DOCKET NO: A-98-49; II-A4-132

 

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT 

ADDITION OF 30 55-GALLON K-WING DEBRIS WASTE CONTAINERS 

TO THE REMOTE-HANDLED DEBRIS WASTE STREAM (AERHDM) 

AT THE ARGONNE NATIONAL LABORATORY 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Federal Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

September 2010
i 

TABLE OF CONTENTS 

Section Page

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

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

2.0 Purpose of Inspections and Tier 1 Evaluations....................................................................5

3.0 Purpose of This Report ........................................................................................................5

4.0 Scope of the Tier 1 Evaluation.............................................................................................6

5.0 Technical Evaluation of the Addition of 30 Drums of K-Wing Debris Waste....................7

5.1 Acceptable Knowledge ........................................................................................... 7

5.2 Radiological Characterization............................................................................... 17

6.0 Summary of Results...........................................................................................................25

7.0 Conclusions........................................................................................................................26

ATTACHMENTS 

Attachment A: Approval Summary for ANL RH Waste Characterization Program 

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

ACRONYMS AND ABBREVIATIONS 

ACL Analytical Chemistry Laboratory 

AGHCF Alpha Gamma Hot Cell Facility 

AK Acceptable Knowledge 

AKE Acceptable Knowledge Expert 

AKSR Acceptable Knowledge Summary Report 

Am americium 

ANL Argonne National Laboratory 

Ba barium 

BDR Batch Data Report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations 

CH Contact-Handled 

Ci Curie 

Cm curium 

CMT Chemical Technology Division 

CRR Characterization Reconciliation Report 

Cs cesium 

CSSF Correlation and Surrogate Summary Form 

CTP Confirmatory Testing Plan 

DOE U.S. Department of Energy 

DQO Data Quality Objective 

DR Discrepancy Resolution 

DTC Dose-to-Curie 

EPA U. S. Environmental Protection Agency 

g/cm3

 grams per cubic centimeter 

LWR light water reactor(s) 

MCNP5 Monte Carlo N-Particle Transport Code 

NCR Non-Conformance Report 
iii 

ORIGEN Oak Ridge Isotopic Generation Computer Program 

PTS Project Tracking System 

Pu plutonium 

RERTR Reduced Enrichment Research and Test Reactor Program 

RH Remote-Handled 

RTR Real-time Radiography 

SPM Site Project Manager 

Sr strontium 

T1 Tier 1 

T2 Tier 2 

TMI Three Mile Island 

TRU Transuranic 

TSFU Total Scaling Factor Uncertainty 

U uranium 

UREX Uranium Extraction 

VE Visual Examination 

WCPIP Remote-Handled TRU Waste Characterization Program Implementation Plan 

WDS Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMP Waste Material Parameter 

WSPF Waste Stream Profile Form 

Y yttrium 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) decision to approve 

the addition of remote-handled (RH) transuranic (TRU) debris waste to the RH debris Waste 

Stream AERHDM at the U.S. Department of Energy’s (DOE’s) Argonne National Laboratory 

(ANL), as characterized by the Central Characterization Project (CCP). Specifically, this 

approval is for the addition of 30 55-gallon containers1 of debris waste from the K-Wing in 

Building 205 to Waste Stream AERHDM. 

On January 16, 2007, EPA approved ANL-CCP’s waste characterization processes for disposal 

of Waste Stream AERHDM at the Waste Isolation Pilot Plant (WIPP). This baseline approval 

applied to 452 containers of legacy RH debris waste drums. The ANL Baseline Final Inspection 

Report (see EPA Docket No. A-98-49; II-A4-73) cited the inclusion of any additional containers 

of debris wastes as a Tier 1 (T1) change that requires EPA approval prior to implementation. A 

summary of EPA’s approval of the ANL RH TRU waste characterization program is included as 

Attachment A. 

On May 20 and 21, 2010, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 

change to include approximately 30 55-gallon containers of K-Wing debris wastes in Waste 

Stream AERHDM. Because there were no new equipment or processes on site at ANL, EPA 

conducted a desktop review of this change, concluding that the ANL-CCP has used the EPAapproved systems of controls to characterize the additional 30 RH debris containers from KWing to the Waste Stream AERHDM (See Section 5.0 for details). ANL-CCP estimates that 

there are, however, approximately 75 55-gallon containers that would be generated from the KWing activity. The systems of controls evaluated as part of this review continue to be technically 

adequate, and EPA thus approves the T1 change request. EPA did not identify any findings or 

concerns during this evaluation. 

In the future, when ANL-CCP characterizes the remaining 45+ containers of the K-Wing waste 

to add to the approved Waste Stream AERHDM, no T1 change request for approval is necessary, 

if ANL-CCP can demonstrate the following: 

 The additional containers have the same pedigree as the approved waste stream; and 

 The radionuclide scaling factors used for the RH waste stream are technically appropriate 

for use in the Dose-to-Curie (DTC) determination of the radiological characterization of 

the additional containers 

In addition, ANL-CCP must: 

1. Notify EPA concerning the approximate number of additional containers and the 

approximate additional volume of waste. 

 

1

 Containers is a generic term which 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

 The baseline approval was written for 45 containers; however, documentation from ANL-CCP indicates that the 

original waste stream contained 44 drums. Therefore, throughout this report, the size of Waste Stream AERHDM 

varies depending on which document is being referenced. 
2 

2. Provide the timeframe for waste generation, characterization and disposal. 

3. Submit to EPA, upon characterizing a sufficient number of containers to generate 1-2 

Batch Data Reports (BDRs), the following: 

a. the list of characterized containers 

b. a revised Acceptable Knowledge Summary Report (AKSR) and supporting source 

documents 

c. an updated radiological characterization report 

4. Inform EPA if any other waste characterization documents have been changed. 

From the list mentioned in #3 above, EPA may select a few containers for a detailed review to 

verify that the additional containers belong to the approved waste stream and are adequately 

characterized to demonstrate regulatory compliance. 

The ANL-CCP’s compliance with the above conditions is necessary when adding containers to 

the approved Waste Stream AERHDM. When adding containers to an approved waste stream, 

however, if different or new scaling factors are used, the T1 change approval is necessary. 

EPA has revised the original tiering table to add the modified T1 change and the above-listed 

conditions as Tier 2 (T2) changes, as shown in Table 1 in bold. Table 1 below now will apply to 

all RH waste characterization activities occurring at ANL-CCP. 

