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 P ROGRAM

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 2012i 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 Drum s in Waste Stream IN-ID-NRF-SPC ......... 15 Table 7. AK Training Qualification Summary ........

................................................... .................. 16

FIGURES

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

ATTACHMENTS

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

Program Attachment B: Listing of Documents Reviewed for Thi s Evaluationii 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 Cent er 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 curieiii

mrem/hr millirem per hour
nCi/g nanocurie(s) per gram
NCR nonconformance report
NDA nondestructive assay
NOFORN Not Releasable to Foreign Nationals/Governme nts/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 Co ntrol (programmatic or

waste-specific data package)

TRU transuranic

TUV transuranic vault

U uranium

VE visual examination

WCPIP Remote-Handled TRU Waste Characterization Pro gram Implementation

Plan
WETSAW Wet Element Transverse Sectioning Abrasive W heel

WIPP Waste Isolation Pilot Plantiv

WMP waste material parameter

WSPF Waste Stream Profile Form
WTS Washington TRU Solutions1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of remotehandled (RH) transuranic (TRU) inorganic debris (Su mmary Category Group S5000) Waste Stream IN-ID-NRF-SPC. This waste stream was generat ed by operations in the Alpha Box and Wet Element Transverse Sectioning Abrasive Wheel (W ETSAW) Enclosure at the Naval Reactors Facility (NRF), located at the U.S. Depart ment 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 cer tification of the INL Central Characterization Project (CCP) waste characterizati on program for RH waste. CCP is responsible for characterizing RH wastes at INL using the syste m 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 chang e approvals. A table listing EPA’s approvals of the INL-CCP RH TRU waste characterizat ion program is included as Attachment A. Because there were no new processes o r equipment at INL associated with characterizing these wastes, EPA chose to conduct t his 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 o f containers 1 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 scali ng factors used for RH Waste Stream IN-ID-NRF-SPC are technically appropriate fo r use in the dose-to-curie (DTC) determination for the radiological characterization of the additional containers.

If a population of additional containers requires n ew or different radionuclide scaling factors, those containers will be subject to EPA’s T1 evalua tion 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-A4-1 45).

This report serves as EPA’s public notification of the results of the proposed T1 change and its evaluation. This information will be provided throu gh the EPA website and by sending e-mails to the WIPPNEWS list, in accordance with Title 40 o f 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 th eir radiological and physical contents.2

2.0 PURPOSE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization activ ities 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 incorpor ated in the INL-CCP RH Baseline Approval report cited in Attachment A.

Under the changes to 40 CFR 194.8 promulgated in th e Federal Register on July 16, 2004 (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation 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 req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspec tion to observe at first hand the implementation of the change, or it can opt to cond uct a desktop review of information provided specific to a change. DOE may choose to characteriz e and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU waste usin g processes, procedures, or equipment implemented as T2 changes. EPA reviews T2 changes o n a quarterly basis and may conduct continued compliance inspections to evaluate implem ented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n 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 evalua tion 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 88221-30903

4.0 SCOPE OF THIS EVALUATION

The scope of this T1 evaluation encompassed the add ition 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 characteri zation, and RTR, each of which is addressed separately in this report.

DOE WIPP-02-3124, “Remote-Handled TRU Waste Charact erization Program Implementation Plan” (WCPIP), Revision 2, was effective as of Apri l 21, 2011. EPA requires that all CCP RH TRU waste characterization activities, including th e preparation of documentation and the documents themselves, be in conformance with this v ersion of the WCPIP. All mentions of the WCPIP in this report refer to DOE WIPP-02-3124, Rev ision 2, unless specified otherwise.

5.0 EVALUATION PERSONNEL

EPA and its support personnel interviewed INL-CCP p ersonnel in several disciplines at the October 2011 meeting in Golden, Colorado, and condu cted follow-up discussions by telephone. Table 1 lists the EPA evaluation team members and t he 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 – Radiologi cal Characterization Amir Mobasheran* SC&A, Technical Evaluator – Radiol ogical Characterization Rose Gogliotti* SC&A, Technical Evaluator – Radiolo gical Characterization Dorothy Gill* SC&A, Technical Evaluator – RTR James Luginbyhl CCP/LANL, Acceptable Knowledge Expe rt Mark Doherty CCP/TechSpecs, Acceptable Knowledge Ex pert Lisa Watson CCP/LANL, Acceptable Knowledge Expert Irene Quintana WTS, INL-CCP Site Project Manager (S PM) Jene Vance** CCP, Radiological Characterization Sub ject Matter Expert Neil Dickes CCP/NDA Carlsbad, Observer Ben Roberts DOE-Idaho, Observer Tom Clements CH2M-Washington Group International, O bserver Michael Sensibaugh WTS-CCP Project Management, Obse rver 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 de bris 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, advance d fuel; Type 2, standard fuel; Type 3, uranium-235 and thorium ( 235 U+Th) fuel; Type 4, natural or depleted U blanket f uels; and Type 5, 233 U+Th fuel.

