCG S5000), (2) CH SRS debris, soil 

and solid (SCG S5000, S4000 and S3000) waste during the continued compliance inspection in 

August 2014 (see EPA Docket No. A-98-49; II-A4-195; report forthcoming). Specifically, EPA 

evaluated applicable CCP procedures; training for all personnel involved with RH TRU 

characterization; the processes of AK compilation, AK verification, AK accuracy assessment and 

AK discrepancy resolution; completion and adequacy of required forms and reports; and the 

SRS-CCP waste stream certification process. SRS-CCP initially characterized Drum No. 

BC0152 as part of CH Waste Stream SR-BCLDP.003.001. 

EPA approved SRS-CCP CH waste characterization 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 emplaced at WIPP in June 2013. Drum No. BC0152, 

however, fell out of Waste Stream SR-BCLDP.003.001 because contact dose rate surveys 

indicated that the container should be reclassified as RH waste due to a surface dose rate of 

greater than 200 mRem/hr. It was not reclassified 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 adequate. The historical AK used to characterize CH Waste Stream 

SR-BCLDP.003.001 and RH Waste Stream SR-BCLDP.003 is identical. Therefore, EPA 

determined that the historical AK for Drum No. BC0152 did not need to be reevaluated and 

reapproved based on the reclassification from CH to RH. 

EPA also evaluated and approved the historical AK, including the AK summary report (AKSR; 

CCP-AK-SRS-530, Revision 2) for Waste Stream SR-BCLDP.003 during a T1 evaluation in 

2010 (see EPA Docket No. A-98-49; II-A4-129). SRS-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 Waste Stream SR-BCLDP.003 was an administrative 

control and not an indication of inadequate AK process implementation. Therefore, EPA 
6 

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 certification to all RH waste regardless of the 

applicable SCG. Additionally, the same AK and Site Project Management personnel are 

responsible for characterization and 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 characterization of RH debris (SCG S5000) also 

applies to characterization of Drum No. BC0152. 

Summary of Acceptable Knowledge Findings and Concerns 

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

characterization of Drum No. BC0152 during this T1 change evaluation. 

Acceptable Knowledge Approval 

Based on the results of this evaluation, EPA approves the characterization of Drum No. BC0152 

consistent with the limitations specified in this report. 

Based on this evaluation, there are no changes to the AK T1 or T2 designations. Characterization 

of any additional SCG S3000 waste remains a T1 change. 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 requirements, 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 continued compliance inspection in August 2014 (see EPA 

Docket No. A-98-49; II-A4-195; report forthcoming). 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 the SRS-CCP CH and RH TRU 

procedures and technical documents. Therefore, EPA limited the scope of this evaluation to the 

technical adequacy of the information supporting 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, procedures 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 (137Cs)-based radionuclide scaling factors via comparison 

with the original RH Waste Stream SR-BCLDP.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 evaluated the following aspects: 

(1) EPA evaluated the overall radiological characterization process and 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. SRS-CCP later determined Drum No. BC0152 to 

be RH waste. SRS-CCP performed a valid assay of this drum as CH waste using the EPAapproved NABC prior to determining that it was RH waste. The NABC is not approved for 

formal assays of RH waste, preventing SRS-CCP from using the NABC data to characterize this 

drum directly. 

Because Drum No. BC0152 is part of Waste Stream SR-BCLDP.003, SRS-CCP considered 

using the scaling factors previously approved for this waste.3

 This would be a reasonable 

approach if the drum’s radionuclide contents were 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 137Cs and actinide concentrations. The AK did not provide sufficient 

information to quantify the extent of these changes and derive a meaningful isotopic distribution 

for this drum. 

For these reasons, SRS-CCP used the hybridized approach represented in Figure 1 to generate 

radionuclide-specific scaling factors for Drum 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 record from Waste Stream SR-BCLDP.003 to the 

hybridized container scaling factors to generate the radionuclide content of the drum, as 

 3

 These scaling factors were based on the analysis of 69 swipe samples in combination with ORIGEN2.2 

modeling of the Light Water Reactor (LWR) fuel pins that were examined in the 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 (SFDebris) and the initial scaling factors 

for Waste Stream SR-BCLDP.003 are the same. 
8 

discussed in Item 4, below. These radionuclide values were decay corrected to reflect the drum’s 

current activities. 

During the course of this T1 evaluation, SRS-CCP revised the documents supporting radiological 

characterization in response to EPA’s comments and discussions between SRS-CCP and EPA 

technical personnel. EPA determined that the radiological characterization process for Drum No. 

BC0152 was technically adequate and appropriately documented in the revised documents. 

There were no outstanding issues regarding the radiological characterization process for Drum 

No. BC0152. 

Consistent with the T1 and T2 designations that 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, any change to CCP-AK-SRS-531 that requires 

CBFO approval remains a T2 change. 
9 

(2) EPA found that SRS-CCP correctly derived and appropriately documented cesium-137-

based radionuclide scaling factors.

SRS-CCP described the development of scaling factors for Drum No. BC0152 in CCP-AK-SRS531, Revision 1, Attachment A. This process incorporated several types of measurements 

resulting in the use of hybridized 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 above 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 waste 
10 

EA stated that the spectrum was “marginal”). The NABC scaling factors for both plutonium-239 

(

239Pu) and americium-241 (241Am) differed considerably from the initial scaling factors for 

Waste Stream SR-BCLDP.003. Additionally, the assay only provided useable values for 137Cs, 

239Pu, 241Am, europium-152 and cobalt-60 (60Co). 