This report serves as EPA’s public notification of the results of the proposed T1 changes and 

their evaluations. This information will be provided through the EPA website and by sending 

e-mails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 

 
3 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP 

(Based on September 12–14, 2006 Baseline Inspection; Updated August 30, 2010) 

RH Waste Characterization 

Process Elements 

ANL-CCP RH Waste Characterization Process – 

T1 Changes 

ANL-CCP RH Waste Ch

T2 Ch

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline 

Modification of the approved Waste Stream AERHDM to include additional containers beyond the approximately 45 included in CCP-AK-ANLE-500, Revision 1, if new or different radionuclide scaling factors are requiredSubstantive modification(s) that have the potential to affect the characterization process to CCP-AK-ANLE-500, 

CCP-AK-ANLE-501 or CCP-AK-ANLE-502 Implementation of load management for any RH waste stream 

Notification to EPA that the final Dfor RH containers in the approved Notification to EPA when updates as a result of WCPIP revisions Notification that updates have beedocuments: 

 All future revisions of CCP-

CCP-ANLE-AK-501 

 Listing of the references tha

pin data and review process 

 All future revisions of CCP- CCP-AK-ANLE-500 and CC

freeze file changes 

Notification to EPA that the data pstream is completed, including any including the CRR and AK SummNotification to EPA when AK accprepared annually at a minimum Notification to EPA when additiRH TRU Waste Stream AERHDcharacterized using the same raNotification to EPA of availabilisource documents supporting thapproved waste stream*Notification to EPA when Attachgenerated to reflect the updated Reference List Notification to EPA when Attachbeen formally updated 
4 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP 

(Based on September 12–14, 2006 Baseline Inspection; Updated August 30, 2010) 

RH Waste Characterization 

Process Elements 

ANL-CCP RH Waste Characterization Process – 

T1 Changes 

ANL-CCP RH Waste Ch

T2 Ch

Radiological Characterization, including Dose-To-Curie (DTC) 

Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP-504 and CCP-AK-ANLE-501, Revision 0, respectively, or substantive modification thereof Any new waste stream not approved under this baseline or addition of containers to Waste Stream AERHDM that require changing the established radionuclide scaling factors Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ANLE-501 

Notification to EPA that revisions TP-504 that require CBFO approvNotification to EPA of availabilicharacterization report, if generto the approved waste stream* Radiological content data providof additional containers*

Visual Examination (VE) VE by reviewing existing audio/visual recordings for 

summary waste category not covered by this approval VE by any new process for S5000 debris wastes 

Notification to EPA that revisions CBFO approval are complete Addition of new S5000 debris wasPhysical content data provided i

additional containers*

Real-time Radiography (RTR) Any use of RTR requires EPA approval None WIPP Waste Data System (WDS) None Changes made to WDS procedure

Notes: 

- This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 or T2 element 

- ANL-CCP will report all T2 changes to EPA quarterly.- Notification to EPA is not necessary when document updates are editorial in nature or are required to address administrative concerns.

- Substantive modification refers to a change with the potential to affect ANL-CCP’s RH waste characterization process, e.g., the use of an 

measurement instrument or the use of the high-range probe as described in CCP-TP-504 for radiological characterization. 

- Additions to the original tiering table as a result of this T1 evaluation appear in bold.

* These marked changes apply when containers are added to Waste Stream AERHDM and are characterized using the same radionucliude 

characterize the original approved waste stream. EPA notification is required when the site identifies the need to characterize additional conwaste stream. 
5 

2.0 PURPOSE OF INSPECTIONS AND TIER 1 EVALUATIONS 

Any changes to the waste characterization activities from the date of the baseline inspection must 

be reported to, and, if applicable, approved by EPA, according to the tiering requirements set 

forth in the ANL Baseline Final Report cited above. 

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

EPA must perform a single baseline inspection of a TRU waste generator site’s waste 

characterization program. The purpose of a 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. An EPA 

inspection team conducts the baseline inspection to verify that the site’s system of controls is 

technically adequate and properly implemented. 

Following the EPA’s approval of waste characterization processes evaluated during the baseline 

inspection, EPA is authorized to evaluate and approve, if necessary, changes to the site’s 

approved waste characterization program by conducting additional inspections under the 

authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct 

continued compliance inspections to verify that the site continues to use only the approved waste 

characterization processes to characterize the waste and remains in compliance with all the 

regulatory requirements. Based on the adequacies of the waste characterization processes 

demonstrated during the baseline inspection, including all conditions and limitations, EPA 

specified which subsequent waste characterization program changes or modifications must 

undergo further EPA inspection or approval under 40 CFR 194.24. This was accomplished by 

assigning a tier level to each aspect of the ANL-CCP’s characterization program. T1 activities 

have more stringent reporting requirements and require that DOE notify EPA, and that EPA 

provide approval prior to implementation. The rule under which baseline inspections are 

conducted can be found in the Federal Register (Vol. 69, No. 136, pages 42571-42583 of 

July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of T1 changes to include approximately 30 

55-gallon containers of RH TRU debris K-Wing waste (see Section 5.0, below in Waste Stream 

AERHDM, as described in CCP-AK-ANLE-500, Revision 5 and Discrepancy Resolution (DR) 

Form DR023. This report presents the technical basis and results of EPA’s approval decision. 

EPA’s approval decision regarding the inclusion of the K-Wing wastes has been conveyed to 

DOE separately by letter. As discussed previously, 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 at the end of the report. Any of these documents can be 

requested from the following: 
6 

Carlsbad Field Office 

Manager, National TRU Program 

U S Department of Energy 

P O Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THE TIER 1 EVALUATION 

The scope of this evaluation was the inclusion of approximately 30 55-gallon containers of RH 

TRU debris K-Wing waste as described in CCP-AK-ANLE-500, Revision 5. The evaluation was 

performed by comparing elements assessed in the previous EPA approval against information 

about the new drums that was provided by ANL-CCP/CBFO to ensure that these drums fit 

within the approval issued by EPA previously. Some elements of the previous report, i.e., the 

Los Alamos National Laboratory mass spectrometry data, were not evaluated again because the 

addition of these containers did not affect these elements. Only those elements that were affected 

by the addition of the approximately 30 containers were re-evaluated. Because this evaluation 

involved expanding an existing waste stream to incorporate new containers and not the addition 

of a new Summary Category Group or waste stream, an inspection checklist was not used. 

This approval is limited to the addition of approximately 30 55-gallon containers of K-Wing RH 

TRU debris waste. If the remaining approximately 45 55-gallon K-Wing containers are to be 

added to the approved RH debris Waste Stream AERHDM, then the T1 change and T2 changes 

included in the revised tiering table (see Table 1 above) apply. EPA approval is necessary when 

any other RH waste stream generated at ANL which is not an approved debris waste stream is 

characterized for the disposal at the WIPP. 

EPA examined the acceptable knowledge (AK) and radiological characterization processes and 

associated information to determine whether ANL-CCP demonstrated compliance with 40 CFR 

194.8 for a T1 change to add drums to Waste Stream AERHDM. Personnel who participated in 

the T1 evaluation are listed in Table 2, along with each person’s affiliation and function during 

the evaluation. 

Table 2. T1 Evaluation Participants 

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Ed Feltcorn Inspector, U.S. EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 

Kevin Peters Acceptable Knowledge Expert, ANL-CCP 

Irene Quintana Site Project Manager, ANL-CCP 

Jene Vance Radiological Characterization Subject Matter Expert, ANL-CCP 
7 

5.0 TECHNICAL EVALUATION OF THE ADDITION OF 30 DRUMS OF K-WING 

DEBRIS WASTE 

5.1 Acceptable Knowledge 

EPA examined the AK process and associated information to determine whether the ANL-CCP 

waste characterization program demonstrated compliance with the requirements of 40 CFR 194.8 

for the addition of approximately 30 K-Wing containers of RH TRU debris waste to ANL Waste 

Stream AERHDM. 