Fuel-element cutting activities were performed in t he 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 fue l elements were remotely sectioned using a slow-speed abrasive cut-off wheel to slice a specim en from the fuel element. Fuel was sectioned in the Alpha Box between 1975 and 1995, and the Alp ha 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 proces s, 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 combu stible waste generated during cleaning was placed in either a 12- or 17-inch plastic bottle; t his material was Waste Stream IN-ID-NRF-153, which EPA evaluated and approved in October 2010 (s ee EPA Docket No. A-98-49; II-A4-135). Sludge pan waste was also collected and placed in s ludge pan containers (SPCs) between sectioning of different fuel types, so the radionuc lides in the SPCs and the organic debris generated during cell cleaning in Waste Stream IN-I D-NRF-153 are similar, if both were generated on or near the same date. It was expected that cesium-137 ( 137 Cs) would be more soluble than the TRU radionuclides in the water use d during the cutting operations and that the difference in solubilities would affect the radionu clide 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 tran sferred from the ECF water pits to the Idaho Nuclear Technology and Engineering Center (IN TEC) for storage, and these have been placed into 30-gallon drums. Each 30-gallon drum, c ontaining one SPC, is overpacked within a 55-gallon drum. The 93 55-gallon drums are identifi ed as INL-CCP Waste Stream IN-ID-NRFSPC and are the subject of this T1 evaluation.

Documents, Waste Containers, Batch Data Reports, an d 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-A K-INL-571, and CCP-AK-INL-

2 Swarf is material that is produced by a cutting or grind ing process.5

572 required revisions as a result of EPA’s evaluat ion, as did some calculation packages. INLCCP provided the revised documents to EPA before th e 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 p rocess and associated information to determine whether INL-CCP demonstrated compliance w ith 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 follow ing with respect to programmatic requirements and the use of AK for RH waste charact erization:

• 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 pathwa y

• Adequacy of training

• Adequacy of the WSPF and related attachments

• Adequacy of nonconformance and discrepancy resoluti on (DR) documentation

• Waste stream definition, including radiological and physical characteristics

• Role of AK in the characterization methodology, inc luding scaling factors

• Verification that the subject waste is of defense o rigin and is not high-level waste (HLW), low-level waste (LLW), or spent nuclear fuel (SNF)

• Adequacy of AK procedure and procedure implementati on6

• Adequacy of the AKSR and associated source document s

• AK data traceability

• Attainment of data quality objectives (DQOs)

Technical Evaluation

(1) The scope of the Tier 1 request and the waste strea m 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-S PC currently includes 68 SPCs but more SPCs may be added to the waste stream. The 68 conta iners were described in CCP-AK-INL-570, Revision 1, and CCP-AK-INL-571, Revision 0. EPA det ermined that the scope could be expanded to incorporate an additional 25 SPCs curre ntly 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 characteriz ation approach, and RTR. Therefore, the expanded evaluation scope has a total of 93 SPCs. I NL-CCP provided a revised AKSR, Radiological Characterization Report, Certification Plan, and other documents that reflected the expanded scope. The expanded scope is adequately do cumented.

Naval Reactor Facility (NRF) personnel examined fue l 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 non combustible waste were also placed in the sludge pans. Each sludge pan contained approximatel y three teaspoons of fuel fines or chips. The physical composition of the waste is well understoo d and supports the waste stream determination; see Item (7) for additional informat ion about the physical composition of the

waste stream (References C016, C093, C098, C101, P043, P050, P06 6, P067, P073, U086, U106, U123, U124, U131, U132, and U133).

Five basic fuel types were sectioned in the Alpha B ox and WETSAW enclosures, as stated previously. Each sludge pan was assigned a unique n umber, and each was correlated to a specific fuel that was sectioned. Fuel types were not coming led 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 appr opriately defined; see Item (7) for additional radiological information. Based on process, radiolo gical, 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 SPCsWETSAW Total

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 des cription of the waste characterization process, was examined and found to be complete.

The WCPIP requires that the Certification Plan desc ribe the process for certification of the waste stream, including a description of the following:

• AK characterization methods selected to meet the DQ Os, including the justification for the selection of the methods

• Quality assurance (QA) objectives for the selected methods

• Characterization and testing methods not included i n the WCPIP in sufficient detail to allow for CBFO approval prior to implementation

• Summary of the program documents to be prepared dur ing the characterization and/or qualification methods

CCP-AK-INL-572, Revision 1, states that a combinati on 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 H LW and SNF [Item (8)], and to establish the isotopic composition of each SPC, which was later m odified through modeling and used in the DTC process to determine the radiological compositi on 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 char acterization process. Specifically, it did not adequately explain the applicability of the samplin g of NRF Waste Stream IN-ID-NRF-153 to Waste Stream IN-ID-NRF-SPC. As discussed in EPA Doc ket No. A-98-49; II-A4-135, the NRF radiological data were collected outside of an appr oved QA program. Therefore, the data were confirmed and qualified through sampling and analys is 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 137 Cs. The adjusted NRF data were used to develop an i ndividual set of scaling factors for each container of SPC waste.