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 distribution (ratios) in RH TRU waste.4

 Therefore, after SRS-CCP 

determined the drum to be RH, SRS-CCP personnel attempted to confirm either 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 137Cs, so it was not helpful for 

comparing scaling factors. 

Since SRS-CCP was unable to definitively establish the radionuclide results of Drum No. 

BC0152 by applying either the initial Waste Stream 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 that were modified by the NABC results. SRSCCP determined that the Pu to uranium (U) ratios should remain constant, and adjusted them to 

account for the 239Pu to 137Cs ratio determined by the NABC using the equation: 

SFi=SFiDebris*(239Pu SFNABC)/(239Pu SFDebris) 

SRS-CCP used the 241Am ratio provided by the NABC without adjustment and quantified the 

fission/activation products using the scaling factors from the original Waste Stream SRBCLDP.003 without modification. SRS-CCP and EPA technical personnel discussed this issue at 

length. EPA determined that SRS-CCP’s scaling 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 configuration of BCLDP waste. This modeling assumed 

there were independent, 1-curie (Ci) sources of both 137Cs and 60Co that were uniformly 

distributed within the drum. Using waste density and the DTC correlation allows calculation of 

the activity attributable to 137Cs, which is then used with decay-corrected scaling factors 

(excluding 60Co) to determine the activities of the radionuclides of interest. The activities for 

137Cs and 60Co are calculated directly from their 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 that were established during the SRS-CCP baseline 

approval, the use of any method to determine scaling 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 the dose-to-curie determination and found it 

to be adequate. 

SRS-CCP did not generate the radionuclide values summarized in CCP-AK-SRS-531 using DTC 

procedure CCP-TP-504. SRS-CCP stated that the DTC approach they used was consistent with 

what had been done previously for Waste Stream 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 required 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 generator sites to be compliant with the current 

revision of CCP-TP-504 or an equivalent procedure. Regardless of previous approvals, all future 

DTC measurements for SRS-CCP RH TRU waste containers must be completed under a 

currently approved procedure. EPA did not identify 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 determination 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 greater 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 documentation of total measurement uncertainty 

and found them to be adequate. 

The total measurement uncertainty (TMU) for Drum No. BC0152 is based on the propagation of 

uncertainties present in the determination of the waste stream’s radiological constituents. These 

aspects are assumed to be independent, which allows them to be added in quadrature.6

 The TMU 

determination included contributions of the following: 

 137Cs DTC correlation 

 5

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

6

 Adding in quadrature is a standard statistical technique 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 137Cs 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 

 137Cs activity measurement 

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

 MCNP5 Model 

 Other gamma emitters 

A general treatment of TMU for Drum No. BC0152 is presented in Table A6-2, CCP-AK-SRS531, Revision 1, and is detailed in SRS-RH-05. The 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 Characterization Findings and Concerns 

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

concerns relative to the characterization of Drum No. BC0152 during this T1 change evaluation. 

Radiological Characterization Approval 

Based on the results of this evaluation, EPA approves the characterization 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 previously 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 initiated during the baseline 

approval remain in effect. 

7.0 FINDINGS AND CONCERNS 

Summary of Findings and Concerns 

The EPA inspection team did not identify any findings or concerns relative to the 

characterization of Drum No. BC0152 during this T1 change evaluation. 

8.0 CONCLUSIONS 

Changes to Tiering 

As a result of this evaluation, EPA did not make any changes to the SRS-CCP RH T1 and T2 

designations that were established during the baseline approval and modified during subsequent 

T1 evaluations and the 2014 continued compliance inspection. The tiering designations 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 and are listed as 

applicable in sections 6.1 and 6.2. 
13 

Approval 

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

used to characterize Drum No. BC0152 are adequate, as evidenced by the records evaluated. 

There are no open issues relative to this T1 evaluation. 

Based on the results of this evaluation, EPA approves this T1 change consistent with the 

limitations specified in this report. Specifically, EPA’s approval includes Drum No. BC0152 

only. Characterization of additional RH S3000 waste remains a T1 change. SRS-CCP may 

continue to characterize previously approved RH TRU waste consistent 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-A4-195 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

Memorandum from Kevin Peters to I. Joo, Waste Stream Container Evaluation Memorandum, 

September 11, 2012 

CCP-AK-SRS-530, Central Characterization Program Acceptable Knowledge Summary Report 

for Battelle Columbus Laboratories Decommissioning Project (BCLDP) Homogeneous 

Transuranic Waste from the Building JN-1 Hydraulic 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 Technical Report for Remote-Handled Transuranic Hydraulic 

Sludge and Debris from Battelle Columbus Laboratories Decommissioning 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, Radiological Characterization Approach 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, providing BCLDP Hydraulic Sludge and Debris Waste 

Timeline, December 3, 2014 

SRS-RH-01, Scaling Factor Development (P727), Revision 2, November 6, 2007 

SRS-RH-02, Dose-to-Curie Correlation 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 Knowledge Documentation, November 28, 

2011 

C1002, CCP-TP-005, Rev. 24, CCP Acceptable Knowledge Documentation, November 28, 2011