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with respect to the use of AK for waste 

characterization as impacted by the addition of new containers: 

 Waste stream identification and definition 

 Radionuclide content of additional waste 

 Physical composition of additional waste 

 Sufficiency of modified AKSR to include the additional waste 

 Drum data traceability 

 Defense origin of additional waste 

 Identification of High-Level Waste (HLW), TRU vs. Low-Level Waste (LLW), Spent 

Nuclear Fuel (SNF) 

 AK source document sufficiency 

 Modifications to the Confirmatory Testing Plan (CTP) 

 Modifications to the Waste Stream Profile Form (WSPF) and Characterization 

Reconciliation Report (CRR) 

 Correlation and Surrogate Summary Form (CSSF) and Contact-Handled (CH)-RH 

correlation 

 Personnel training 

 Non-Conformance Reports (NCRs) and AK DRs 

 AK accuracy 

 Load management 

 Identification and attainment of Data Quality Objectives (DQOs)

Documents, Waste Containers and Batch Data Reports Provided

EPA evaluated the documentation that ANL-CCP had prepared to support the inclusion of 

approximately 30 55-gallon containers of K-Wing waste in Waste Stream AERHDM. Several 

attachments, source documents, required forms and other data were provided to EPA, and 

relevant sources were examined as part of this T1 inspection. Revision 5 of the AKSR (provided 

to EPA at the start of this review) did not satisfactorily support inclusion of K-Wing waste in 

Waste Stream AERHDM. Therefore, EPA based their evaluation and subsequent approval on the 
8 

draft AKSR, Revision 6, as provided by ANL-CCP representatives through Freeze File3

documentation. The listing of all documentation reviewed is in Attachment B, and the list of 

BDRs examined is presented in Table 3. 

Table 3. Batch Data Reports Examined 

Drum Number VE BDR Number DTC BDR Number 

RW18870 RHANLVE100004 RHANLDTC10005 

RW18871 RHANLVE100004 RHANLDTC10005 

RW18872 RHANLVE100004 RHANLDTC10005 

RW18873 RHANLVE100004 RHANLDTC10005 

RW18874 RHANLVE100004 RHANLDTC10005 

Technical Evaluation

To assess inclusion of approximately 30 55-gallon RH debris drums from the K-Wing based on 

their radiological and physical characteristics, EPA determined the following: how these data 

had been integrated, impacts of the information on the waste stream, changes to the radiological 

and physical characteristics of the waste and other elements that could affect pertinent 

characteristics of Waste Stream AERHDM. Results of the analysis are presented below. When 

information presented in the text is supported directly by one of the AK references, that reference 

is cited in parentheses. 

(1) The definition of Waste Stream AERHDM was examined with respect to the addition of 

the K-Wing wastes and found to be adequate. 

Waste Stream AERHDM is a debris waste stream generated by ANL in two locations – the alpha 

gamma hot cell facility (AGHCF) and the K-Wing4

. As part of the baseline, EPA evaluated this 

waste stream and concluded that the waste stream was adequately defined, but the waste stream 

did not at that time include K-Wing waste. After reviewing the modified documentation, EPA 

concluded that inclusion of K-Wing waste in Waste Stream AERHDM is adequately supported. 

K-Wing waste created from 1995–2007 as a result of hot cell activities is included in Waste 

Stream AERHDM, because most of the materials tested in the K-Wing hot cells originated as 

either samples prepared in the AGHCF or from the same commercial reactors. ANL sampled 

irradiated target material (corrosion studies and high-burnup characterization) and demonstration 

of Uranium Extraction (UREX) chemical separation processes in support of advanced nuclear 

fuel cycles. EPA evaluated an ANL-CCP-provided comparison of the accountable materials 

identified in the K-Wing inventory and the materials identified in AK source documents 

collected during the characterization of the original AGHCF waste materials (C2027, P2033), 

and concluded that adding K-Wing waste to the AERHDM waste stream is technically adequate. 

Additionally, since fuel pin residue samples generated during processing of samples from 

 

3

 Freeze File: As a result of EPA inspections, if CCP must revise documents to address EPA issues, CCP makes 

those changes and provides a copy to EPA as objective evidence for the changes made. These revisions are then 

processed by CCP’s document control process to generate an official version as the most current revision. 

4

 The AGHFC and the K-Wing Hot Cell Facility are distinct facilities located in the 200 Area of ANL that were used 

for similar purposes. 
9 

various reactors were transferred between the AGHCF and the K-Wing, those samples may have 

been contaminated/commingled with minor amounts of radiological materials from any fuels 

ever processed in the same area (P051, P330, P344, P515, P518, P519, P523, P551, P575, P802, 

P819, C812, C2006, C2027, U303, U304, U802, U1003, U2002, U2004). 

Based on the historical information concerning materials handled in the K-Wing and AGHCF, 

ANL-CCP concluded that the physical form and composition of the K-Wing debris wastes are 

similar to the AGHCF debris waste, and therefore eligible to be part of Waste Stream AERHDM. 

ANL-CCP personnel estimated waste material parameters (WMPs) based on documented 

historical operations and visual estimates of the waste inventory. See Item (3), below, for further 

discussion regarding physical composition of K-Wing debris waste. 

Even though the UREX process significantly impacted the radiological composition of the KWing debris, as indicated in CCP-AK-ANLE-501, Revision 2, Attachment A, the transfer of 

many common materials between the two areas and provision of common support activities 

between the K-Wing and AGHCF suggest that the debris waste generated from the K-Wing (as 

identified in CCP-AK-ANLE-501, Revision 2, Attachment A) has common physical and 

radiological characteristics and was generated by mutually supportive activities. Therefore, the 

modified AKSR and support documentation, as presented to EPA, as well as other contaminant 

transfer information, adequately support inclusion of K-Wing waste in Waste Stream AERHDM. 

 

(2) Radiological characteristics of the K-Wing waste were assessed with respect to their 

similarity to Waste Stream AERHDM and found to be adequate. 

The AKSR states that most of the sources and samples were moved into K-Wing following the 

1995 cleanout campaign, and these sources and samples are documented in the Chemical 

Technology Division (CMT) Nuclear Materials Inventory Database. Table 11 in the AKSR 

provides a list of the significant isotopes calculated in the fuels managed in K-Wing, as well as 

the total grams of each isotope estimated to be present in the K-Wing portion of the AERHDM 

waste stream, and provides evidence of the completeness of the AK record. 

ANL-CCP determined that the radiological signature imparted by the UREX processes would 

have a dominant impact on the radiological composition of debris removed from K-Wing. 