INL-CCP revised CCP-AK-INL-572 to state that the sa mpling and analyses done in support of the radiological characterization of Waste Stream I N-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 t o 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 pathw ay 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 BD R 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, exclu de 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 usi ng AK, modeling, and DTC. The physical composition of the waste stream, including the abse nce of prohibited items, was determined using radiography. The characterization pathway was adequately identified.

(4) Examples of nonconformance and discrepancy resoluti on documentation were examined and found to be adequate.

INL-CCP provided Nonconformance Report (NCR) No. NC R-RHINL2540110 with BDR INLRHDTC11001. The NCR applied to five drums: NRFTR USPC065-1, 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 was te. INL-CCP addressed these in a single DR, DR003 (CCP-TP-005, Attachment 11), that also ad dressed discrepancies associated with assignment of hazardous waste numbers. INL-CCP demo nstrated adequate implementation of the NCR and DR processes.

(5) The acceptable knowledge procedure and related atta chments 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 sub sequently revised Revision 22 as part9

of the resolution of CBFO CAR11-043 (Revision 23) a nd 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 doc uments were created under Revisions 23 or 24. EPA found that CCP-TP-005, Revision 24, reflect ed all applicable WCPIP requirements and expects that all document revisions and procedure i mplementation will follow the requirements in the revision of CCP-TP-005 that is in place at t he 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 int erview form. It is used to generate source documents identified by a “C” when an interv iew is performed (e.g., Reference C039).

• “Attachment 3 – Acceptable Knowledge Source Documen t 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 ar e attached to the accompanying AK source document if CCP generated that source docume nt (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), a nd EPA reviewed those documents at the evaluation in Golden, Colorado.

• “Attachment 4 – Acceptable Knowledge Source Documen t 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 Paramete rs, 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 Docume nt 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 completi on and, therefore, has not yet been prepared. This is acceptable, given the timing of t he 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 Surr ogate Summary Form,” was provided but EPA did not review it. (See the explan ation 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 g enerations 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 an d is not applicable because the AK NDA memorandum is specific to CH wastes.

• “Attachment 9 – Waste Characterization Data Cross-R eference,” 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 info rmation. EPA chose not to review Attachments 14 and 15 in detail because the documen ts’ contents did not impact the evaluation and EPA has previously observed the successful prep aration 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 i n 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 def iciencies (CCP-AK-INL-570, Revision 2). The AKSR provides necessary informatio n presented in CCP-TP-005, Attachment 12, and was adequately revised to addres s 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 acceptabl e knowledge.

Waste Stream IN-ID-NRF-SPC is primarily metal debri s 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. Av ailable INL-CCP RTR data sheets verify the waste composition. INL-CCP used historic waste pack aging 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 esti mated 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% inorganic11

materials and 0.2% organic materials, which is gene rally verified by available INL-CCP RTR results. The absence of liquid is documented throug h RTR. The physical composition of Waste Stream IN-ID-NRF-SPC is well understood.

Five basic fuel types were sectioned in the Alpha B ox and WETSAW enclosures, as discussed above. INL-CCP did not provide the general radiolog ical 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, l isted in Table 5. These values only reflect the availability of AK radiological information and wer e 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

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

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

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

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

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

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

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

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

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

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

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

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

INL-CCP found that the majority of SPCs contained F uel 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 radiologic al distribution for the waste stream as a whole, shown in AKSR Table 7. INL-CCP generated thi s table by summing the total quantity of each radionuclide identified by NRF, then developin g the mass and curie (Ci) distributions for the waste stream as a whole. EPA’s review of the av ailable AK data indicates that the radiological composition of the waste stream was av ailable to INL-CCP, and overall radiological composition was adequately described in the AKSR.

(8) The waste stream information was examined and indic ates that the waste stream does not contain spent nuclear fuel or high-level waste.

The LWA prohibits the disposal at the WIPP of SNF a nd 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 elem ents of which have not been separated by reprocessing.” DOE M 435.1-1 3 expands on this definition and states that “test sp ecimens of fissionable material irradiated for research and de velopment only, and not production of power or plutonium, may be classified as waste, and manag ed 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 f rom the reprocessing of spent nuclear fuel, including liquid waste produced directly in reproce ssing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations, and other highly radioactive material that the Commission, consisten t with existing law, determines by rule requires permanent isolation.” The waste is compose d 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 indic ates that the waste stream is defense in origin.

The AKSR states that RH TRU waste is eligible for d isposal at the WIPP if it has been generated in whole or in part by one of the atomic energy def ense activities listed in Section 10101(3) of the NWPA

. The Alpha Box and WETSAW enclosure both managed de fense-related material during the time the waste stream was generated. Nav al 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 reac tor 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 Alp ha 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 Ch aracterization Reconciliation Report were examined and found to be adequate.

