EPA DOCKET NO: A-98-49, II-A4-159 

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

AT THE IDAHO NATIONAL LABORATORY: 

ADDITION OF WASTE STREAM IN-ID-NRF-SPC 

October 4–6, 2011 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

March 2012 
i

TABLE OF CONTENTS 

Section Page

Abbreviations and Acronyms ......................................................................................................... ii

1.0 Executive Summary .............................................................................................................1

2.0 Purpose of Tier 1 Evaluations ..............................................................................................2

3.0 Purpose of This Report ........................................................................................................2

4.0 Scope of This Evaluation .....................................................................................................3

5.0 Evaluation Personnel ...........................................................................................................3

6.0 Evaluation of Waste Stream IN-ID-NRF-SPC ....................................................................4

6.1 Programmatic Requirements and Acceptable Knowledge ..............................................5

6.2 Radiological Characterization .......................................................................................17

6.3 Real-Time Radiography ................................................................................................24

7.0 Summary of Results ...........................................................................................................26

TABLES 

Table 1. T1 Evaluation Participants ................................................................................................ 3

Table 2. BDRs Examined ............................................................................................................... 5

Table 3. Fuel Type and Percentage by Generation and/or Storage Location ................................. 7

Table 4. Characterization Methods for Waste Stream .................................................................... 8

Table 5. Fuel Type Scaling Factors Derived from the NRF Radiological Data ........................... 11

Table 6. Traceability Information for Selected Drums in Waste Stream IN-ID-NRF-SPC ......... 15

Table 7. AK Training Qualification Summary ............................................................................. 16

FIGURES 

Figure 1. Flow Diagram of the Characterization Process: IN-ID-NRF-SPC................................ 19

ATTACHMENTS 

Attachment A: Approval Summary for INL-CCP Remote-Handled Waste Characterization 

Program 

Attachment B: Listing of Documents Reviewed for This Evaluation 
ii

ABBREVIATIONS AND ACRONYMS 

AK acceptable knowledge 

AKSR acceptable knowledge summary report 

Am americium 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations

CH contact-handled 

Ci curie(s) 

Cm curium 

CRR Characterization Reconciliation Report 

Cs cesium 

CTAC Carlsbad Technical Assistance Contractor 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 

DTC dose-to-curie 

ECF Expended Core Facility 

EF enhancement factor 

EPA U.S. Environmental Protection Agency 

Eu europium 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

ITR Independent Technical Reviewer 

LANL Los Alamos National Laboratory 

LLW low-level waste 

LOQI list of qualified individuals 

LWA Waste Isolation Pilot Plant Land Withdrawal Act

mR/hr/Ci milliroentgen(s) per hour per curie 
iii

mrem/hr millirem per hour 

nCi/g nanocurie(s) per gram 

NCR nonconformance report 

NDA nondestructive assay 

NOFORN Not Releasable to Foreign Nationals/Governments/Non-U.S. Citizens 

(document handling instruction) 

NRF Naval Reactors Facility 

NWPA Nuclear Waste Policy Act

ORIGEN-S Oak Ridge Isotope Generation and Depletion (computer code) 

PAC pressure abatement container 

Pu plutonium 

QA quality assurance 

RH remote-handled 

RTR real-time radiography 

SNF spent nuclear fuel 

SPC sludge pan container 

SPCSC sludge pan container shielded container 

SPM Site Project Manager 

Sr strontium 

T1 Tier 1 

T2 Tier 2 

Th thorium 

TMU total measurement uncertainty 

TRAMPAC TRU Waste Authorized Methods for Payload Control (programmatic or 

waste-specific data package) 

TRU transuranic 

TUV transuranic vault 

U uranium 

VE visual examination 

WCPIP Remote-Handled TRU Waste Characterization Program Implementation 

Plan 

WETSAW Wet Element Transverse Sectioning Abrasive Wheel 

WIPP Waste Isolation Pilot Plant 
iv

WMP waste material parameter 

WSPF Waste Stream Profile Form 

WTS Washington TRU Solutions 
1

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of remotehandled (RH) transuranic (TRU) inorganic debris (Summary Category Group S5000) Waste 

Stream IN-ID-NRF-SPC. This waste stream was generated by operations in the Alpha Box and 

Wet Element Transverse Sectioning Abrasive Wheel (WETSAW) Enclosure at the Naval 

Reactors Facility (NRF), located at the U.S. Department of Energy’s (DOE’s) Idaho National 

Laboratory (INL). 

On August 30, 2011, the Carlsbad Field Office (CBFO) requested EPA approval of a Tier 1 (T1) 

change to add Waste Stream IN-ID-NRF-SPC to the certification of the INL Central 

Characterization Project (CCP) waste characterization program for RH waste. CCP is responsible 

for characterizing RH wastes at INL using the system of controls that EPA approved during the 

baseline inspection in January 2007 (see EPA Docket No. A-98-49; II-A4-72), and during 

subsequent process- and equipment-specific T1 change approvals. A table listing EPA’s 

approvals of the INL-CCP RH TRU waste characterization program is included as 

Attachment A. Because there were no new processes or equipment at INL associated with 

characterizing these wastes, EPA chose to conduct this review in Golden, Colorado, on 

October 4–6, 2011. 

Section 7.0 of this report presents the results of this T1 evaluation. No open issues remain 

relative to this T1 change. EPA determined that the procedures and processes used by INL-CCP 

for the characterization of Waste Stream IN-ID-NRF-SPC were adequate. Therefore, EPA 

approves the addition of Waste Stream IN-ID-NRF-SPC to INL-CCP’s RH baseline approval. 

This approval is not limited to a specific number of containers1

 in Waste Stream IN-ID-NRFSPC. INL-CCP may add containers to the approved INL RH waste stream provided that the 

following conditions are met: 

• Additional containers have similar pedigree to the approved waste stream. 

• INL-CCP can demonstrate that the radionuclide scaling factors used for RH Waste 

Stream IN-ID-NRF-SPC are technically appropriate for use in the dose-to-curie (DTC) 

determination for the radiological characterization of the additional containers. 

If a population of additional containers requires new or different radionuclide scaling factors, 

those containers will be subject to EPA’s T1 evaluation and approval before emplacement in the 

Waste Isolation Pilot Plant (WIPP), as described in the revised tiering table contained in the 

HFEF Lot 4A report (EPA Docket No. A-98-49; II-A4-145). 

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 sending e-mails 

to the WIPPNEWS list, in accordance with Title 40 of the Code of Federal Regulations 

(40 CFR) 194.8(b)(3).

 

1 Containers is a generic term that applies to cans, canisters, drums, and any other types of waste packaging 

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

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization activities since 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 and incorporated in the INL-CCP RH Baseline Approval 

report cited in Attachment A. 

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

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

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

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

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

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

destined for disposal at the WIPP. 

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

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

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

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

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

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

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

specific to a change. DOE may choose to characterize and dispose of, at risk of subsequent EPA 

disapproval, any previously approved TRU waste using processes, procedures, or equipment 

implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and may conduct 

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

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of T1 changes to dispose of fully 

characterized containers of INL RH Waste Stream IN-ID-NRF-SPC at the WIPP (Section 6.0, 

below), as described in CCP-AK-INL-570, Revision 1. This report presents the technical basis 

and results of EPA’s approval decision, which will be conveyed to DOE separately by letter. 

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

accordance with 40 CFR 194.8(b)(3). 

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

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

from the following address: 

Carlsbad Field Office 

Manager, National TRU Program 

U.S. Department of Energy 

PO Box 3090 

Carlsbad, NM 88221-3090 
3

4.0 SCOPE OF THIS EVALUATION 

The scope of this T1 evaluation encompassed the addition of INL RH Waste Stream IN-ID-NRFSPC, consisting at the time of 93 55-gallon drums. This evaluation included three waste 

characterization areas: AK, radiological characterization, and RTR, each of which is addressed 

separately in this report. 

DOE WIPP-02-3124, “Remote-Handled TRU Waste Characterization Program Implementation 

Plan” (WCPIP), Revision 2, was effective as of April 21, 2011. EPA requires that all CCP RH 

TRU waste characterization activities, including the preparation of documentation and the 

documents themselves, be in conformance with this version of the WCPIP. All mentions of the 

WCPIP in this report refer to DOE WIPP-02-3124, Revision 2, unless specified otherwise. 

5.0 EVALUATION PERSONNEL 

EPA and its support personnel interviewed INL-CCP personnel in several disciplines at the 

October 2011 meeting in Golden, Colorado, and conducted follow-up discussions by telephone. 

Table 1 lists the EPA evaluation team members and the personnel contacted, with their 

affiliations and technical areas of expertise. This list includes personnel present at meetings 

conducted as part of this evaluation. 

Table 1. T1 Evaluation Participants 

Name Affiliation and Function 

Edward Feltcorn EPA, Lead Inspector 

Connie Walker SC&A, Technical Evaluator – AK 

Patrick Kelly SC&A, Technical Evaluator – Radiological Characterization 

Amir Mobasheran* SC&A, Technical Evaluator – Radiological Characterization 

Rose Gogliotti* SC&A, Technical Evaluator – Radiological Characterization 

Dorothy Gill* SC&A, Technical Evaluator – RTR 

James Luginbyhl CCP/LANL, Acceptable Knowledge Expert 

Mark Doherty CCP/TechSpecs, Acceptable Knowledge Expert 

Lisa Watson CCP/LANL, Acceptable Knowledge Expert 

Irene Quintana WTS, INL-CCP Site Project Manager (SPM) 

Jene Vance** CCP, Radiological Characterization Subject Matter Expert 

Neil Dickes CCP/NDA Carlsbad, Observer 

Ben Roberts DOE-Idaho, Observer 

Tom Clements CH2M-Washington Group International, Observer 

Michael Sensibaugh WTS-CCP Project Management, Observer 

Margie Martinez CTAC/CBFO, Observer 

Marcus A. Pinzel DOE/CBFO, Observer 

* Amir Mobasheran, Rose Gogliotti, and Dorothy Gill did not attend the evaluation in 

Golden, Colorado, but conducted reviews in support of this T1 change. 