Further, it was determined that while radiological data are available for the various fuels (Table 

11 of the AKSR), the actual isotopic signature and related scaling factors for debris within the 

K-Wing A and B Cells could not be determined using these data and ORIGEN2.2 modeling 

because of the potential separation of cesium-137 (137Cs) during the UREX process. Therefore, 

ANL-CCP decided that the radiological composition of the debris must instead be determined 

through swipe sampling and analysis; Section 5.2 below presents EPA's evaluation of the swipe 

sampling and analysis. ANL-CCP compared the swipe sample analytical results for plutonium 

(Pu) isotopes against AK information specific to light water reactor (LWR) fuels (U896). This 

comparison showed that the swipe sample data and AK information for both the Pu isotopes and 

the uranium-235/238 (235/238U) ratios were in good agreement, thus indicating that the waste 

composition was dominated by LWR fuels used in the UREX process. Because 234U could not be 

measured and because the AK LWR data had been verified through sampling and analysis, 

ANL-CCP then used 234U information from LWR fuel AK data to develop scaling factors for this 
10 

isotope. These data indicate that the AK record is very useful and provides a good understanding 

of the radiological material in the K-Wing, and sampling and analysis verify radiological 

assumptions based on AK. 

(3) Physical characteristics of the K-Wing waste were assessed with respect to the physical 

characteristics of Waste Stream AERHDM and were found to be adequate. 

WMPs identified in the K-Wing waste materials include iron-based metals/alloys, aluminumbased metals/alloys, other metals, other inorganic materials, cellulosics, rubber and plastic (waste 

materials), which are the same WMPs previously identified for the AGHCF waste. ANL-CCP 

estimated a preliminary waste inventory for the K-Wing waste based on visual inspection of the 

K-Wing hot cells. WMP fractions were estimated based on observation and a review of 

documentation regarding historical operations in the K-Wing, and WMP weights were estimated 

based on observation and experience with similar debris in other locations. Based on the results 

of this evaluation, ANL-CCP concluded that the K-Wing debris waste is physically similar to the 

AGHCF debris waste, and that the WMP parameters published in the AKSR for the AGHCF 

debris waste are comparable and bounding. Source document C2010 presents the WMP 

assessment summarized in this section and states that the memo will be included in Attachment 6 

– Waste Form, WMPs, Prohibited Items and Packaging to support the physical waste description 

of Waste Stream AERHDM. 

ANL-CCP representatives indicated that all organic liquids presently in the K-Wing will be 

segregated and not included in Waste Stream AERHDM, and aqueous solutions found in the 

K-Wing will be neutralized and solidified prior to packaging and inclusion in Waste Stream 

AERHDM. Visual Examination (VE) will be performed at the time of packaging to confirm the 

absence of prohibited items.

(4) The AK summary and implementation of AK as required in Attachment A of the Waste 

Characterization Program Implementation Plan were evaluated and were found to be 

adequate. 

EPA examined Revision 5 of the AKSR and found that the document contained all the necessary 

pieces prescribed in Attachment A of the WCIP, but the waste stream was not defined well 

enough to support inclusion of the K-Wing waste. The EPA inspector raised the following two 

issues. 

Issue No. 1: The argument that K-Wing waste should be part of Waste Stream AERHDM 

needed to have better justification, taking into account the following points: 

a) The various components of the waste stream needed to be more clearly explained and 

supported as belonging to the same waste stream. 

b) Commonality of fuel pins and flow of materials between the AGHCF and K-Wing 

needed to be more clearly demonstrated. That is, the AKSR must show that the 

underlying radiological composition of the waste (excluding UREX) is common to KWing and AGHCF per the waste stream definition. 
11 

c) The UREX demonstrations have such a large influence on the radiological 

characterization of the K-Wing waste that a better counter argument is needed to 

explain why the K-Wing waste does not need to be its own waste stream. 

Issue No. 2: In several places throughout Revision 5 of the AKSR, an explanation is given 

that both the AGHCF and K-Wing handled fuel samples from the same nuclear reactor (for 

example, page 23, 2nd paragraph, page 26, 1st and 2nd paragraphs), but source document 

references are only provided for AGHCF. Additional references and/or a re-write of the 

sections to better incorporate the K-Wing waste needed to be provided. 

ANL-CCP AK personnel provided an additional source document (C2027) to EPA that addresses 

the majority of the points raised in the above two issues. Now the source document more clearly 

explained the relationship between AGHCF waste and K-Wing waste through a fuel-by-fuel 

comparison of the K-Wing inventory and the AK documentation collected for the 

characterization of the original AGHCF RH debris waste. The document also more clearly 

describes historic waste management practices in the K-Wing and AGHCF, including mention of 

historic waste commingling and procedures that had been in place, before being changed for 

reasons unrelated to the technical aspects of the waste, to transfer all K-Wing waste to the 

AGHCF for packaging. This information also explains that ANL-CCP considers that the UREX 

waste belongs in Waste Stream AERHDM because of the historic commingling and common 

fuel sources between the K-Wing and the AGHCF. See Item (1), above, for a full discussion of 

the waste stream definition. ANL-CCP also provided to EPA (and the AK record) a copy of the 

draft Revision 6 of the AKSR (U911) demonstrating how reference C2027 is to be incorporated 

into the document. This draft addresses both of the above EPA issues and satisfactorily supports 

inclusion of the K-Wing waste. 

EPA finds that the AKSR will be sufficient upon inclusion of the revisions as demonstrated in 

the draft Revision 6 that EPA reviewed, and expects a formal revision of the AKSR to be 

completed prior to the ANL-CCP’s 2011 1st quarter submission of T2 changes to EPA for review 

and concurrence. 

(5) Data traceability of K-Wing waste was examined and was found to be adequate. 

EPA examined traceability of AK data to understand the waste generation, packaging, 

processing, transfer and characterization processes up to and including that performed by ANLCCP. Data management in the Project Tracking System (PTS) data system used by ANL-CCP 

was also assessed, as well as presentation and general contents of the ANL-CCP waste 

characterization data. Also, availability of the data in the WIPP Waste Data System (WDS) was 

evaluated. 

The K-Wing waste is newly generated, so there are no original data packaging sheets or other 

generator documentation associated with individual drums. ANL-CCP indicated that prior to the 

submission of a T1 change request five drums were generated that underwent ANL-CCP’s VE 

and DTC characterization. EPA was provided the following two BDRs: 
12 

 A VE BDR (RHANLVE100004) that included five K-Wing drums—RW18870, 

RW18871, RW18872, RW18873 and RW18874. Examination of these data indicated that 

the drums contained many different debris items including, but not limited to, plywood 

disks, open plastic and glass bottles, plastic caps, plastic tubing, tape, stainless steel 

hardware and steel cans/cable, heating mantles, hose clamps, ceramic funnels, rubber 

stoppers, stainless steel fittings, plastic bags, glass labware, aluminum, brass, 

thermocouples, cameras, equipment, copper gaskets and paper. These items are generally 

consistent with the anticipated waste stream content presented in the AKSR. 

 A DTC BDR (ANLRHDTC10005) that included measurements for drums RW18870, 

RW18871, RW18872, RW18873 and RW18874. Documentation in the BDR included 

the container data and DTC conversion sheets for each drum. Examination of the BDR 

indicated that the radionuclide scaling factors presented on the conversion sheets were 

equivalent to those calculated by ANL-CCP as presented in Section 5.2 of this report, as 

well as in Table A4-1 of CCP-AK-ANLE-501, Revision 2, Appendix A. 