With implementation of the WCPIP, INL-CCP elected t o generate a single WSPF that satisfied both the WCPIP and the New Mexico Environment Depar tment 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 characterizatio n

• AKSR number

• SPM signature and date

The CRR is attached to the WSPF and must contain th e 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 DQ O were qualified

• Radiography and/or VE summary to document that proh ibited liquids are absent and to confirm the waste’s physical properties

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

• Complete AK summary (unless previously submitted)

• Complete listing of all container identification nu mbers used to generate the WSPF, cross-referenced to each BDR

• Signature of the SPM

The draft WSPF required revision to reflect the cur rent number of containers in the waste stream (93) and to include an updated AK Summation of Aspects t hat reflected changes to the AKSR. INL-CCP provided a revised CRR that references an i ncorrect Certification Plan, but EPA assumes that this typographical error will be corre cted 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 Summati on of Aspects. Both of these attachments are required to demonstrate WCPIP compl iance. The updated draft WSPF is adequate.

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

The SPC drums underwent a complex history of waste generation, packaging, remediation, shipment, and characterization. This history must b e summarized to explain the traceability data examined. EPA selected six SPCs to assess whether t heir 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 cle aning. Forms (e.g., ECF-NRFE-169) were used to document SPC information, including fuel ty pe, mass, SPC contents, and storage location (References P008, P015, U027, U028, and U1 06). Sludge pans contained fuel fines and water that was used as a coolant for the cutting op erations; therefore, after sectioning a specific fuel element or type, the sludge pans were either a ir dried or filled with fuller’s earth to absorb liquids.14

Once dried, each sludge pan was placed in an SPC th at was stainless or carbon steel. Early in the program, closed SPCs were placed in concrete TUVs a nd 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 underwen t pressure abatement in a pressure abatement container (PAC) while in the water pit. T he 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 contain ed water were vacuum dried. The water inspection tool and a small screen filter used duri ng these remediation activities were placed in each SPC following the remediation efforts (Referen ces C104, P031, P032, and P050).

Once remediated, the SPCs were packaged into sludge pan container shielded containers (SPCSCs); these containers were returned to the wat er pit and were placed in shielded 55-gallon drums that were shipped to INTEC for characterizati on. 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 (Reference s 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 foun d to be adequate.

The WCPIP indicates that characterization program p ersonnel responsible for compiling AK, characterizing RH TRU waste streams using the AK pr ocess, 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 indiv idual containers

The WCPIP also states that the “RH TRU characteriza tion program is responsible for maintaining records of the training provided to per sonnel responsible for compiling AK” (page 33). Table 7 presents the training received b y key AK personnel interviewed during the inspection, as documented by the cited information.15Table 6. Traceability Information for Selected Drums in Waste Stream IN-ID-NRF-SPCCCP DrumNumberSPCFuelTypeOriginInitial SPCGenerationDateClosureDateOriginalSPCLoading*PAC VentingInformation*Drilling andWaterInspectionRecordsSPCSCPackaging**Repackagedby CCP?CCP BDRNot yet assigned 26 1 Alpha Boxin theTUVs9/8/1976 Still atNRFU109 None—TUVstorageNone—TUVstorageNone—TUVstorageNo Not characterizedat the time of theinspectionNRFTRUSPC039-1 39 2 Alpha Box 6/22/1978 4/11/11 U106,p. 11P069 P031/P051 P073 No Not characterizedat the time of theinspectionNRFTRUSPC040-1 40 3 Alpha Box 7/10/1978 12/22/10 U106,p. 15P069 P031/P051 P073 Yes Not characterizedat the time of theinspectionNRFTRUSPC055-1 55 1 Alpha Box 2/21/1980 12/6/10 U106,p. 41P069 P031/P051 P073 Yes Not characterizedat the time of theinspectionNRFTRUSPC083-1 83 1 Alpha Box 7/30/1987 12/8/10 U106,p. 86P069 P031/P051 P073 Yes INLRHRTR11001INLRHDTC11001NRFTRUSPC094-1 94 1 WETSAW 12/11/2001 12/11/01 U132,p. 52P069 P031/P051 P073 No Not characterizedat the time of theinspection* 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 pe riodic briefings/training to keep AK personnel abreast of AK documents and WCPIP revisio ns. EPA will rely on inspection interviews to determine whether AK experts are fami liar 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 b e addressed:

Defense Waste, HLW, and SNF Determination (Regulato ry 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 m illion Ci of RH TRU; activity limit per canister is 23 Ci per li ter; and all radionuclides important to release calculations must be tracked.

4 Rem or millirem is a unit of dose equivalent, which is often commo nly called dose or when it is expressed per unit time, a dose rate . The criterion for RH determination is expressed i n terms of a dose rate in rem, which, while technically incorrect, is commonly used. In t his 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, R evision 1, as discussed in Section 6.2 below.

Physical Properties (Regulatory Basis: EPA Certific ation of the WIPP) :

• Liquids: The absence of liquids in excess of one percent mu st 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 suppo rted that all DQOs were achieved either through AK, radiography, or the radiological charac terization process. EPA also determined that the waste stream was appropriately identified based on process, radiological, and physical information, and the appropriate WCPIP elements wer e adequately addressed.