** Jene Vance participated in the October 4–6, 2011, evaluation via teleconference. 
4

6.0 EVALUATION OF WASTE STREAM IN-ID-NRF-SPC 

Waste-Generating Activities

Waste Stream IN-ID-NRF-SPC consists of inorganic debris from fuel-element cutting operations 

conducted at INL from April 1975 to December 2007. The fuel fines generated by these 

operations contain five fuel types: Type 1, advanced fuel; Type 2, standard fuel; Type 3, 

uranium-235 and thorium (235U+Th) fuel; Type 4, natural or depleted U blanket fuels; and Type 

5, 233U+Th fuel. 

Fuel-element cutting activities were performed in the Alpha Box and the WETSAW (a fuel 

element sectioning tool) Enclosure in the Expended Core Facility (ECF) at the NRF. The Alpha 

Box was a carbon steel containment box in which fuel elements were remotely sectioned using a 

slow-speed abrasive cut-off wheel to slice a specimen from the fuel element. Fuel was sectioned 

in the Alpha Box between 1975 and 1995, and the Alpha Box was removed in 1995. The 

WETSAW Enclosure was constructed in 1992, was used for sectioning between 1995 and 2007, 

and was dismantled in 2008 (References P073, U106, U132, and U133). 

NRF personnel stated that during the cutting process, most (85%) of the waste material and water 

was collected in an underlying sludge pan, and the remaining (15%) water and swarf 2

 were 

dispersed within the Alpha Box and WETSAW Enclosure. The inside of the Alpha Box was 

cleaned when a fuel type was changed, and the combustible waste generated during cleaning was 

placed in either a 12- or 17-inch plastic bottle; this material was Waste Stream IN-ID-NRF-153, 

which EPA evaluated and approved in October 2010 (see EPA Docket No. A-98-49; II-A4-135). 

Sludge pan waste was also collected and placed in sludge pan containers (SPCs) between 

sectioning of different fuel types, so the radionuclides in the SPCs and the organic debris 

generated during cell cleaning in Waste Stream IN-ID-NRF-153 are similar, if both were 

generated on or near the same date. It was expected that cesium-137 (137Cs) would be more 

soluble than the TRU radionuclides in the water used during the cutting operations and that the 

difference in solubilities would affect the radionuclide ratios in the waste. This was confirmed by 

sampling and analysis performed in support of Waste Stream IN-ID-NRF-153, as documented in 

CCP-AK-INL-561 and discussed in Sections 6.1 and 6.2 of this report. 

Out of the 93 SPCs generated, 68 SPCs had been transferred from the ECF water pits to the 

Idaho Nuclear Technology and Engineering Center (INTEC) for storage, and these have been 

placed into 30-gallon drums. Each 30-gallon drum, containing one SPC, is overpacked within a 

55-gallon drum. The 93 55-gallon drums are identified as INL-CCP Waste Stream IN-ID-NRFSPC and are the subject of this T1 evaluation. 

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

Attachment B to this report lists all documentation that EPA reviewed in support of this T1 

evaluation. Table 2 presents the single DTC and RTR BDRs examined and lists the drums cited 

in those BDRs. INL-CCP provided CCP-AK-INL-570, CCP-AK-INL-571 and calculation 

packages, and CCP-AK-INL-572. CCP-AK-INL-570, CCP-AK-INL-571, and CCP-AK-INL-

 

2

Swarf is material that is produced by a cutting or grinding process. 
5

572 required revisions as a result of EPA’s evaluation, as did some calculation packages. INLCCP provided the revised documents to EPA before the conclusion of this T1 evaluation. 

Table 2. BDRs Examined 

Drum Number RTR BDR Number DTC BDR Number 

NRFTRUSPC065-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC047-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC062-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC060-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC059-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC064-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC083-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC055-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC039A-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC061-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC040-1 INLRHRTR 11001 INLRHDTC11001 

NRFTRUSPC046-1 INLRHRTR 11001 INLRHDTC11001 

6.1 Programmatic Requirements and Acceptable Knowledge 

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

determine whether INL-CCP demonstrated compliance with the requirements of 40 CFR 194.8 

for Waste Stream IN-ID-NRF-SPC. 

Waste Characterization Element Description

As part of this evaluation, EPA reviewed the following with respect to programmatic 

requirements and the use of AK for RH waste characterization: 

• Inspection scope and waste stream identification 

• Identification of the WCPIP waste characterization process 

• Adequacy of the Certification Plan and other WCPIP documentation 

• Adequacy of the WCPIP waste characterization pathway 

• Adequacy of training 

• Adequacy of the WSPF and related attachments 

• Adequacy of nonconformance and discrepancy resolution (DR) documentation 

• Waste stream definition, including radiological and physical characteristics 

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

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

(HLW), low-level waste (LLW), or spent nuclear fuel (SNF) 

• Adequacy of AK procedure and procedure implementation 
6

• Adequacy of the AKSR and associated source documents 

• AK data traceability 

• Attainment of data quality objectives (DQOs)

Technical Evaluation

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

Waste Stream IN-ID-NRF-SPC and found to be adequate.

The T1 request stated that Waste Stream IN-ID-NRF-SPC currently includes 68 SPCs but more 

SPCs may be added to the waste stream. The 68 containers were described in CCP-AK-INL-570, 

Revision 1, and CCP-AK-INL-571, Revision 0. EPA determined that the scope could be 

expanded to incorporate an additional 25 SPCs currently stored in transuranic vaults (TUVs) at 

NRF, awaiting shipment to INTEC for repackaging and characterization. EPA agreed with the 

expansion based on AK, the radiological characterization approach, and RTR. Therefore, the 

expanded evaluation scope has a total of 93 SPCs. INL-CCP provided a revised AKSR, 

Radiological Characterization Report, Certification Plan, and other documents that reflected the 

expanded scope. The expanded scope is adequately documented. 

Naval Reactor Facility (NRF) personnel examined fuel from nuclear-powered warships, 

prototype plants, and the Shippingport Atomic Power Station, as well as specimens from various 

test reactors. As a result of sectioning operations, Waste Stream IN-ID-NRF-SPC includes 

wastes that were collected in sludge pans, as well as other debris such as stainless-steel aircraft 

cable, nuts and bolts, steel saw parts and cut-off wheels, brass tags, lead, aluminum, and Zircaloy 

foils. Worn or broken abrasive wheels and other noncombustible waste were also placed in the 

sludge pans. Each sludge pan contained approximately three teaspoons of fuel fines or chips. The 

physical composition of the waste is well understood and supports the waste stream 

determination; see Item (7) for additional information about the physical composition of the 

waste stream (References C016, C093, C098, C101, P043, P050, P066, P067, P073, U086, 

U106, U123, U124, U131, U132, and U133). 

Five basic fuel types were sectioned in the Alpha Box and WETSAW enclosures, as stated 

previously. Each sludge pan was assigned a unique number, and each was correlated to a specific 

fuel that was sectioned. Fuel types were not comingled within sludge pans, so the radiological 

composition of each sludge pan is directly related to the fuel type that was sectioned. Table 3 

presents fuel types and percentages based on their generation and/or storage location. Each SPC 

grouping (TUVs, Alpha Box, and WETSAW) is composed primarily of Fuel Type 1. This 

continuity indicates that the waste stream was appropriately defined; see Item (7) for additional 

radiological information. Based on process, radiological, and physical information, the waste 

stream was adequately defined. 
7

Table 3. Fuel Type and Percentage by Generation and/or Storage Location 

Fuel 

Type

Total 

TUV 

% of Total 

SPCs in TUV

Total SPCsAlpha Box % of SPCsAlpha Box Total SPCsWETSAW% of SPCsWETSAWTotal 

SPCs 

% of Total 

SPCs 

1 19 76% 37 60.65% 7 100% 63 67.74 

2 1 4% 10 16.39% 0 0% 11 11.83 

3 0 0% 7 11.48% 0 0% 11 11.83 

4 4 16% 3 4.92% 0 0% 3 3.23 

5 1 4% 4 6.56% 0 0% 5 5.38 

Total 25 100% 61 100% 7 100% 93 100%

(2) The Certification Plan, as revised to include a description of the waste characterization 

process, was examined and found to be complete. 

The WCPIP requires that the Certification Plan describe the process for certification of the waste 

stream, including a description of the following: 

• AK characterization methods selected to meet the DQOs, including the justification for 

the selection of the methods 

• Quality assurance (QA) objectives for the selected methods 

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

allow for CBFO approval prior to implementation 

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

qualification methods 

CCP-AK-INL-572, Revision 1, states that a combination of characterization methods was 

employed to characterize Waste Stream IN-ID-NRF-SPC, specifically AK, radiological 

characterization, and RTR. AK was used to determine and describe the waste stream, to define 

Waste Isolation Pilot Plant Land Withdrawal Act (LWA) required DQOs such as the defense 

status of the waste [Item (9)] and the absence of HLW and SNF [Item (8)], and to establish the 

isotopic composition of each SPC, which was later modified through modeling and used in the 

DTC process to determine the radiological composition of the waste stream. 

EPA examined CCP-AK-INL-572, Revision 0, during the initial evaluation and found that it did 

not adequately describe the radiological waste characterization process. Specifically, it did not 

adequately explain the applicability of the sampling of NRF Waste Stream IN-ID-NRF-153 to 

Waste Stream IN-ID-NRF-SPC. As discussed in EPA Docket No. A-98-49; II-A4-135, the NRF 

radiological data were collected outside of an approved QA program. Therefore, the data were 

confirmed and qualified through sampling and analysis of combustible Waste Stream IN-IDNRF-SPC. INL-CCP also used the sampling results to determine how to adjust the NRF data to 

account for the depletion of 137Cs. The adjusted NRF data were used to develop an individual set 

of scaling factors for each container of SPC waste.