A copy of the Attachment 8 container list was provided; the list was dated 2007 and did not 

include the K-Wing wastes. However, the March 10, 2009, Add Container Memo that was 

appended to Attachment 8 requested inclusion of the five K-Wing drums in the waste stream. 

EPA expects that Attachment 8 will eventually be formally updated to include the K-Wing 

wastes and has identified a new T2 change to receive notification when the Attachment 8 

container list has been formally updated. 

ANL-CCP did not originally provide to EPA documentation pertaining to drum data as managed 

in the ANL-CCP PTS system. ANL-CCP also did not originally provide Site Project Manager 

(SPM) review documentation, or a CRR that addressed the K-Wing waste. Also, the five KWing drums mentioned above had not been entered into the WDS. EPA requested provision of a 

CRR that addressed the K-Wing waste, as well as modifications (change requests) to the WSPF 

addressing K-Wing and print-outs of each drum as currently documented in the PTS and AK 

Tracking Spreadsheet. ANL-CCP provided all of the requested information, except for the 

revised WSPF which will occur once the waste stream is approved by EPA and subsequently 

certified by CBFO; the CRR was provided in draft form solely for the purpose of EPA’s T1 

review. Provision of these data demonstrates that ANL-CCP is able to generate the required 

documentation for the K-Wing drums. 

 

(6) Defense Origin of K-Wing waste was assessed and found to be adequate. 

EPA previously evaluated and approved the defense waste determination of Waste Stream 

AERHDM for the AGHCF waste during the baseline inspection (No. EPA-ANL-CCP-RH-9.06-

8). Defense-related spent fuels managed in K-Wing after 1995 included those obtained from the 

EBR-II reactor, Hanford N reactor, Shippingport Light Water Breeder Reactor and Reduced 

Enrichment Research and Test Reactor Program (RERTR), which were also used in Yucca 

Mountain corrosion studies and high-burnup characterization studies (C006, C2004, C2007, 

U001). ANL-CCP representatives also indicate that due to the fact that the K-Wing continues to 

“store, manage, and utilize research materials... accumulated throughout the... operational 

history” and the impossibility of “separation of contamination from destructively examined 
13 

specimens,” all RH TRU debris waste from the K-Wing meets the WIPP requirement of defenserelated waste (C2027). 

(7) Identification of high-level waste, transuranic versus low-level waste, spent nuclear fuel 

with respect to K-Wing waste was assessed and found to be adequate 

According to the Nuclear Waste Policy Act (NWPA), spent nuclear fuel is fuel that has been 

withdrawn from a nuclear reactor following irradiation, the constituent elements of which have 

not been separated by reprocessing. DOE’s M 435.1-1, DOE Radioactive Waste Management 

Manual expands on this definition to clarify that test specimens of fissionable material irradiated 

for research and development only may be classified as waste. ANL-CCP determined that the 

wastes generated during deactivation, decommissioning and demolition activities of the K-Wing 

facility are contaminated with residual radiological contamination from various operations 

conducted from 1996 until 2007, and do not contain irradiated fuel elements withdrawn from a 

reactor. EPA inspected the K-Wing inventory documentation and agrees that the radiological 

materials managed in the K-Wing were primarily fuel samples and swarf, as indicated by the size 

of the material and the segment/sample ID record (U2004). ANL-CCP also states that the intact 

irradiated fuel pin test specimens were managed separately and are not included in the waste 

stream. As a result, the K-Wing waste material is not considered spent nuclear fuel. 

High-level waste is defined by the NWPA 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. ANL-CCP determined that the KWing waste does not contain spent nuclear fuel, so by definition the waste could not contain 

high-level waste. Also, while the K-Wing UREX process demonstrations included reprocessing 

research, by virtue of taking place within a hot cell, these R&D laboratory operations were not 

production operations involving the separation or reprocessing of constituent elements from 

reactor fuels; therefore, no high-level waste was generated (P2019, P2023, P2024). ANL-CCP 

concluded that the waste is not a spent nuclear fuel or high-level waste, and EPA believes the 

arguments presented are reasonable. Note that ANL-CCP is not including in Waste Stream 

AERHDM any of the vitrified samples of high-level waste or waste surrogates from West Valley 

and Savannah River Site used during Yucca Mountain corrosion studies and stored in the KWing, pending further evaluation. 

(8) Sufficiency of AK support documents and related document tracking with respect to the 

addition of K-Wing references was evaluated and was found to be adequate. 

An AK Source Document Reference List was prepared using unique identifiers for the different 

document types, following the format typically used by ANL-CCP for RH wastes. The listing is 

complete, and is easy to understand. ANL-CCP identified several references specific to K-Wing 

wastes; however, EPA identified several places in the AKSR where statements were made about 

the K-Wing without associated source documents to support the statements. EPA discussed this 

with ANL-CCP representatives, and an additional source document (C2027) was provided [see 

Items (1) and (4), above, for details]. ANL-CCP representatives also provided a draft Revision 6 
14 

of the AKSR to demonstrate that references to source document C2027 were added to the text, 

and the reference list at the back of the AKSR was updated accordingly (U911). Available 

information supports the overall inclusion of K-Wing waste into the existing AERHDM waste 

stream. EPA only examined the documentation specific to the technical elements discussed in the 

AKSR and not the individual source documents used by the AK Expert (AKE) to prepare the AK 

basis for the waste stream in question (see Attachment B for a list of reviewed references). 

(9) Modifications of the Waste Stream Profile Form and related Characterization 

Reconciliation Report were assessed and were found to be adequate. 

ANL-CCP representatives indicated that a revision to the WSPF has not yet been prepared, but 

did provide a draft revision of the CRR. EPA evaluated the draft CRR and found it to be 

adequate. As required in EPA’s baseline approval, revision of the WSPF and related attachments, 

including the CRR, is a T2 change, and EPA will receive notification of these changes when they 

are made. 

(10) Evaluation of the Certification Plan and Confirmatory Testing Plan was found to be 

satisfactory. 

RH sites must generate a Certification Plan that explains how RH waste characterization will 

take place at each site, as well as a CTP when this plan is required as part of AK Qualification. 

ANL-CCP provided a combined Certification Plan and CTP for EPA review, and EPA reviewed 

its compatibility with the Waste Characterization Program Implementation Plan (WCPIP) 

requirements. ANL-CCP’s characterization program for the K-Wing waste includes the use of 

sampling and analysis information in combination with DTC to quantify the WIPP-tracked 

radionuclides and VE during packaging to identify the physical WMPs. ANL-CCP stated that 

“[although] there is considerable detailed information on the composition and burnup of the fuel 

materials examined in all of the hot cells, the potential separation of the 137Cs in the UREX 

processing relative to the actinides and other insoluble radionuclides would make it virtually 

impossible to develop scaling factors based on ORIGEN2.2 analyses and modeling for the 

K-Wing hot cells. Therefore, to develop scaling factors a sampling campaign was performed.” 

Smear samples were collected and analyzed at the ANL Analytical Chemistry Laboratory 

(ACL). EPA observed the sampling and analysis process at ANL on February 16-17, 2010. 

Approval of this process is included in EPA Docket No. A-98-49; II-A4-130, dated August 2010. 