Summary of Acceptable Knowledge Findings and Concer ns

The EPA evaluation team did not identify any AK-rel ated 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 subse quent T1 evaluations.

Acceptable Knowledge Approval

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

6.2 Radiological Characterization

EPA examined the radiological characterization proc ess 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 sca ling 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 operation s. A set of 137 Cs-based scaling factors was developed for each SPC, incorporating the partition ing of 137 Cs and the distribution of fuel fines between the sludge pans and the Alpha Box/WETSAW En closure.18

The NRF data from Waste Stream IN-ID-NRF-153 had be en confirmed previously by sample collection and radiochemical analyses/mass spectrom etry of debris from the Alpha Box and WETSAW Enclosure. These results were used to qualif y the NRF radiological data and to determine whether and to what extent the 137 Cs remained in the fuel matrix ( 137 Cs partitioning). The NRF radionuclide data were based on known dimen sions of fuel elements and cuts, in conjunction with reactor physics calculations perfo rmed by Oak Ridge Isotope Generation and Depletion (ORIGEN-S), as documented in CCP-AK-INL-5 61, 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 characteri zation process used for the IN-ID-NRF-SPC

wastes.

The DTC measurement aspect was not directly assesse d during this T1 evaluation in Golden, Colorado. EPA did evaluate the characterization met hods used for the IN-ID-NRF-SPC RH wastes in terms of the technical adequacy of the ap proach, as supported by the program’s documents, procedures, and controls, and the knowle dge and understanding of the personnel involved in the RH waste characterization program.

Technical Evaluation

(1) The EPA inspection team evaluated the correlati on of waste records and cesium-137 concentrations for Waste Stream IN-ID-NRF-SPC and f ound 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 Wast e 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 SP C according to the quantities of each of the five fuel types. Sampling and analysis data from th e 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 137 Cs-based scaling factors was developed for the Alph a 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 137 Cs over the expected mass, the 137 Cs enhancement factor (EF) of 4.17. The 137 Cs EF represents the increase in 137 Cs in the debris transferred to the Alpha Box by the cut-off wheel cooling water, leading, in turn, to less 137 Cs in the sludge pans than there would have been if water had had no impact. This reductio n in 137 Cs results in higher 137 Cs-based scaling factors compared to if there was no 137 Cs depletion. The 137 Cs EF is defined as (strontium-90 ( 90 Sr)/ 137 Cs) mix / ( 90 Sr/ 137 Cs) sample data without regard for the mix of fuel types, assuming a fuel fine release factor of 15%, with th e remaining 85% of fuel fines deposited in the 48 sludge pans in the Alpha Box.19

Figure 1. Flow Diagram of the Characterization Proc ess: IN-ID-NRF-SPC Locate and retrieve relevant records

Use the NRF data, ORIGEN-S, and

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

Develop DTC correlation factors (mR/hr/Ci)-density relationships for 137 Cs and 154 Eu 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 base d on weight of drum contents and fill factor

Divide the mean measured dose rate by the DTC conve rsion factor to find the 137 Cs activity in curies

Multiply the 137 Cs activity by the scaling factors to determine the activities of the radionuclides of interest

Determine the uncertainties for the radionuclides o f interest Determine Scaling Factor: Determine DTC Conversion Factor:

Execute DTC to Determine 137 CS Activity:

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

Fuel Fine Release Fraction = mass of fuel fines in Alpha Box and WETSAW Enclo sure/total mass of fuel fines = 0.15 = 15% Fuel Fine Retention Fraction = 1

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

137 Cs EF = mass of 137 Cs in Alpha Box and WETSAW Enclosure/expected mass of 137 Cs in Alpha Box and WETSAW Enclosure = 4.17

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

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

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

The 137 Cs EF represents the increase in 137 Cs on debris transferred to the Alpha Box by the cu t-off wheel cooling water. The 137 Cs EF is defined as ( 90 Sr/ 137 Cs) mix /( 90 Sr/ 137 Cs) sample data without regard to the mix of fuel types contributi ng 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 samp ling of Waste Stream IN-ID-NRF-153 did not include the WETSAW Enclosure. However, the Alph a Box data can serve as surrogates for WETSAW Enclosure SPCs. This means that the data pro vided 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 137 Cs EF were used to develop a set of 137 Cs-based scaling factors for each SPC in Waste Stream IN-ID-NRF-SPC. These s caling factors are used to determine the activities and masses of all reportable radionuclid es in each waste drum. These activities are documented in calculation packages INL-RH-81 throug h INL-RH-85 and incorporate the following information:

• Activity estimates of a large number of radionuclid es, including the actinides and fission products, contained in each of the 93 SPCs

• Scaling factors for the five fuel types derived fro m NRF data

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

• Use of the 137 Cs 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 137 Cs release fraction value of 62.55% and the 137 Cs retention fraction value of 37.45%