INL-CCP revised CCP-AK-INL-572 to state that the sampling and analyses done in support of 

the radiological characterization of Waste Stream IN-ID-NRF-153 (discussed in CCP-AK-INL-
8

561) was also intended to support the radiological characterization for the 93 SPCs. Section 6.2 

of this report discusses the use of sampling data to characterize Waste Stream IN-ID-NRF-SPC. 

EPA’s examination found that the required elements are included and that the Certification Plan 

is adequate. 

5164

(3) The waste characterization pathway was identified, and documentation of the approach 

was adequate. 

Table 4 summarizes the waste characterization pathway as presented in the revised Certification 

Plan and Radiological Characterization Report. 

Table 4. Characterization Methods for Waste Stream 

Item Method Location of Method 

Description Supporting BDR 

Physical 

Parameters 

Characterization by radiography CCP-AK-INL-572 BDR INLRHRTR11001 

Radiological 

Parameters 

Radiological characterization 

using AK-derived scaling factors 

verified by sampling and analysis 

of another debris waste stream. 

DTC used to derive radiological 

characteristics. 

CCP-AL-INL-571 

CCP-AK-INL-572 

BDR INLRHDTC11001 

INL-CCP used AK to identify the waste stream, exclude HLW and SNF, and verify the defense 

status of the waste stream. INL-CCP also used AK to establish the isotopic composition of each 

SPC [see Item (2), above], which was determined using AK, modeling, and DTC. The physical 

composition of the waste stream, including the absence of prohibited items, was determined 

using radiography. The characterization pathway was adequately identified. 

 

(4) Examples of nonconformance and discrepancy resolution documentation were examined 

and found to be adequate. 

INL-CCP provided Nonconformance Report (NCR) No. NCR-RHINL2540110 with BDR 

INLRHDTC11001. The NCR applied to five drums: NRFTRUSPC065-1, NRFTRUSPC062-1, 

NRFTRUSPC060-1, NRFTRUSPC059-1, and NRFTRUSPC061-1. All five drums exhibited a 

TRU alpha activity concentration less than or equal to 100 nanocuries per gram (nCi/g), and the 

drums were segregated for management as non-TRU waste. INL-CCP addressed these in a single 

DR, DR003 (CCP-TP-005, Attachment 11), that also addressed discrepancies associated with 

assignment of hazardous waste numbers. INL-CCP demonstrated adequate implementation of 

the NCR and DR processes. 

(5) The acceptable knowledge procedure and related attachments were examined and found 

to be adequate and appropriately implemented. 

During the WCPIP revision process, CBFO transferred AK procedural requirements from the 

WCPIP to procedure CCP-TP-005, Revision 22. CCP subsequently revised Revision 22 as part 
9

of the resolution of CBFO CAR11-043 (Revision 23) and again revised the procedure on 

November 28, 2011, to incorporate additional WCPIP requirements (Revision 24). Many Waste 

Stream IN-ID-NRF-SPC documents, including Revision 1 of the AKSR, were created under 

CCP-TP-005, Revision 22 (April 21, 2011); other documents were created under Revisions 23 or 

24. EPA found that CCP-TP-005, Revision 24, reflected all applicable WCPIP requirements and 

expects that all document revisions and procedure implementation will follow the requirements 

in the revision of CCP-TP-005 that is in place at the time of the activity. 

INL-CCP provided CCP-TP-005, Attachments 1, 2, 3, 4, 5, 6, 8, 11, 13 (draft), 14, and 15: 

• “Attachment 1 – Acceptable Knowledge Documentation Checklist,” is the roadmap 

identifying source documents that provide required information. 

• “Attachment 2 – Record of Communication,” is an interview form. It is used to generate 

source documents identified by a “C” when an interview is performed (e.g., Reference 

C039). 

• “Attachment 3 – Acceptable Knowledge Source Document Summary,” summarizes 

source document contents; INL-CCP provided examples during the inspection. All copies 

of Attachment 3 are kept in the CCP QA files and are attached to the accompanying AK 

source document if CCP generated that source document (e.g., correspondence, AK 

accuracy reports). Other, non-CCP-generated source documents are in AK records, but 

EPA was only given copies of those source documents released by the U.S. Navy. 

Several documents were designated as Not Releasable to Foreign 

Nationals/Governments/Non-U.S. Citizens (NOFORN), and EPA reviewed those 

documents at the evaluation in Golden, Colorado. 

• “Attachment 4 – Acceptable Knowledge Source Document Information List,” was 

updated in January 2012, to include new references supporting the additional 25 SPCs 

stored at the TUV. 

• “Attachment 5 – Hazardous Constituents,” addresses hazardous waste numbers. This 

attachment is not applicable and was therefore not reviewed by EPA. 

• “Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and 

Packaging,” is addressed in Item (7) below. 

• “Attachment 8 – Waste Containers List,” was updated to include all 93 SPCs. 

• “Attachment 11 – Acceptable Knowledge Source Document Discrepancy Resolution,” is 

addressed in Item (4) above. 

• “Attachment 13 – CCP Waste Stream Characterization Checklist,” is provided when 

characterization of a waste stream is near completion and, therefore, has not yet been 

prepared. This is acceptable, given the timing of the evaluation. 

• “Attachment 14 – CCP Acceptable Knowledge Accuracy Report,” was provided but EPA 

did not review it. (See the explanation below.) 

• “Attachment 15 – CCP TRU Waste Correlation and Surrogate Summary Form,” was 

provided but EPA did not review it. (See the explanation below.) 
10

The attachments were prepared on forms presented in either CCP-TP-005, Revisions 22, 23, or 

24, depending on the revision in place at the time. This is acceptable because implementation of 

the AK process for this waste stream spanned four generations of CCP-TP-005 revisions. 

INL-CCP did not provide CCP-TP-005, Attachments 7, 9, 10, and 12, for the following reasons: 

• “Attachment 7 – Radionuclides,” was not prepared and is not applicable because the AK 

NDA memorandum is specific to CH wastes. 

• “Attachment 9 – Waste Characterization Data Cross-Reference,” is a reference tool and, 

therefore, does not require completion of a form. 

• “Attachment 10 – Acceptable Knowledge Re-evaluation Checklist,” was not prepared 

because it was not necessary. 

• “Attachment 12 – Example Form and Content Guide for AK Summary Reports,” is a 

reference tool for writing the AKSR. AKSR adequacy is addressed in Item (6) below. 

Both the AK accuracy report and the Correlation and Surrogate Summary Form contained 

typographical errors or technically inadequate information. EPA chose not to review 

Attachments 14 and 15 in detail because the documents’ contents did not impact the evaluation 

and EPA has previously observed the successful preparation of Attachments 14 and 15. CCP-TP005 was adequately implemented. 

(6) The AKSR, associated source documents and reference list, were examined and found to 

be adequate. 

EPA reviewed the AKSR and identified deficiencies in waste stream definition, physical waste 

description and packaging, radiological composition, and identification of the characterization 

and qualification pathways. The AKSR also required revision to include the 25 SPCs in the 

TUVs. INL-CCP revised the AKSR to address these deficiencies (CCP-AK-INL-570, 

Revision 2). The AKSR provides necessary information presented in CCP-TP-005, 

Attachment 12, and was adequately revised to address deficiencies identified by EPA during the 

evaluation. 

(7) The overall radiological and physical properties of the waste stream were examined and 

found to be adequately described based on acceptable knowledge. 

Waste Stream IN-ID-NRF-SPC is primarily metal debris consisting of the SPCs, metal fines, 

absorbent materials, and other materials. Specific items include metal parts, pans, and containers; 

lead and nonreactive Zircaloy foil (Reference C069); cut-off saw pieces; rubber; fuller’s earth 

(clay absorbent); and other inorganic materials. Available INL-CCP RTR data sheets verify the 

waste composition. INL-CCP used historic waste packaging information (e.g., References U106 

and U109) to estimate the waste material parameter (WMP) percentages (Reference U130); the 

calculations considered information for all sludge pans, including those managed in the TUVs. 

INL-CCP categorized the waste items by WMP and estimated the WMP volumes for each SPC 

based on the loading log sheet information, and it calculated weights based on publicly available 

waste item weight estimates. INL-CCP’s calculations showed the waste to be 99.8% inorganic 
11

materials and 0.2% organic materials, which is generally verified by available INL-CCP RTR 

results. The absence of liquid is documented through RTR. The physical composition of Waste 

Stream IN-ID-NRF-SPC is well understood. 

Five basic fuel types were sectioned in the Alpha Box and WETSAW enclosures, as discussed 

above. INL-CCP did not provide the general radiological composition of “Advanced Fuel” or 

“Standard Fuel.” However, CCP-AK-INL-561 describes the radiological composition of INL 

Waste Stream IN-ID-NRF-153 and includes the scaling factors for each fuel type, which are 

generally representative of the fuel composition, listed in Table 5. These values only reflect the 

availability of AK radiological information and were not used to develop the SPC-specific 

scaling factors for Waste Stream IN-ID-NRF-SPC.