The sampling data were used, as detailed in Section 5.2 of this report, to develop radionuclide 

scaling factors applicable to the K-Wing waste. ANL-CCP compared the 235/238U ratio and the 

relative abundance of the Pu isotopes in the sampling results against AK data pertinent to LWR 

fuels. Both sets of values compared favorably, demonstrating that the LWR AK data can be 

verified by analytical data. Sampling data did not provide 234U isotopic information; however, 

the 234U AK data used to quantify this isotope was qualified by confirmatory testing. 

The above clarifies the characterization and qualification elements of the radiological 

characterization process; however, this has not been clearly presented in the CTP. Review of the 

CTP showed that all of the remaining required radiological characterization elements were 

adequately addressed. Based on the information above, EPA determined that ANL-CCP 
15 

adequately used a combination of approaches to characterize and, as necessary, qualify AK data 

as required in 40 CFR 194.24/22. 

(11) Use of a Correlation and Surrogate Summary Form was evaluated and it was determined 

to not apply to these wastes. 

Completion of a CSSF is required when AK information from a related CH waste stream is used 

in the RH waste characterization process. During Baseline Inspection No. EPA-ANL-CCP-RH9.06-8, an ANL-CCP representative indicated that CH data were not used in this manner. 

Inclusion of K-Wing debris waste in Waste Stream AERHDM also did not require completion of 

a CSSF. 

(12) Personnel training was evaluated and was found to be adequate. 

Training records for Kevin Peters (AKE), Steve Schafer (AKE) and Irene Quintana (SPM) were 

examined. Records were provided on July 21, 2010. It should be noted that the documentation 

examined did not indicate that ANL-CCP individuals are trained to EPA requirements, nor are 

they trained with respect to radiological characterization aspects, both of which are required in 

the WCPIP. Since the WCPIP is currently under revision, EPA will examine future training 

against the next version of the WCPIP. 

(13) Non-Conformance Reports and Discrepancy Resolution Forms were examined and were 

found to be adequate. 

EPA examined NCRs and DRs related to Waste Stream AERHDM during Baseline Inspection 

No. EPA-ANL-CCP-RH-9.06-8 and found the preparation of these documents to be adequate. 

No Non-Conformance Report (NCRs) are available for the K-Wing wastes as only five drums 

have been fully characterized at this time. One DR Form (DR023) addresses the change in the 

estimated volume of K-Wing debris waste. Based on this single DR, and NCRs and DRs 

evaluated during previous reviews, EPA expects that the process EPA evaluated in the past 

would be used to develop these documents when necessary. 

(14) AK accuracy was assessed and was found to be adequate. 

ANL-CCP revises its AK Accuracy Report annually. The last AK Accuracy Report was 

completed on May 13, 2010, but does not include evaluation of the AK accuracy for any K-Wing 

drums. EPA’s baseline approval includes changes or updates to the AK Accuracy Report as a T2 

change. Therefore, ANL-CCP/CBFO will automatically notify EPA when the next AK Accuracy 

Report specific to this waste stream is available. 

(15) Load Management was evaluated and it was determined to not apply to this waste stream. 

ANL-CCP representatives indicated that load management is not intended for Waste Stream 

AERHDM, and this will not change with inclusion of the K-Wing wastes that comprise this T1 

evaluation. EPA’s baseline inspection report indicated that the implementation of load 

management is a T1 change requiring EPA prior approval. 
16 

(16) Attainment of Data Quality Objectives was evaluated and found to be adequate. 

As a result of the analysis presented in Items 1-14, above, EPA was able to assess how each 

DQO will be addressed. The following DQOs must be addressed as per the WCPIP: 

 Defense determination 

 TRU waste determination 

 RH waste determination 

 Activity determination (total and activity per canister, including quantification and 

identification of the 10 EPA WIPP-tracked radionuclides) 

 Residual liquids 

 Physical form, including metals, cellulose, plastic and rubber 

As indicated in Item (9), above, the DQOs were addressed primarily through AK, DTC, Solid 

Sampling/Analysis and VE. When evaluated as a whole, CCP-AK-ANLE-500, Revision 5 and 

the draft Revision 6 prepared by ANL-CCP in July 2010, CCP-AK-ANLE-501, Revision 2, 

CCP-AK-ANLE-502, Revision 2, Draft A, and the reviewed supporting source documents, 

indicate that the DQOs, as specified in the WCPIP, have been met. 

Summary of Acceptable Knowledge

Findings or Concerns 

The EPA Inspection Team did not identify any findings or concerns relative to the inclusion of 

approximately 30 55-gallon containers of K-Wing debris waste during this T1 change evaluation. 

New Tier 2 AK Changes 

Based on the results of this T1 evaluation, there is one change to the AK T1 designations and 

four AK T2 changes. The T1 change requires EPA approval when containers added to an 

approved waste stream require different radionuclide scaling factors for radiological 

characterization. Four new AK T2 changes require the following: (1) EPA notification when 

additional containers characterized using the same scaling factors are added to the approved 

waste stream, (2) submission of a revised AKSR addressing addition of containers to the 

approved waste streams and supporting source documents, (3) submission of Attachment 4 of 

CCP-TP-005 is revised to include the updated AKSR Source Document Reference List, and (4) 

submission of Attachment 8 of CCP-TP-005 has been formally updated to reflect the additional 

containers. Accordingly, the AK portion of the tiering table is revised. Refer to the revised 

tiering table - Table 1 of the Executive Summary. 
17 

5.2 Radiological Characterization 

Radiological Characterization Element Description

The nature of RH TRU waste presents difficulties with respect to obtaining meaningful 

measurement data. RH radiological characterization relies on the development of radionuclide 

scaling factors that correlate an easily measured parameter like a waste container’s external 

exposure (dose) rate with isotopic distributions for specific TRU radionuclides. The development 

of radionuclide scaling factors for the ANL K-Wing RH TRU debris waste was based on the 

collection and analysis of smear samples. The development of the 137Cs-based scaling factors 

was supported by the following five sources of information: 

 Sampling Plan CCP-AK-ANL-505A: This plan was specifically developed for collecting 

samples from the debris waste in the K-Wing hot cells and describes the number of 

samples and location to collect the smear samples 

 Sampling BDR AERH1001: This BDR includes pertinent sample information, i.e., 

location, identification and collection dates and times 

 BDR 7TRUA50: The report summarizes the results of smear samples analysis 

(radionuclide measurements) conducted by the ANL ACL 

 Calculation package ANL-RH-08, K-Wing Debris Scaling Factor Development: The 

ExcelTM spreadsheet calculates the 137Cs-based scaling factors for specific radionuclides 

in each sample 

 Calculation package ANL-RH-13, Development of U-234 Scaling Factor for K-Wing 

Debris: The calculation package provides the scaling factor for 234U 

The characterization method used for the ANL K-Wing RH TRU debris waste was evaluated in 

terms of the technical adequacy as supported by the program’s documents, procedures and 

controls, and the knowledge and understanding of the personnel involved in the RH waste 

characterization program. During this T1 evaluation, EPA examined the following elements of 

the ANL-CCP radiological characterization program: 

 

 Development of DTC relationships as a function of waste density using MicroShieldTM

based on each drum’s measured external exposure (dose) rate, assuming the main 

contributor to the external exposure was 137Cs 

 Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked 

radionuclides, as supported by the sampling and the calculation packages 

Documents and Batch Data Reports Provided

EPA evaluated the documentation that ANL-CCP prepared to support the approval of the ANL 

K-Wing RH TRU debris waste. The list of all radiological characterization-related documents 

reviewed by EPA is included in Attachment B. 
18 

Technical Evaluation

The EPA inspection team evaluated the following aspects: 

(1) The technical adequacy and documentation supporting the development of scaling factors 

and identification of the types of fuel and general distribution of contaminants associated 

with this waste stream were evaluated and found to be adequate. 