• Calculation of the 137 Cs depletion factor value of 0.441

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

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

• Consideration of water as the fuel matrix in the sh ielding calculations

• Additional calculations to confirm the modeling app roach selected

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

• Activity in Ci and mass in grams for each of the 10 WIPP-tracked radionuclides, i.e., 137 Cs, americium-241 ( 241 Am), plutonium-238 ( 238 Pu), 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U,
234 U, and 238 U

• Associated uncertainty for all radionuclides listed in previous bullet

• Status of a waste drum as TRU, i.e., greater than 1 00 nCi/g of TRU alpha activity

• Fissile gram equivalent

• Pu-equivalent Ci

• Decay heat in watts21

The constants and other values required for these c alculations were taken from the appropriate sources [RH-TRU Waste Authorized Methods for Payloa d Control (TRAMPAC)] and were spotchecked for accuracy. A total of eight shielding calculations were perfor med using MicroShield ® with 1-Ci each sources of 137 Cs and 154 Eu uniformly distributed throughout a 55-gallon was te 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 137 Cs and 154 Eu. Using the scaling factor for 154 Eu for dose partitioning, the DTC conversion factor for 137 Cs was determined. The actual DTC calculations are performed using an Excel spreadsheet in which the input inclu des 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 was te records for the 93 55-gallon drums of Waste Stream IN-ID-NRF-SPC with 137 Cs 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 fa ctors 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 statistic al metrics using the mean and standard deviation values for each radionuclide

• The appropriateness of the choice of physical const ants and radionuclide-specific attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technical c orrectness of the values assigned to each attribute

• Isotopic activity values correlated to the radionuc lides whose physical half-lives are such that they could be responsible for the measured ext ernal dose rate; i.e., 137 Cs and 154 Eu

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

• Appropriate decay correction according to DTC proce dure CCP-TP-504, Revision 10, of all radionuclides for the purpose of model developm ent (note: decay corrections should be made to a new shipping date)

• ORIGEN-S results used to develop radionuclide-speci fic scaling factors that are corrected for the 137 Cs depletion factor (0.441) and are used to quantif y those radionuclides from the measured 137 Cs values and DTC relationships

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

241 Am, 137 Cs, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U22

• Determination of the contribution of all radionucli des to the radiological hazard 5

• Shielding and other calculations supporting the sca ling factors performed using MicroShield

® to derive the appropriate DTC relationships for a 5 5-gallon drum

• Estimation of the scaling factor variation due to f uel composition, burnup, and decay period used as normal fuel parameters in the NRF OR IGEN-S calculations

• Estimation of the scaling factor variation due to O RIGEN-S benchmark uncertainty by earlier ORIGEN-S benchmark analyses

There are no issues related to the technical adequa cy or documentation of radionuclide scaling factors for Waste Stream IN-ID-NRF-SPC.

(3) The technical basis of the dose-to-curie correl ation 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 ver ified that this BDR included the following:

• “Attachment 1 – Measurement Control Report,” with a ll 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: 241 Am, 137 Cs, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U,
234 U, and 238 U

• “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 req uired parameters for 12 drums

• TRU determination for 12 drums on waste container D TC conversion records

• Correct revision of CCP-TP-504 at the time of measu rement (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 i n 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 as pects of a container’s radiological characterizatio n.23

was technically adequate. There were no issues rela ted to the DTC correlation and its documentation for Waste Stream IN-ID-NRF-SPC.

(4) Technical aspects and documentation of the rad iological characterization process were evaluated and found to be acceptable.

CCP-AK-INL-571 and the six calculation packages lis ted in Attachment 1 describing the radiological characterization process for Waste Str eam 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 me eting in Golden, Colorado. The documents were discussed during the meeting, at which time th e 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 revi sions 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 i n aggregate, it does not necessarily provide technical support for assigning SPC-specific scalin g factors. However, given the constraints on obtaining further information regarding Waste Strea m 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 mea surement uncertainty were evaluated and were found to be adequate.

The development of total measurement uncertainty (T MU) for Waste Stream IN-ID-NRF-SPC is based on the propagation of uncertainties in all as pects of the radiological characterization process. These aspects are assumed to be independen t, which allows them to be added in quadrature. 6 The TMU determination included the uncertainty con tributions of the following:

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

• 137 Cs activity measurement – instrument and distance m easurement uncertainties, and uncertainty in the dose contribution of other gamma -emitting radionuclides

• Scaling factor determination – including 137 Cs depletion factor uncertainty

• NRF inventory estimates – ORIGEN-S benchmarking, co de inputs, and estimated contributions of different fuel types to the SPC in ventory

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 137 Cs depletion factor, ORIGEN-S benchmarking, variati on in code inputs, and NRF inventories. There were no concerns regardi ng the technical derivation and documentation of TMU for Waste Stream IN-ID-NRF-SPC

.

6 Adding in quadrature is a standard statistical tec hnique that allows one to combine the square root o f the sum of each contributor to uncertainty squared, res ulting in a lower value than what would be obtained if the values were simply added.24

(6) Remote-handled and transuranic determinations w ere assessed and were found to be adequate.