Table 5. Fuel Type Scaling Factors Derived from the NRF Radiological Data 

Radionuclide Fuel Type 1 Fuel Type 2 Fuel Type 3 Fuel Type 4 Fuel Type 5 

241Am 2.63E-03 3.32E-04 6.75E-04 1.00E-01 1.59E-04 

244Cm 1.90E-03 1.92E-05 5.32E-06 1.98E-03 1.23E-06 

154Eu 2.61E-02 1.08E-02 5.86E-03 6.71E-03 5.83E-03 

238Pu 2.44E-01 3.60E-02 8.76E-03 1.62E-02 2.11E-03 

239/240Pu 5.08E-04 1.07E-04 3.51E-04 3.81E-02 8.28E-05 

241Pu 2.40E-02 2.58E-03 6.32E-03 6.65E-01 1.49E-03 

90Sr 9.37E-01 9.39E-01 9.72E-01 4.10E-01 1.01E+00 

228Th 4.04E-06 1.88E-06 3.66E-03 3.27E-07 9.77E-03 

232U 3.93E-06 1.83E-06 3.55E-03 3.17E-07 9.49E-03 

233/234U 5.55E-05 6.70E-05 2.28E-03 6.17E-06 6.32E-03 

235U 2.28E-06 2.65E-06 3.06E-06 4.23E-05 7.20E-07 

236U 7.57E-06 9.31E-06 6.75E-06 1.16E-06 1.65E-06 

INL-CCP found that the majority of SPCs contained Fuel Type 1, as shown in Table 3. INL-CCP 

examined the SPC-specific radiological information provided by NRF (Reference U130) and 

developed a table presenting the general radiological distribution for the waste stream as a 

whole, shown in AKSR Table 7. INL-CCP generated this table by summing the total quantity of 

each radionuclide identified by NRF, then developing the mass and curie (Ci) distributions for 

the waste stream as a whole. EPA’s review of the available AK data indicates that the 

radiological composition of the waste stream was available to INL-CCP, and overall radiological 

composition was adequately described in the AKSR. 

(8) The waste stream information was examined and indicates that the waste stream does not 

contain spent nuclear fuel or high-level waste. 

The LWA prohibits the disposal at the WIPP of SNF and HLW, as defined by the Nuclear Waste 

Policy Act (NWPA). The NWPA states that SNF is “fuel that has been withdrawn from a nuclear 

reactor following irradiation, the constituent elements of which have not been separated by 

reprocessing.” DOE M 435.1-13expands on this definition and states that “test specimens of 

fissionable material irradiated for research and development only, and not production of power 

or plutonium, may be classified as waste, and managed in accordance with the requirements of 

 

3

 DOE M 435.1-1 is DOE’s Radioactive Waste Management Manual, Revision 1, issued June 2001. 
12

this Order when it is technically infeasible, cost prohibitive, or would increase worker exposure 

to separate the remaining test specimens from other contaminated material.” The NWPA defines 

HLW as “the highly radioactive material resulting from the reprocessing of spent nuclear fuel, 

including liquid waste produced directly in reprocessing and any solid material derived from 

such liquid waste that contains fission products in sufficient concentrations, and other highly 

radioactive material that the Commission, consistent with existing law, determines by rule 

requires permanent isolation.” The waste is composed of fuel dust and chips generated by 

sectioning spent fuel rods. No intact rods or large portions of rods are included in the waste 

stream, so the waste does not contain SNF. Also, no HLW was generated because the fuel was 

not chemically modified. 

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

defense in origin. 

The AKSR states that RH TRU waste is eligible for disposal at the WIPP if it has been generated 

in whole or in part by one of the atomic energy defense activities listed in Section 10101(3) of 

the NWPA. The Alpha Box and WETSAW enclosure both managed defense-related material 

during the time the waste stream was generated. Naval reactor fuels were the primary fuel types 

that were sectioned and included fuel elements from nuclear-powered warships, prototype plants, 

irradiated test specimens related to the naval reactor systems, and the Shippingport Atomic 

Power Station (References C099, P005 and P019). EPA agrees that references support the 

sectioning of defense-related fuels in both the Alpha Box and WETSAW enclosures, and that the 

waste stream will contain fines from the sectioning of these fuels. 

(10) The draft Waste Stream Profile Form and attached Characterization Reconciliation 

Report were examined and found to be adequate. 

With implementation of the WCPIP, INL-CCP elected to generate a single WSPF that satisfied 

both the WCPIP and the New Mexico Environment Department permit. The WCPIP states that 

the WSPF must contain the following: 

• WSPF number 

• Generator site 

• Technical contact/telephone number 

• Generator site EPA identification number 

• Summary category group 

• Waste stream name and description 

• Number of containers 

• BDR numbers supporting waste stream characterization 

• AKSR number 

• SPM signature and date 

The CRR is attached to the WSPF and must contain the following, at a minimum: 
13

• Specification of applicable site and waste stream 

• Listing of each DQO 

• Data from the AK record that address each DQO 

• AK source document references that support/provide the data 

• Listing of AK record DRs relevant to each DQO 

• Documentation, such as BDRs, corroborative data, or peer review proceedings, including 

specific references, of how the AK data for each DQO were qualified 

• Radiography and/or VE summary to document that prohibited liquids are absent and to 

confirm the waste’s physical properties 

• Summary presentation of radiological data used to meet the DQOs and to confirm AK 

• Complete AK summary (unless previously submitted) 

• Complete listing of all container identification numbers used to generate the WSPF, 

cross-referenced to each BDR 

• Signature of the SPM 

The draft WSPF required revision to reflect the current number of containers in the waste stream 

(93) and to include an updated AK Summation of Aspects that reflected changes to the AKSR. 

INL-CCP provided a revised CRR that references an incorrect Certification Plan, but EPA 

assumes that this typographical error will be corrected in the future. The draft WSPF did not 

specify the BDR or provide a detailed waste stream description, but it referenced and attached a 

Characterization Information Summary and AK Summation of Aspects. Both of these 

attachments are required to demonstrate WCPIP compliance. The updated draft WSPF is 

adequate. 

(11) Drum data are traceable and are in the acceptable knowledge record. 

The SPC drums underwent a complex history of waste generation, packaging, remediation, 

shipment, and characterization. This history must be summarized to explain the traceability data 

examined. EPA selected six SPCs to assess whether their general history and waste management 

can be verified, as summarized in Table 6. 

Waste fines were collected in sludge pans as fuels were segmented. Alpha Box and WETSAW 

Enclosure logbooks were used to record the specific details of every activity, including fuel 

element sectioning, equipment installation, and cleaning. Forms (e.g., ECF-NRFE-169) were 

used to document SPC information, including fuel type, mass, SPC contents, and storage 

location (References P008, P015, U027, U028, and U106). Sludge pans contained fuel fines and 

water that was used as a coolant for the cutting operations; therefore, after sectioning a specific 

fuel element or type, the sludge pans were either air dried or filled with fuller’s earth to absorb 

liquids. 
14

Once dried, each sludge pan was placed in an SPC that was stainless or carbon steel. Early in the 

program, closed SPCs were placed in concrete TUVs and held in dry storage at NRF, where they 

remained at the time of EPA’s evaluation. NRF later decided to manage SPCs by storing them in 

an ECF water pit after drying/absorption. In 2007, NRF determined that the SPCs in the water pit 

could generate hydrogen gas, so these SPCs underwent pressure abatement in a pressure 

abatement container (PAC) while in the water pit. The SPCs were removed from the water pit 

and PAC and were remediated by permanently venting; SPCs were also tested for water content 

using a water detection tool, and SPCs that contained water were vacuum dried. The water 

inspection tool and a small screen filter used during these remediation activities were placed in 

each SPC following the remediation efforts (References C104, P031, P032, and P050). 

Once remediated, the SPCs were packaged into sludge pan container shielded containers 

(SPCSCs); these containers were returned to the water pit and were placed in shielded 55-gallon 

drums that were shipped to INTEC for characterization. At INTEC, the SPCSCs were removed 

from the shipping drums, and the SPCs were removed from the SPCSCs. Each SPC will be 

placed in a 30-gallon drum that will be overpacked in a 55-gallon drum. Radiography and DTC 

are conducted on this last configuration (References C028, C039, C071, C085, C102, C103, 

C104, C105, C115, P010, P054, P073, U106, and U126). 

EPA determined that the information associated with each container is traceable through the 

major phases of the waste generation, remediation, packaging, shipment, and characterization 

processes. 

(12) Acceptable knowledge training was examined and found to be adequate. 

The WCPIP indicates that characterization program personnel responsible for compiling AK, 

characterizing RH TRU waste streams using the AK process, and assessing the AK 

characterization shall be qualified and trained in the following: 

• The WCPIP 

• Characterization program NCR and corrective action processes 

• Site-specific training relative to the site’s waste streams; e.g., current AKSRs 

• Determination of the radiological contents of individual containers

The WCPIP also states that the “RH TRU characterization program is responsible for 

maintaining records of the training provided to personnel responsible for compiling AK” 

(page 33). Table 7 presents the training received by key AK personnel interviewed during the 

inspection, as documented by the cited information.
15

Table 6. Traceability Information for Selected Drums in Waste Stream IN-ID-NRF-SP

CCP Drum 

Number SPC 

Fuel 

Type Origin 

Initial SPC 

Generation 

Date 

Closure 

Date 

Original 

SPC 

Loading* 

PAC Venting 

Information* 

Drilling and 

Water 

Inspection 

Records 

SPCSC 

Packaging 

** 

Rep

by 

Not yet assigned 26 1 Alpha Box 

in the TUVs 

9/8/1976 Still at 

NRF 

U109 None—TUV 

storage 

None—TUV 

storage 

None—

TUV 

storage 

NRFTRUSPC039-1 39 2 Alpha Box 6/22/1978 4/11/11 U106, 

p. 11 

P069 P031/P051 P073 

NRFTRUSPC040-1 40 3 Alpha Box 7/10/1978 12/22/10 U106, 

p. 15 

P069 P031/P051 P073 

NRFTRUSPC055-1 55 1 Alpha Box 2/21/1980 12/6/10 U106, 

p. 41 

P069 P031/P051 P073 

NRFTRUSPC083-1 83 1 Alpha Box 7/30/1987 12/8/10 U106, 

 p. 86 

P069 P031/P051 P073 

NRFTRUSPC094-1 94 1 WETSAW 12/11/2001 12/11/01 U132, 

p. 52 

P069 P031/P051 P073 

* This column displays the source document number. ** Packaging procedure only; NRF did not provide documentation of packaging.
16

Table 7. AK Training Qualification Summary 

Name WCPIP 

Nonconformance 

and Corrective 

Action 

(CCP-QP-005) 

Site-Specific 

Training 

Determining 

Radiological 

Contents of 

Containers 

Current Revision of 

CCP-TP-005 

Jim Luginbyhl Qual Card Qual Card 

CCP 

Document 

Control 

Screenshot 

Briefing 

R21: Att 6 

R22: Briefing and Att 15 

R23: Att 8 and 15 

Mark Doherty Qual Card Qual Card 

CCP 

Document 

Control 

Screenshot 

Briefing Qual Card 

Lisa Watson Qual Card Qual Card Email 

Statement Briefing R23: Briefing 

Accompanying each approval request, EPA expects INL-CCP to provide up-to-date training 

documentation for all AK personnel that includes periodic briefings/training to keep AK 

personnel abreast of AK documents and WCPIP revisions. EPA will rely on inspection 

interviews to determine whether AK experts are familiar with procedure revisions that are less 

critical. 