The nature of the activities and operations conducted in the K-Wing hot cells was such that 

scaling factors could not be developed based on ORIGEN2.2 because of the UREX processing 

and the potential separation of 137Cs. ANL-CCP prepared a sampling Plan CCP-AK-ANL-505A 

for taking swipe samples of the K-Wing waste. EPA reviewed the adequacy of a sampling plan 

to determine if the sampling method and its implementation could result in the collection of a 

representative (statistically unbiased) sample from the debris waste suitable for radiochemical 

analysis. The minimum numbers of samples needed were less than the number of reported values 

by a factor of between two and three. There were no concerns regarding the technical adequacy 

of a sampling plan and documentation that EPA reviewed. EPA determined that the sampling 

plan and its implementation to obtain 19 smear samples from the ANL K-Wing RH TRU debris 

waste were technically adequate. EPA also reviewed the BDR AERH1001 and determined that 

the appropriate sample-related information was included. Specifically, the Attachment 1 from 

CCP-TP-512 contained: sample collection date; sample collection procedure number with 

current revision; sample identification number; sample matrix and container size; and the 

specific analyses that were requested. 

(2) The technical content and documentation of the resources used to determine the 

radionuclide contents of the representative samples collected were evaluated and found to 

be adequate. 

EPA evaluated ANL-CCP BDR 7TRUA50, which summarized the results of the analysis 

performed on the 19 collected samples by the ANL’s ACL. There were no concerns regarding 

the technical adequacy and documentation of the resources used for the identification of the 

types and general distribution of the contaminants relative to these ANL K-Wing RH TRU debris 

wastes. 

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

technically adequate and appropriately documented. 

A radionuclide scaling factor provides a technically sound method of deriving a value for 

radionuclides that are difficult to measure on the basis of an easily measurable attribute like 

external dose rate, assuming the measured dose rate can be correlated to a known constituent, 

i.e., the fission product 137Cs, the dominant contributor to the gamma dose rate for K-Wing RH 

TRU debris wastes. The measured dose rate in conjunction with the waste density and the DTC 

correlation leads to the determination of the concentration of 137Cs, and the activities of the 

reportable radionuclides, using their 137Cs-based scaling factors. 

The measurements of the radionuclide concentrations in the samples were used to develop the 

scaling factors. Except for 233U and 234U, which were treated differently, the scaling factors were 
19 

determined by dividing the total activity of each radionuclide by total 137Cs activity. The 

spreadsheet in the Calculation Package ANL-RH-08, K-Wing Debris Scaling Factor 

Development, was reviewed (U889) for a process followed when generating radionuclide scaling 

factors and was determined as technically adequate. 

The averaging procedure described above and in Calculation Package ANL-RH-08 (U889) could 

not be applied to 233U and 234U to determine their scaling factors. This was because only one 

sample had a reported measurement value for 233U and 234U was not measured in any of the 

samples analyzed. The scaling factor for 233U was determined, as an upper bound 

(conservative/overestimate) value, using the minimum detectable activity. 

The nearly exclusive UREX processing activities in the K-Wing hot cells (from 2003 to 2007) 

led to a particular method of determining the scaling factor for 234U. The method used was based 

on the assumption that the extensive UREX processing had resulted in a U distribution in the 

debris waste similar to what is present in the fuel processed (fuels from the Big Rock Point, 

Cooper and H.B. Robinson reactors). Based on this assumption, the scaling factor for 234U was 

determined as follows: 

(a) Determine the ratio 234/238U from the characterization data for LWR fuels in Calculation 

Package ANL-RH-13. It is noted again that this ratio was not available from the sample 

data, as 234U had not been measured in any of the samples collected. 

(b) Determine the 234U/137Cs scaling factor by multiplying the ratio found in Step (a) by the 

238U/137Cs ratio derived from the sample data.

The validity of the assumption made above (representativeness of the ratio 234/238U obtained from 

the AK record) was verified via comparing the 235/238U ratio from the sample data with the 

235/238U ratio from the AK record; they were 5.83E-02 and 7.51E-02, respectively. A second 

comparison involving Pu isotopes was also conducted, and it also confirmed the assumption (see 

Figure A4-1 in Appendix A, CCP-AK-ANLE-501, Revision 2). The Calculation Package ANLRH-13, Development of U-234 Scaling Factor for K-Wing Debris, was reviewed (U896) for a 

process followed when generating radionuclide scaling factors and was determined as technically 

adequate. 

 

Figure 1 below, which is Figure A 2-1 of Appendix A of the Technical Report CCP-AK-ANLE501, Revision 2, depicts the flow diagram of the characterization process for K-Wing RH TRU 

debris waste at ANL. 
20 

Figure 1. Flow Diagram Depicting the Characterization Process for the K-Wing RH TRU 

Debris Waste at ANL
21 

A single set of 137Cs-based scaling factors was determined for the characterization of K-Wing 

RH TRU debris waste at ANL. The scaling factors are shown in Table 4, below.

Table 4. Scaling Factors for the K-Wing RH TRU Debris Waste at ANL 

 in Units of Curies of Specific Radionuclide/Curies 137Cs (Ci/Ci 137Cs)

Radionuclide 137Cs Scaling Factor 233U 5.57E-5 234U 1.45E-05 235U 2.62E-07 238U 4.48E-06 238Pu 5.61E-02 

239Pu 5.90E-03 240Pu 8.63E-03 241Pu 4.03E-01 242Pu 3.56E-05 241Am 4.55E-02 244Cm 1.52E-02 137Cs 1.00E+00 137mBa 9.46E-01 

90Sr 8.40E-01 

90Y 8.40E-01 

EPA evaluated the following aspects: 

 Activity values derived from modeling and statistical metrics, namely mean and standard 

deviation values for each measured 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 are correlated to the radionuclide whose physical half-lives 

possibly contribute to the measured external dose rate, i.e., 137Cs 

 Contributions of the short-lived radionuclides to the total measured dose rate 

 Appropriate decay correction according to ANL-CCP procedure (CCP-TP-504) of all 

radionuclide values for purposes of model development and routine assays performed via 

DTC 

 The calculated results used to develop the scaling factors and convert the measured 

external dose rates obtained via DTC to radionuclide activity levels 

 Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides 

[

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, americium-241 (241Am), 137Cs and 

strontium-90 (90Sr)] 
22 

 The determination of the contribution of all radionuclides to the radiological hazard5 

 Shielding and other calculations supporting the scaling factors performed using 

MicroShieldTM and MCNP5 to derive the appropriate DTC relationships as a function of 

waste density for the geometry appropriate to the K-Wing RH TRU debris waste at ANL 

following repackaging (55-gallon drum)6

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

factors for the K-Wing RH TRU debris waste at ANL. 