The RH determinations for SPC containers were docum ented 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, NRF TRUSPC046-1, NRFTRUSPC047-1, NRFTRUSPC055-1, NRFTRUSPC064-1, NRF TRUSPC065-1 and NRFTRUSPC083-1. Seven of the containers were measur ed in four locations at the center height of the drum, and all had external dose rates in exc ess 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 t hat were surveyed, five of which were determined to be non-TRU on the basis of havin g a TRU concentration less than 100 nCi/g. The BDR contained NCR NCR-RHINL2540110 to address t he lack of a duplicate measurement because this was not required under CCP-TP-504, Rev ision 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 co ncerns regarding the TRU and RH determinations for the containers in Waste Stream I N-ID-NRF-SPC.

Summary of Radiological Characterization Findings a nd Concerns

The EPA inspection team did not identify any findin gs or concerns related to the radiological characterization of Waste Stream IN-ID-NRF-SPC duri ng 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 base line inspection and subsequent T1 evaluations.

Radiological Characterization Approval

Based on the results of this evaluation, EPA is app roving 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 evaluati on, EPA reviewed RTR BDR No. INLRHRTR11001 that documented the RTR process f or SPC wastes. The BDR contained the following:

• Required Measurement Control Reports dated January 17, 18, 19, and 25, 201125

• RTR data generated for SPC containers on four separ ate occasions:
January 17, 2011 – Container Nos. NRFTRUSPC047-1, N RFTRUSPC060-1, NRFTRUSPC062-1, and NRFTRUSPC065-1
January 18, 2011 – Container Nos. NRFTRUSPC055-1, N RFTRUSPC059-1, NRFTRUSPC064-1, and NRFTRUSPC089-1
January 19, 2011 – Container No. NRFTRUSPC039A-1
January 25, 2011 – Container Nos. NRFTRUSPC040-1, N RFTRUSPC046-1, and NRFTRUSPC061-1

• Required quality control examinations: Replicate Sc an for Container No. NRFTRUSPC064-1 and Independent Observation for Container No. NRFTRUSPC055-1

• Review checklists for data-generation-level (ITR) a nd 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 wer e performed by different operators, as required. EPA inspectors reviewed the written and a udio/visual recordings for selected containers in the BDR and determined that data shee ts were complete and were consistent between the records.

The CCP list of qualified individuals (LOQI) that t he EPA inspectors reviewed demonstrated that RTR data were generated by qualified personnel . EPA also reviewed selected training records, including practical demonstrations of comp etence for the RTR operators generating the data contained in BDR No. INLRHRTR11001. EPA determ ined that the operators were trained in accordance with CCP requirements.

Summary of Real-Time Radiography Findings and Conce rns

The EPA inspection team did not identify any findin gs or concerns related to RTR for Waste Stream IN-ID-NRF-SPC during this T1 change evaluati on.

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 subse quent T1 evaluations.

Real-Time Radiography Approval

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

7.0 SUMMARY OF RESULTS

EPA concluded that the waste characterization proce sses 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 acce ptable. There are no open issues relative to this T1 evaluation.

Findings and Concerns

The EPA inspection team did not identify any findin gs 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 debr is containers from Lot 4A of Hot Fuel Examination Facility (HFEF) Waste Stream ID-HFEF-S5 400-RH.

Approval

EPA determined that the procedures and processes us ed 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 Janu ary 2007 A-98-49; II-A4-75
Tier 1 Change – Approval of Real-Time Radiography F ebruary 2007 A-98-49; II-A4-80
Tier 1 Change – Approval of K Cell Wastes January 2 008 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 Tech nique September 2009 A-98-49; II-A4-118
Tier 1 Change – Addition of Twelve Containers to Wa ste 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-S54 00-RH June 2010 A-98-49; II-A4-126
Tier 1 Change – Approval of Waste Stream ID-INTEC-S 5400-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-S30 00 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 ti ering requirements.B-1 ATTACHMENT B

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION

CCP-AK-INL-560, Central Characterization Project Ac ceptable Knowledge Summary Report for Idaho National Laboratory Remote-Handled Transu ranic Debris Waste from the Naval Reactors Facility Waste Stream IN-ID-NRF-153, Revis ion 2, September 30, 2009

CCP-AK-INL-561, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d Transuranic Debris Waste from Idaho National Laboratory Naval Reactors Facility Waste S tream IN-ID-NRF-153, Revision 1, May 10, 2010

CCP-AK-INL-570, Central Characterization Project Ac ceptable Knowledge Summary Report for Idaho National Laboratory Remote-Handled Transu ranic Debris Waste from the Naval Reactors Facility Waste Stream IN-ID-NRF-SPC, Revis ion 1, June 6, 2011, and Revision 2, December 5, 2011

CCP-AK-INL-571, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d Transuranic Debris Waste from Idaho National Laboratory Naval Reactors Facility Waste S tream 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 Pl an for INL Waste Stream IN-ID-NRFSPC, Revision 0, April 14, 2011, and Revision 1, Oc tober 31, 2011