(13) Data quality objectives were evaluated and found to be adequately met. 

The WCPIP identifies the following DQOs that must be addressed: 

Defense Waste, HLW, and SNF Determination (Regulatory Basis: LWA): This ensures that the 

waste stream was generated by atomic energy defense activities, is not HLW, and is not SNF. 

These are addressed in CCP-AK-INL-570, Revision 2, and CCP-AK-INL-572, Revision 1, as 

discussed above in Items (9) and (8), respectively.

Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP): 

• TRU Waste Determination: Waste must contain more than 100 nanocuries of TRU 

isotopes per gram of waste. 

• RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem 

per hour (mrem/hr) and less than 1,000 rem/hr.4

• Activity Determination: The total waste inventory can be no more than 5.1 million Ci of 

RH TRU; activity limit per canister is 23 Ci per liter; and all radionuclides important to 

release calculations must be tracked. 

 

4 Rem or millirem is a unit of dose equivalent, which is often commonly 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. The actual difference among these values for the 

purpose of this report is negligible. 
17

These three DQOs are addressed in CCP-AK-INL-571, Revision 1, as discussed in Section 6.2 

below. 

Physical Properties (Regulatory Basis: EPA Certification of the WIPP): 

• Liquids: The absence of liquids in excess of one percent must be confirmed. 

• Physical Form: The physical form of the waste must be determined to delineate the waste 

stream as required by the final certification rule.

These two DQOs are addressed as discussed in Item (7), above. 

EPA determined that the documents cited above supported that all DQOs were achieved either 

through AK, radiography, or the radiological characterization process. EPA also determined that 

the waste stream was appropriately identified based on process, radiological, and physical 

information, and the appropriate WCPIP elements were adequately addressed. 

Summary of Acceptable Knowledge Findings and Concerns

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

addition of Waste Stream IN-ID-NRF-SPC during this T1 change evaluation. 

Changes to Tiering

Based on the results of this evaluation, there are no changes to the AK T1 or T2 designations as 

identified during the baseline inspection and subsequent T1 evaluations. 

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA is approving the T1 request to add Waste Stream INID-NRF-SPC.

6.2 Radiological Characterization 

EPA examined the radiological characterization process and associated information to support 

the inclusion of Waste Stream IN-ID-NRF-SPC in the INL-CCP approval. 

Radiological Characterization Overview

The overall approach to characterizing Waste Stream IN-ID-NRF-SPC is DTC in conjunction 

with radionuclide-specific scaling factors. The scaling factors were developed based on NRFsupplied estimates of the radionuclide distribution and activity of each SPC, as representative of 

the fuel types involved in the sectioning operations. A set of 137Cs-based scaling factors was 

developed for each SPC, incorporating the partitioning of 137Cs and the distribution of fuel fines 

between the sludge pans and the Alpha Box/WETSAW Enclosure. 
18

The NRF data from Waste Stream IN-ID-NRF-153 had been confirmed previously by sample 

collection and radiochemical analyses/mass spectrometry of debris from the Alpha Box and 

WETSAW Enclosure. These results were used to qualify the NRF radiological data and to 

determine whether and to what extent the 137Cs remained in the fuel matrix (137Cs partitioning). 

The NRF radionuclide data were based on known dimensions of fuel elements and cuts, in 

conjunction with reactor physics calculations performed by Oak Ridge Isotope Generation and 

Depletion (ORIGEN-S), as documented in CCP-AK-INL-561, Revision 1. This provided activity 

values for radionuclides of each fuel type based on the quantity of fuel in each SPC. Figure 1 

provides an overview of the radiological characterization process used for the IN-ID-NRF-SPC 

wastes. 

The DTC measurement aspect was not directly assessed during this T1 evaluation in Golden, 

Colorado. EPA did evaluate the characterization methods used for the IN-ID-NRF-SPC RH 

wastes in terms of the technical adequacy of the approach, 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. 

Technical Evaluation

(1) The EPA inspection team evaluated the correlation of waste records and cesium-137 

concentrations for Waste Stream IN-ID-NRF-SPC and found it to be adequate. 

INL-CCP’s approach is predicated on the assumption that radionuclide-specific information for 

Waste Stream IN-ID-NRF-SPC applies directly to Waste Stream IN-ID-NRF-153 that is 

documented in CCP-AK-INL-561. NRF estimates of the fuel mass in each SPC were based on 

known dimensions of fuel elements and the width of cuts made by the cut-off wheel. Using 

ORIGEN-S, NRF calculated the activities for each SPC according to the quantities of each of the 

five fuel types. Sampling and analysis data from the Alpha Box cleanup were used to confirm the 

NRF data for the actinides and fission products in each sludge pan. After confirmation, a single 

set of 137Cs-based scaling factors was developed for the Alpha Box-related debris designated as 

Waste Stream IN-ID-NRF-153. 

The sampling and analysis results for Waste Stream IN-ID-NRF-153 were also used to derive the 

ratio of the actual mass of 137Cs over the expected mass, the 137Cs enhancement factor (EF) of 

4.17. The 137Cs EF represents the increase in 137Cs in the debris transferred to the Alpha Box by 

the cut-off wheel cooling water, leading, in turn, to less 137Cs in the sludge pans than there would 

have been if water had had no impact. This reduction in 137Cs results in higher137Cs-based 

scaling factors compared to if there was no 137Cs depletion. The 137Cs EF is defined as 

(strontium-90 (90Sr)/137Cs)mix / (90Sr/137Cs)sample data without regard for the mix of fuel types, 

assuming a fuel fine release factor of 15%, with the remaining 85% of fuel fines deposited in the 

48 sludge pans in the Alpha Box. 
19

Figure 1. Flow Diagram of the Characterization Process: IN-ID-NRF-SPC 

Locate and retrieve relevant records 

Use the NRF data, ORIGEN-S, and 

137Cs depletion factor (0.441)* to 

determine the scaling factors, i.e., 

1/0.441 times the ratio of the total 

activity of each radionuclide divided 

by the total 137Cs activity, for the 

type of fuel contained in each SPC 

Validate ORIGEN results by 

comparing the model outputs to 

similar modeling data and NRF 

data 

Use MicroShield® to model the gamma dose rate at 1 meter from 

the drum as a function of density to develop a 137Cs DTC 

correlation based on a 1-Ci source of 137Cs and 154Eu 

Develop DTC correlation factors (mR/hr/Ci)-density relationships 

for 137Cs and 154Eu and determine the dose-partitioning factor 

Find mean gamma dose rate at 1 meter from the drum based on 

four measurements, determine the waste density based on weight 

of drum contents and fill factor 

Divide the mean measured dose rate by the DTC conversion factor 

to find the 137Cs activity in curies 

Multiply the 137Cs activity by the scaling factors to determine 

the activities of the radionuclides of interest

Determine the uncertainties for the radionuclides of interest 

Determine Scaling Factor: Determine DTC Conversion Factor:

Execute DTC to Determine 137CS Activity:

* Definitions and calculations to estimate the 137Cs Depletion Factor: 

Fuel Fine Release Fraction = mass of fuel fines in Alpha Box and WETSAW Enclosure/total mass of fuel fines = 0.15 = 15% 

Fuel Fine Retention Fraction = 1 - Fuel Fine Release Fraction = 1 - 0.15 = 0.85 = 85%

137Cs EF = mass of 137Cs in Alpha Box and WETSAW Enclosure/expected mass of 137Cs in Alpha Box and 

 WETSAW Enclosure = 4.17 

137Cs Release Fraction = Fuel Fine Release Fraction * 137Cs EF = 0.15 * 4.17 = 0.6255 = 62.55% 

137Cs Retention Fraction = 1 - 137Cs Release Fraction = 1 - 0.6255 = 0.3745 = 37.45% 

137Cs Depletion Factor = 137Cs Retention Fraction/Fuel Fine Retention Fraction = 37.45%/85% = 0.441 

The 137Cs EF represents the increase in 137Cs on debris transferred to the Alpha Box by the cut-off wheel cooling water. The 137Cs EF 

is defined as (90Sr/137Cs)mix/(90Sr/137Cs)sample data without regard to the mix of fuel types contributing to the Alpha Box sample data. 
20

While Waste Stream IN-ID-NRF-SPC contains SPCs from both the Alpha Box and WETSAW 

Enclosure fuel element cutting operations, the sampling of Waste Stream IN-ID-NRF-153 did 

not include the WETSAW Enclosure. However, the Alpha Box data can serve as surrogates for 

WETSAW Enclosure SPCs. This means that the data provided by NRF apply to both Waste 

Stream IN-ID-NRF-153 and Waste Stream IN-ID-NRF-SPC. Accordingly, the fuel fine release 

and retention fractions and the 137Cs EF were used to develop a set of 137Cs-based scaling factors 

for each SPC in Waste Stream IN-ID-NRF-SPC. These scaling factors are used to determine the 

activities and masses of all reportable radionuclides in each waste drum. These activities are 

documented in calculation packages INL-RH-81 through INL-RH-85 and incorporate the 

following information: 