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revisions 21, 22, 23, and 24, December 29, 2010, April 21, 2011, June 30, 2011, N ovember 28, 2011

CCP-TP-005, Attachment 1 – Acceptable Knowledge Doc umentation Checklist, Site(s): Idaho National Laboratory, IN-ID-NRF-SPC, J. Luginbyhl, generated October 13, 2011

CCP-TP-005, Attachment 4 – Acceptable Knowledge Sou rce 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 Materi al 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, N aval Reactors Facility at Idaho National Laboratory, Waste Stream IN-ID-NRF-SPC, J. Luginbyh l, December 16, 2011

CCP-TP-005, Attachment, 13 – CCP Waste Stream Characterization Checklist, draft, unsigned, undated, generated December 2011B-2

CCP-TP-005, Attachment 14

– Acceptable Knowledge Accuracy Report: Idaho Nationa l Laboratory Waste Stream IN-ID-NRF-SPC Lot 1, I. Qui ntana, for audit purposes only, June 24, 2011

CCP-TP-005, Attachment 15 – CCP TRU Waste Correlati on and Surrogate Summary Form, Naval Reactors Facility at Idaho National Lab oratory, Waste Stream IN-ID-NRF-SPC, Waste Stream Used to Correlate IN-ID-NRF-153, J. Lu ginbyhl, December 13, 2011

Characterization Information Summary Waste Stream I N-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 Septem ber 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 o f 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 N os. NRFTRUSPC039A-1, NRFTRUSPC040-1, NRFTRUSPC046-1, NRFTRUSPC047-1, NRF TRUSPC055-1, NRFTRUSPC064-1, NRFTRUSPC065-1 and NRFTRUSPC083-1

Remote-Handled TRU Waste Characterization Program I mplementation Plan, Revision 2, DOE WIPP-02-3124, U.S. Department of Energy, Carlsbad F ield 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, J une 2, 2011

WSPF for Waste Stream IN-ID-NRF-SPC, I. Quintana, d raft for audit purposes only, December 22, 2011

C016, Memorandum to H. Wade, Re: Alpha Box Waste Ma terial Identification Letter to Manager, Pittsburgh Naval Reactors Office , Approval Request of NRF Alpha-Box Waste Accountability Facilities, J.F. Ruggiero, Oct ober 12, 1976

C028, Correspondence to M.W. Littleton, Re: ECF Tra nsuranic Waste Disposal Plan Summary, E.L. Juell, NRFE-EE-7503, November 18, 1977B-3

C039, Interview with H. Thompson, NRF Hot Cell Tech nician, Re: WETSAW Operations, J. Luginbyhl, February 5, 2009, Attachment 2, CCP-TP-0 05

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 C ontainer 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. Zavi dny, 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 Servi cing Facility Use, R.L. Elder, B-REO(SC)- 251, August 3, 2006

C099, PCER No. B-REO(A4W)-7130, Re: Radiological Co ntrols for Potential Containers Requiring Remediation, M.W. Weisfield, B-REO(A4W)-7 130, September 12, 2005

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

C102, Letter to T. Clements, Re: Trans-U Vault Info rmation (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)-3 12, 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 1 0, 2007

C115, Letter to T. Clements, Re: Letter to INTEC Do cumenting 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 Resolut ion, SPC Hazardous Waste Numbers, J. Luginbyhl, March 19, 2009, Attachment 11, CCP-TP -005

P005, Transmittal of the Evaluation of Naval Reacto rs Facility Radioactive Waste Disposed of at the Radioactive Waste Management Complex, S.L. Dunn , NR: IBO-05/023, February 3, 2005B-4

P008, Alpha Box Operations and Maintenance, NRF 166 1.22, 1986

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

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

P019, Description of Naval Spent Nuclear Fuel Recei pt and Handling at the Expended Core Facility at the Idaho National Engineering Laborato ry, 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. Eavenso n, RP05653-A23, August 29, 2007

P043, Cut-Off Wheel Sludge Pan, W. Roach, DWG933B61 9 C, December 8, 1987

P050, Hazardous Evaluation/Disposition Form No. 295 4 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 M eeting at Naval Reactors Facility, D.M. Chauvet, B-REO(SC)-291, February 22, 2007

P066, ECF Sample Storage Tube (Hex Containers), RPC O, 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 (P OL Y-6-LWBR, TRU-POL Y-7-S3G), W.L. Harris, HEF 3161, Revision 3, September 14, 20 10B-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 a n 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 Storag e 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, H EF 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 a nd 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 “Tran suranic 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, var ious 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 Propert ies of Remote-Handled Transuranic Waste from Naval Reactors Facility, B.T. Baranko, EDF 877 5, Revision 2, September 15, 2010

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

U133, WETSAW Records, September 5, 2007

U160, CCP Calculation Package: Development of Cs-13 7 Depletion Factor for SPCs, J. Holderness, INL-RH-81, December 4, 2009

U161, CCP Calculation Package: Development of SPC S caling 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