• Activity estimates of a large number of radionuclides, including the actinides and fission 

products, contained in each of the 93 SPCs 

• Scaling factors for the five fuel types derived from NRF data 

• Role of sampling and analysis results as surrogates for qualifying NRF data 

• Use of the 137Cs EF value of 4.17 

• Use of the fuel fine release fraction value of 15% and the fuel fine retention fraction value 

of 85% 

• Calculation of the 137Cs release fraction value of 62.55% and the 137Cs retention fraction 

value of 37.45% 

• Calculation of the 137Cs depletion factor value of 0.441 

• Calculation of the sets of scaling factors using the 137Cs depletion factor 

• Shielding calculations to derive DTC relationships for 137Cs and europium-154 (154Eu) 

• Consideration of water as the fuel matrix in the shielding calculations 

• Additional calculations to confirm the modeling approach selected 

Calculation of the 137Cs activity for a container allows the determination of the following: 

• Activity in Ci and mass in grams for each of the 10 WIPP-tracked radionuclides, 

i.e., 137Cs, americium-241 (241Am), plutonium-238 (238Pu), 239Pu, 240Pu, 242Pu, 90Sr, 233U, 

234U, and 238U 

• Associated uncertainty for all radionuclides listed in previous bullet 

• Status of a waste drum as TRU, i.e., greater than 100 nCi/g of TRU alpha activity 

• Fissile gram equivalent 

• Pu-equivalent Ci 

• Decay heat in watts 
21

The constants and other values required for these calculations were taken from the appropriate 

sources [RH-TRU Waste Authorized Methods for Payload Control (TRAMPAC)] and were spotchecked for accuracy. 

A total of eight shielding calculations were performed using MicroShield® with 1-Ci each 

sources of 137Cs and 154Eu uniformly distributed throughout a 55-gallon waste drum for a fuller’s 

earth density of 41.6 pounds per cubic foot, a tare weight of 40.6 pounds for the SPC, a fill 

height of 18 inches for the SPC, a density of 11.45 specific gravity for the oxide fuel, and a 

density of 1.873 specific gravity for the Cs. These results were then used to derive DTC 

relationships for 137Cs and 154Eu. Using the scaling factor for 154Eu for dose partitioning, the 

DTC conversion factor for 137Cs was determined. The actual DTC calculations are performed 

using an Excel spreadsheet in which the input includes the following [see Item (3) below]: 

• Drum identification number 

• Container gross weight 

• Four external dose rate measurements 

There were no concerns about the correlation of waste records for the 93 55-gallon drums of 

Waste Stream IN-ID-NRF-SPC with 137Cs concentrations. 

(2) The development of radionuclide scaling factors was evaluated and was found to be 

technically adequate and appropriately documented. 

Calculation of the radionuclide-specific scaling factors developed for the 93 individual drums is 

documented in INL-RH-82 and Attachment 2 of CCP-AK-INL-571, Revision 0. EPA evaluated 

the technical basis for the following aspects: 

• Activity values derived from modeling and statistical metrics using the mean and 

standard deviation values for each radionuclide 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 

• Isotopic activity values correlated to the radionuclides whose physical half-lives are such 

that they could be responsible for the measured external dose rate; i.e., 137Cs and 154Eu 

• Potential contributions of short-lived radionuclides to the measured dose rate 

• Appropriate decay correction according to DTC procedure CCP-TP-504, Revision 10, of 

all radionuclides for the purpose of model development (note: decay corrections should 

be made to a new shipping date) 

• ORIGEN-S results used to develop radionuclide-specific scaling factors that are corrected 

for the 137Cs depletion factor (0.441) and are used to quantify those radionuclides from 

the measured 137Cs values and DTC relationships 

• Activity and uncertainty values determined for the 10 WIPP-tracked radionuclides: 

241Am, 137Cs, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U 
22

• Determination of the contribution of all radionuclides to the radiological hazard5

• Shielding and other calculations supporting the scaling factors performed using 

MicroShield®to derive the appropriate DTC relationships for a 55-gallon drum 

• Estimation of the scaling factor variation due to fuel composition, burnup, and decay 

period used as normal fuel parameters in the NRF ORIGEN-S calculations 

• Estimation of the scaling factor variation due to ORIGEN-S benchmark uncertainty by 

earlier ORIGEN-S benchmark analyses 

There are no issues related to the technical adequacy or documentation of radionuclide scaling 

factors for Waste Stream IN-ID-NRF-SPC. 

(3) The technical basis of the dose-to-curie correlation and its documentation were evaluated, 

and both aspects were acceptable. 

 

The DTC correlation was evaluated based on DTC BDR No. INLRHDTC11001, which 

contained 12 SPC drums. The EPA evaluation team verified that this BDR included the 

following: 

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

• “Attachment 1 – CCP Nonconformance Report (NCR)” 

• Container data sheets for 12 drums (Attachment 2), with activities and uncertainties for 

the 10 WIPP-tracked radionuclides: 241Am, 137Cs, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U,

234U, and 238U 

• “Attachment 4 – Batch Data Report Cover Sheet” 

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

• “Attachment 6 – Batch Data Report Narrative Summary” 

• “Attachment 7 – ITR Checklist” 

• “Attachment 8 – SPM Checklist” 

• Evidence of signatures by the Independent Technical Reviewer (ITR) on Attachment 7 

and an SPM on Attachment 8 

• Waste container DTC conversion records with all required parameters for 12 drums 

• TRU determination for 12 drums on waste container DTC conversion records 

• Correct revision of CCP-TP-504 at the time of measurement (Revision 10) 

Five of the 12 containers were determined not to be TRU because they have TRU alpha 

concentrations less than 100 nCi/g, as documented in NCR No. NCR-RHINL2540110. The BDR 

 

5

 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this

information may be useful in understanding other aspects of a container’s radiological characterization. 
23

was technically adequate. There were no issues related to the DTC correlation and its 

documentation for Waste Stream IN-ID-NRF-SPC. 

(4) Technical aspects and documentation of the radiological characterization process were 

evaluated and found to be acceptable. 

CCP-AK-INL-571 and the six calculation packages listed in Attachment 1 describing the 

radiological characterization process for Waste Stream IN-ID-NRF-SPC had been prepared and 

reviewed by Jene Vance and Jim Holderness. The EPA evaluation team reviewed these 

documents in advance of the formal T1 evaluation meeting in Golden, Colorado. The documents 

were discussed during the meeting, at which time the EPA evaluation team had the opportunity 

to raise specific technical concerns and point out apparent discrepancies to INL-CCP personnel. 

As a result of these discussions, INL-CCP made revisions to several documents, all of which 

EPA reviewed. 

While the information provided adequately supports the basis for the radiological 

characterization process with respect to the SPCs in aggregate, it does not necessarily provide 

technical support for assigning SPC-specific scaling factors. However, given the constraints on 

obtaining further information regarding Waste Stream IN-ID-NRF-SPC and the magnitude of the 

uncertainty values assigned to SPC drums, EPA finds this approach to be adequate. 

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

were found to be adequate. 

 

The development of total measurement uncertainty (TMU) for Waste Stream IN-ID-NRF-SPC is 

based on the propagation of uncertainties in all aspects of the radiological characterization 

process. These aspects are assumed to be independent, which allows them to be added in 

quadrature.6

 The TMU determination included the uncertainty contributions of the following: 

• DTC correlation – waste density, MicroShield® code, and modeling uncertainties 

•

137Cs activity measurement – instrument and distance measurement uncertainties, and 

uncertainty in the dose contribution of other gamma-emitting radionuclides 

• Scaling factor determination – including 137Cs depletion factor uncertainty

• NRF inventory estimates – ORIGEN-S benchmarking, code inputs, and estimated 

contributions of different fuel types to the SPC inventory

A general treatment of TMU for this waste stream is presented in CCP-AK-INL-571 and 

Calculation Package INL-RH-84, Revision 0. The principal sources of uncertainty are 

uncertainties in the 137Cs depletion factor, ORIGEN-S benchmarking, variation in code inputs, 

and NRF inventories. There were no concerns regarding the technical derivation and 

documentation of TMU for Waste Stream IN-ID-NRF-SPC. 

 

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. 
24

(6) Remote-handled and transuranic determinations were assessed and were found to be 

adequate. 

The RH determinations for SPC containers were documented on Radiological Survey Reports 

from INTEC that were collected in January 2011. EPA reviewed the RH determinations for SPC 

Container Nos. NRFTRUSPC039A-1, NRFTRUSPC040-1, NRFTRUSPC046-1, 

NRFTRUSPC047-1, NRFTRUSPC055-1, NRFTRUSPC064-1, NRFTRUSPC065-1 and 

NRFTRUSPC083-1. Seven of the containers were measured in four locations at the center height 

of the drum, and all had external dose rates in excess of 200 mrem/hr. Container 

No. NRFTRUSPC065-1 had a single external dose rate measurement on the bottom of the drum 

that exceeded 200 mrem/hr, but it was determined to be non-TRU. 

DTC BDR No. INLRHDTC11001 lists 12 SPC containers that were surveyed, five of which 

were determined to be non-TRU on the basis of having a TRU concentration less than 100 nCi/g. 

The BDR contained NCR NCR-RHINL2540110 to address the lack of a duplicate measurement 

because this was not required under CCP-TP-504, Revision 10, which was in place when the 

surveys were performed. The DTC BDR documented the appropriate source and background 

checks and was acceptable. 

There were no technical or documentation-related concerns regarding the TRU and RH 

determinations for the containers in Waste Stream IN-ID-NRF-SPC. 

Summary of Radiological Characterization Findings and Concerns

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

characterization of Waste Stream IN-ID-NRF-SPC during this T1 change evaluation. 

Changes to Tiering

Based on the results of this evaluation, there are no changes to the radiological characterization 

T1 or T2 designations as identified during the baseline inspection and subsequent T1 evaluations. 

Radiological Characterization Approval

Based on the results of this evaluation, EPA is approving the T1 request to add Waste Stream INID-NRF-SPC.

6.3 Real-Time Radiography 

EPA had evaluated and approved the RTR process for RH TRU wastes at INL in 2007 (see 

Docket No. A-98-49; II-A4-80). For this T1 evaluation, EPA reviewed RTR BDR 

No. INLRHRTR11001 that documented the RTR process for SPC wastes. The BDR contained 

the following: 

• Required Measurement Control Reports dated January 17, 18, 19, and 25, 2011 
25

• RTR data generated for SPC containers on four separate occasions: 

January 17, 2011 – Container Nos. NRFTRUSPC047-1, NRFTRUSPC060-1, 

NRFTRUSPC062-1, and NRFTRUSPC065-1 

January 18, 2011 – Container Nos. NRFTRUSPC055-1, NRFTRUSPC059-1, 

NRFTRUSPC064-1, and NRFTRUSPC089-1 

January 19, 2011 – Container No. NRFTRUSPC039A-1 

January 25, 2011 – Container Nos. NRFTRUSPC040-1, NRFTRUSPC046-1, and 

NRFTRUSPC061-1 

• Required quality control examinations: Replicate Scan for Container 

No. NRFTRUSPC064-1 and Independent Observation for Container 

No. NRFTRUSPC055-1 

• Review checklists for data-generation-level (ITR) and project-level (SPM) reviews 

Data were generated using CCP RH Standard Real-Time Radiography Inspection Procedure 

CCP-TP-508, Revision 7. There was no NCR generated for this BDR. 

The independent observation and replicate scans were performed by different operators, as 

required. EPA inspectors reviewed the written and audio/visual recordings for selected 

containers in the BDR and determined that data sheets were complete and were consistent 

between the records.

The CCP list of qualified individuals (LOQI) that the EPA inspectors reviewed demonstrated 

that RTR data were generated by qualified personnel. EPA also reviewed selected training 

records, including practical demonstrations of competence for the RTR operators generating the 

data contained in BDR No. INLRHRTR11001. EPA determined that the operators were trained 

in accordance with CCP requirements. 

Summary of Real-Time Radiography Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to RTR for Waste 

Stream IN-ID-NRF-SPC during this T1 change evaluation. 

Changes to Tiering

Based on the results of this evaluation, there are no changes to the RTR T1 or T2 designations as 

identified during the baseline inspection and subsequent T1 evaluations. 

Real-Time Radiography Approval

Based on the results of this evaluation, EPA is approving the T1 request to add Waste Stream INID-NRF-SPC.
26

7.0 SUMMARY OF RESULTS 

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

and RTR proposed for use by INL-CCP to characterize RH TRU SPC wastes from the Alpha 

Box and WETSAW Enclosure in the ECF at NRF are acceptable. There are no open issues 

relative to this T1 evaluation. 

Findings and Concerns

The EPA inspection team did not identify any findings or concerns during the inspection. 

Tiering Changes

Based on the results of this evaluation, there are no changes to the INL RH tiering table included 

in the March 2011 EPA report evaluating INL RH debris containers from Lot 4A of Hot Fuel 

Examination Facility (HFEF) Waste Stream ID-HFEF-S5400-RH. 

Approval

EPA determined that the procedures and processes used by INL-CCP for the addition of Waste 

Stream IN-ID-NRF-SPC, currently consisting of 93 55-gallon drums, were adequate. EPA, 

therefore, approves Waste Stream IN-ID-NRF-SPC as a T1 change to INL-CCP’s RH baseline 

approval. 
A-1

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP 

REMOTE-HANDLED WASTE CHARACTERIZATION PROGRAM 

Specific INL RH Approval Date EPA Docket Number 

INL RH Baseline Approval January 2007 A-98-49; II-A4-72 

Tier 1 Change – Approval of Visual Examination January 2007 A-98-49; II-A4-75 

Tier 1 Change – Approval of Real-Time Radiography February 2007 A-98-49; II-A4-80 

Tier 1 Change – Approval of K Cell Wastes January 2008 A-98-49; II-A4-97 

Tier 1 Change – Approval of High-Range Gamma Probe for DTC April 2008 A-98-49; II-A4-98 

Tier 1 Change – Approval of Visual Examination Technique September 2009 A-98-49; II-A4-118 

Tier 1 Change – Addition of Twelve Containers to Waste Stream 

ID-ANLE-S5000 and Addition of Waste Stream ID-HFEF-S5400-RH January 2010 A-98-49; II-A4-122 

Tier 1 Change – Approval of Waste Stream ID-MFC-S5400-RH June 2010 A-98-49; II-A4-126 

Tier 1 Change – Approval of Waste Stream ID-INTEC-S5400-RH August 2010 A-98-49; II-A4-130 

Tier 1 Change – Addition of Lot 1B to Waste Stream 

ID-HFEF-S5400-RH August 2010 A-98-49; II-A4-131 

Tier 1 Change – Approval of Waste Stream IN-ID-NRF-153 November 2010 A-98-49; II-A4-135 

Tier 1 Change – Approval of Waste Stream ID-RTC-S3000 November 2010 A-98-49; II-A4-137 

Tier 1 Change – Addition of Lot 4A to Waste Stream 

ID-HFEF-S5400-RH March 2011* A-98-49; II-A4-145 

*This report contains the latest revision of the tiering requirements. 
B-1 

ATTACHMENT B 

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION 

CCP-AK-INL-560, Central Characterization Project Acceptable Knowledge Summary Report 

for Idaho National Laboratory Remote-Handled Transuranic Debris Waste from the Naval 

Reactors Facility Waste Stream IN-ID-NRF-153, Revision 2, September 30, 2009 

CCP-AK-INL-561, Central Characterization Project Remote-Handled Transuranic Radiological 

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

National Laboratory Naval Reactors Facility Waste Stream IN-ID-NRF-153, Revision 1, 

May 10, 2010 

CCP-AK-INL-570, Central Characterization Project Acceptable Knowledge Summary Report 

for Idaho National Laboratory Remote-Handled Transuranic Debris Waste from the Naval 

Reactors Facility Waste Stream IN-ID-NRF-SPC, Revision 1, June 6, 2011, and Revision 2, 

December 5, 2011 

CCP-AK-INL-571, Central Characterization Project Remote-Handled Transuranic Radiological 

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

National Laboratory Naval Reactors Facility Waste Stream IN-ID-NRF-SPC, Revision 0, 

April 25, 2011, and Revision 1, November 29, 2011 

CCP-AK-INL-572, Central Characterization Project RH TRU Waste Certification Plan for 

40 CFR Part 194 Compliance and Confirmation Test Plan for INL Waste Stream IN-ID-NRFSPC, Revision 0, April 14, 2011, and Revision 1, October 31, 2011 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revisions 21, 22, 23, and 24, 

December 29, 2010, April 21, 2011, June 30, 2011, November 28, 2011 

CCP-TP-005, Attachment 1 – Acceptable Knowledge Documentation Checklist, 

Site(s): Idaho National Laboratory, IN-ID-NRF-SPC, J. Luginbyhl, generated October 13, 2011 

CCP-TP-005, Attachment 4 – Acceptable Knowledge Source Document Information List, 

Site(s): Idaho National Laboratory, Waste Stream IN-ID-NRF-SPC, J. Luginbyhl, January 1, 

2012 

CCP-TP-005, Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and 

Packaging, Idaho National Laboratory, IN-ID-NRF-SPC, J. Luginbyhl, January 13, 2011

CCP-TP-005, Attachment 8 – Waste Containers List, Naval Reactors Facility at Idaho National 

Laboratory, Waste Stream IN-ID-NRF-SPC, J. Luginbyhl, December 16, 2011 

CCP-TP-005, Attachment, 13 – CCP Waste Stream Characterization Checklist, draft, unsigned, 

undated, generated December 2011 
B-2 

CCP-TP-005, Attachment 14 –Acceptable Knowledge Accuracy Report: Idaho National 

Laboratory Waste Stream IN-ID-NRF-SPC Lot 1, I. Quintana, for audit purposes only, June 24, 

2011 

CCP-TP-005, Attachment 15 – CCP TRU Waste Correlation and Surrogate Summary 

Form, Naval Reactors Facility at Idaho National Laboratory, Waste Stream IN-ID-NRF-SPC, 

Waste Stream Used to Correlate IN-ID-NRF-153, J. Luginbyhl, December 13, 2011 

Characterization Information Summary Waste Stream IN-ID-NRF-SPC Lots 1–8, I. Quintana, 

December 16, 2011 

CRR-IN-ID-NRF-SPC-001, Waste Stream IN-ID-NRF-SPC, CCP-TP-506, Attachment 4, draft 

for audit purposes only, unsigned, generated September 2, 2011 

CRR-IN-ID-NRF-SPC-001, Waste Stream IN-ID-NRF-SPC, generated December 22, 2011 

DTC BDR No. INLRHDTC11001 

Memorandum, J. Vance to I. Quintana, Re: Analysis of Sample Data for RH TRU Debris Waste 

Generated from the NRF at INL, August 23, 2009 

NCR No. NCR-RHINL2540110, Less Than 100 nCi/g, NRF Drums, C. Boland, May 2011 

Radiological Survey Reports for NRF-SPC Container Nos. NRFTRUSPC039A-1, 

NRFTRUSPC040-1, NRFTRUSPC046-1, NRFTRUSPC047-1, NRFTRUSPC055-1, 

NRFTRUSPC064-1, NRFTRUSPC065-1 and NRFTRUSPC083-1 

Remote-Handled TRU Waste Characterization Program Implementation Plan, Revision 2, DOE 

WIPP-02-3124, U.S. Department of Energy, Carlsbad Field Office, April 21, 2011 

RH-TRAMPAC Document, Revision 0, U.S. Department of Energy, Carlsbad Field Office, 

June 2006 

RTR BDR No. INLRHRTR11001 

WSPF for Waste Stream IN-ID-NRF-SPC, I. Quintana, June 2, 2011 

WSPF for Waste Stream IN-ID-NRF-SPC, I. Quintana, draft for audit purposes only, December 

22, 2011 

C016, Memorandum to H. Wade, Re: Alpha Box Waste Material Identification 

Letter to Manager, Pittsburgh Naval Reactors Office, Approval Request of NRF Alpha-Box 

Waste Accountability Facilities, J.F. Ruggiero, October 12, 1976 

C028, Correspondence to M.W. Littleton, Re: ECF Transuranic Waste Disposal Plan Summary, 

E.L. Juell, NRFE-EE-7503, November 18, 1977 
B-3 

C039, Interview with H. Thompson, NRF Hot Cell Technician, Re: WETSAW Operations, J. 

Luginbyhl, February 5, 2009, Attachment 2, CCP-TP-005 

C069, Correspondence to E.L. Juell, Re: Zircaloy and Uranium Shipment Request, A.D. Rogers,

ADR-110-87, August 28, 1987

C071, Correspondence to J.L. Gregory, Re: ECF Plan To Reduce Backlog of Transuranics, 

E.L. Juell, NRFE-E-344, June 15, 1984 

C085, Correspondence to C.J. Sing, Re: Sludge Pan Container Activity Estimates, T.J. Malewitz, 

NRF-WS-226, December 19, 2007 

C093, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Expended Core Facility-Sludge 

Pan Container Disposal Plan for Approval, M.J. Zavidny, NRF-E(RME)-542, August 1, 2007 

 

C098, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Expended Core Facility-Sludge 

Pan Container Remediation Planning Letter for Servicing Facility Use, R.L. Elder, B-REO(SC)-

251, August 3, 2006 

C099, PCER No. B-REO(A4W)-7130, Re: Radiological Controls for Potential Containers 

Requiring Remediation, M.W. Weisfield, B-REO(A4W)-7130, September 12, 2005 

C101, Letter to file, CC: H.B. Gonzales, Re: SPC Procedures with Liquid, T.N. Miller, NRFE(RME)-777, November 27, 2007 

C102, Letter to T. Clements, Re: Trans-U Vault Information (for INTEC), J.I. Eavenson, NRFE(RME)-755, September 5, 2007 

C103, Correspondence to D.A. Arcidiacono, Manager, RPCOINRF, Re: Transuranic Vault 

Sludge Pan Containers, J.A. Dokos, NRF-E(RME)-677, April 30, 2007 

C104, Correspondence to D.A. Arcidiacono, Manager, ECF-RPCO, Re: Detonation Pressure in 

the Transuranic Vaults, C.M. Roadhouse, B-REO(SC)-312, May 30, 2007 

C105, Correspondence to D.A. Arcidiacono, Manager, RPCO/NRF, Re: Response to 

B-REO(SC)-291, T.N. Miller, NRF-E(RME)-671, April 10, 2007 

C115, Letter to T. Clements, Re: Letter to INTEC Documenting the Radionuclide Activities and 

Hazard Evaluation for Sludge Pan Container 96, W.L. Harris, NRF-E(RME)-1065E1, 

November 24, 2009 

DR003, Acceptable Knowledge Source Document Resolution, SPC Hazardous Waste Numbers, 

J. Luginbyhl, March 19, 2009, Attachment 11, CCP-TP-005 

P005, Transmittal of the Evaluation of Naval Reactors Facility Radioactive Waste Disposed of at 

the Radioactive Waste Management Complex, S.L. Dunn, NR: IBO-05/023, February 3, 2005 
B-4 

P008, Alpha Box Operations and Maintenance, NRF 1661.22, 1986 

P010, Alpha Box Support Operations, NRF 1661.22 9, October 1, 1984 

P015, Management of Alpha Box Waste, NRF 1661.22, Revision 9, March 1, 1982 

P019, Description of Naval Spent Nuclear Fuel Receipt and Handling at the Expended Core 

Facility at the Idaho National Engineering Laboratory, C.A. Detrick, WAPD-OT(E)-107, 

Attachment B, April 1995 

P031, SPC Remediation in Hot Cell 1, J.I. Eavenson, RP05653-A20 2, August 29, 2007 

P032, SPC Vacuum Drying in Hot Cell 1, J.I. Eavenson, RP05653-A23, August 29, 2007 

P043, Cut-Off Wheel Sludge Pan, W. Roach, DWG933B619 C, December 8, 1987 

P050, Hazardous Evaluation/Disposition Form No. 2954 for ECF Sludge Pan Containers 

(SPCs) and Contents for SPC Nos. 31 through 95, 39A, and 71A, R. D. Wingfield, HEF 2954, 

March 23, 2009 

P051, Deficiency Form for SPC 39, J.I. Eavenson, DR/DL 08225, September 21, 2007 

P054, Component Movement and Inventory System, R.M. Stetz, NRF 1660.403, April 1, 2007 

P055, Transuranic and Alpha Container Remediation Meeting at Naval Reactors Facility, 

D.M. Chauvet, B-REO(SC)-291, February 22, 2007 

P066, ECF Sample Storage Tube (Hex Containers), RPCO, NRF, January 23, 2004 

P067, Cut Fuel Storage Container (Hex Container), J.K. Corley, TRR-ECF, March 5, 2004 

P069, PAC Operations, RP05653-A2 11, May 17, 2007 

P073, Store WETSAW Fines in the Main Hot Cell Bank, K.B. Gibbard, RP07736-A4, 

January 31, 2008 

P207, Stainless Steel Sludge Pan Containers (SPCs) and Contents for SPC Nos. 21 through 30, 

Currently Located in Transuranic Vaults (TUVs), W.L. Harris, HEF 3136, Revision 1, 

September 15, 2010 

P208, ECF Carbon Steel Sludge Pan Containers (SPCs) and Contents for SPC Nos. 00, 1, 2, 3, 4, 

5, 6, 7, 9, 11, 13, 14, 15, 16, and 18, W.L. Harris, HEF 3137, Revision 1, September 15, 2010 

P209, ECF Empty Group 1 Transuranic Waste Vaults (POL Y-6-LWBR, TRU-POL Y-7-S3G), 

W.L. Harris, HEF 3161, Revision 3, September 14, 2010
B-5 

P210, ECF Group 1 Transuranic Waste Vault EC0100004, which Contains Carbon Steel SPC 

Nos. 15, 16, 18 and Stainless Steel SPC No. 22 in an SPC Storage Insert, W.L. Harris, HEF 

3207, Revision 1, October 14, 2010 

P211, ECF Group 1 Transuranic Waste Vault EC0200002, Containing Carbon Steel SPC 

Nos. 00, 14 and Stainless Steel SPC Nos. 21, 24, 25 and 28 in an SPC Storage Insert, W.L. 

Harris, HEF 3208, Revision 1, October 14, 2010 

P212, ECF Group 1 Transuranic Waste Vault EC0300001, Containing Carbon Steel SPC Nos. 1, 

2, 3, 4 and Stainless Steel SPC 26 in an SPC Storage Insert, W.L. Harris, HEF 3209, Revision 1, 

October 14, 2010 

P213, ECF Group 1 Transuranic Waste Vault EC0300002, Containing Carbon Steel SPC Nos. 5, 

6, 7 and 9 in an SPC Storage Insert, W.L. Harris, HEF 3210, Revision 1, October 14, 2010 

P214, ECF Group 1 Transuranic Waste Vault TR-U-SPC-5-MIX, Containing Carbon Steel SPC 

Nos. 11, 13 and Stainless Steel SPC Nos. 23, 27, 29 and 30 in an SPC Storage Insert, W.L. 

Harris, HEF 3211, Revision 1, October 14, 2010

P215, Transuranic Vault Transport System Assembly and Spare Parts, D. Lower, HEF 3155, 

Revision 0, March 4, 2010

U027, Alpha Box Log, Volume I, March 1, 1976 

U028, Alpha Box Log, Volume 2, March 26, 1985 

U086, Technical Work Record on Noncombustible “Transuranic Waste” in ECF Storage, 

E.L. Juell, July 22, 1988 

U106, SPC Load Logs for SPC Nos. 31–85, 87–89, 71A, and 39A, various dates 

U109, Data Logs for SPC Nos. in TUVs, unsigned, various dates 

U123, ECF Route Card on Resin Column Disposal, J.F. Ruggiero, RC 30154, June 6, 1979

U124, ECF Route Card on Repackaging Zirc Chips and Resin for Water Pit Storage, undated 

U126, Sludge Pan Container (SPC) Printout, undated 

U130, SPC Drum Evaluation, WMP, J. Luginbyhl, March 3, 2009 

U131, Engineering Design File: Radiological Properties of Remote-Handled Transuranic Waste 

from Naval Reactors Facility, B.T. Baranko, EDF 8775, Revision 2, September 15, 2010 

U132, Log Book for WETSAW, August 15, 1995, to December 11, 2001 
B-6 

U133, WETSAW Records, September 5, 2007 

U160, CCP Calculation Package: Development of Cs-137 Depletion Factor for SPCs, 

J. Holderness, INL-RH-81, December 4, 2009 

U161, CCP Calculation Package: Development of SPC Scaling Factors, J. Holderness, INL-RH82, May 6, 2011 

U162, CCP Calculation Package: NRF SPC Cs-137 Dose-to-Curie RH TRU Radiological 

Correlation for 55-Gallon Drums Characterization, J. Vance, INL-RH-83, December 4, 2009 

U163, CCP Calculation Package: Uncertainty Analysis for NRF SPCs, J. Holderness, INL-RH84, December 4, 2009 

U164, CCP Calculation Package: DTC Spreadsheet for NRF SPCs, J. Holderness, INL-RH-85, 

May 6, 2011 

U165, CCP Calculation Package: Determination of NRF Reportable Radionuclides-SPC, 

J. Holderness, INL-RH-86, May 6, 2011