(4) The technical basis of the Dose-To-Curie correlation and its documentation were 

evaluated and found to be unchanged from what EPA had inspected and approved 

previously, and both aspects were acceptable. 

The DTC correlation was based on the following assumptions: 

 The waste drum 100 percent full with waste 

 The radionuclides of interest dispersed uniformly throughout the waste 

 The waste matrix’s density to be unity (one), because photon attenuation is more 

influenced by material density, as opposed to specific composition or atomic number 

 Waste densities range from 0.2 g/cm3 to 1.8 g/cm3

Using MicroShieldTM, ANL-CCP developed a DTC correlation for a 55-gallon drum filled with 

RH TRU waste in terms of millirem per hour for a 1-Ci source of 137Cs. Figure A5-2 in CCPAK-ANLE-501, Revision 2 shows a plot of dose rate as a function of waste density at a distance 

of 1 meter for 137Cs. A DTC spreadsheet similar to the DTC spreadsheet that EPA evaluated 

during the baseline inspection is used for K-Wing RH TRU debris waste at ANL as well, 

involving the debris waste scaling factors. The spreadsheet contained the required information, 

specifically: cask identification number, container gross weight, estimated fill percentage and 

results of the four dose rate measurements that are obtained via the application of DTC 

procedure CCP-TP-504. An example Waste Drum DTC Conversion Record (spreadsheet) is 

included as Figure A5-3 in CCP-AK-ANLE-501, Revision 2. There were no concerns regarding 

the technical basis of the DTC correlation and its documentation for the K-Wing RH TRU debris 

waste at ANL. 

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

evaluated and found to be acceptable. 

Attachment A to CCP-AK-ANLE-501, Revision 2 is the main document that describes the 

radiological characterization process that ANL-CCP used for the K-Wing RH TRU debris waste 

at ANL. This attachment is supported by a series of calculation packages that were reviewed in 

 

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. 

6

 MicroShieldTM is a commercial computer code used for shielding analyses. MCNP5 is Monte Carlo N-Particle 

Transport Code that has been developed by Los Alamos National Laboratory. 
23 

the process of evaluating the K-Wing RH TRU debris waste at ANL, listed in Attachment A. 

These packages had been prepared and reviewed by several ANL-CCP radiological 

characterization team members who supported the ANL-CCP RH baseline effort. These 

packages documented the following for the K-Wing RH TRU debris waste at ANL: 

 Scaling factor development 

 Determination of reportable radionuclide 

 DTC correlation for 137Cs 

 Uncertainty analysis 

 DTC spreadsheet 

 Development of 234U scaling factor DTC spreadsheet 

The EPA evaluation team reviewed these packages and Appendix A to CCP-AK-ANLE-501, 

Revision 2 and found that they adequately document the radiological characterization process for 

K-Wing RH TRU debris waste at ANL. The calculation packages cited above adequately support 

the activities upon which the radiological characterization of the K-Wing RH TRU debris waste 

at ANL is based. There were no issues related to the documentation of technical aspects of the 

radiological characterization approach for the K-Wing RH TRU debris waste at ANL-CCP. 

(6) The technical basis and derivation of Total Scaling Factor Uncertainty were evaluated 

and were found to be adequate. 

The development of Total Scaling Factor Uncertainty (TSFU) for the K-Wing RH TRU debris 

waste at ANL, which belongs to the Waste Stream AERHDM, is based on the propagation of 

uncertainties present in all aspects of the determination of the radiological constituents of RH 

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

quadrature. The TSFU determination included contributions of the following: 

 137Cs activity measurement 

- Measurement uncertainty 

- Dose contribution of other gamma-emitting radionuclides 

 137Cs DTC correlation 

- Waste density determination 

- Drum weight measurement 

- Tare weight determination 

- Estimated fill percentage 

- MicroShieldTM modeling uncertainties (function of waste density) 

- MicroShieldTM code uncertainties 

 Scaling factor uncertainty 

- Sample data measurement uncertainty 

- Uncertainty in the mean scaling factor derived from the sample data 

- Drum-to-drum variations in the scaling factors 

 

The treatment of TSFU is presented in Appendix A to CCP-AK-ANLE-501, Revision 2 and 

Calculation Package No. ANL-RH-11. The principal contributors to the uncertainty in the total 

137Cs-based scaling factors are the uncertainty in mean scaling factors and the drum-to-drum 
24 

uncertainty, the latter being the main contributor. The main contributors to the overall (total) 

uncertainty are 137Cs activity uncertainty and the TSFU, as indicated in Table 5 below. 

Table 5. Final Scaling Factor Uncertainty Listed by Radionuclide 

for K-Wing RH TRU Debris Waste at ANL

Radionuclide 

Cs-137 Activity 

Uncertainty 

Drum-to-Drum 

Uncertainty 

Total 

Uncertainty 233U 34.2% 103.2% 108.7% 234U 34.2% 33.0% 47.5% 235U 34.2% 28.0% 44.2% 238U 34.2% 29.0% 44.8% 238Pu 34.2% 30.3% 45.6% 

239Pu 34.2% 20.2% 39.7% 240Pu 34.2% 26.8% 43.4% 241Pu 34.2% 28.0% 44.2% 242Pu 34.2% 45.0% 56.5% 241Am 34.2% 28.6% 44.6% 244Cm 34.2% 26.8% 43.4% 

90Sr 34.2% 33.5% 47.8% 137Cs 34.2% 0.0% 34.2% 

There were no concerns regarding the technical derivation and documentation of TSFU for the 

K-Wing RH TRU debris waste at ANL. 

(7) RH and TRU determinations were assessed and were found to be adequate. 

The determination that the RH containers meet the definition of TRU waste and RH waste was 

examined during the baseline inspection. Both of these aspects are directly involved with the 

DTC measurement conducted at ANL, as was observed during the baseline inspection. These 

were not assessed directly during this T1 evaluation, but EPA did verify that no aspects of these 

two determinations had changed. There were no technical or documentation-related concerns 

regarding the TRU and RH determinations for K-Wing RH TRU debris waste at ANL. 

Summary of Radiological Characterization

Findings or Concerns 

The EPA Inspection Team did not identify any findings or concerns relative to the radiological 

characterization of approximately 30 55-gallon containers of K-Wing debris waste during this T1 

change evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the T1 designations and two 

T2 changes for radiological characterization. The two T2 changes added to the radiological 

characterization portion of the tiering table are (1) requiring notification regarding the 
25 

availability of a revised radiological characterization technical report associated with the addition 

of containers of K-Wing waste to the approved waste stream (AERHDM), and (2) providing 

radiological BDRs for additional containers as discussed below. 

If additional containers for this waste stream are generated and will be characterized using the 

same scaling factors as those used for the containers approved as part of this T1 change request, 

then the following information for radiological characterization is necessary. Upon 

characterizing a sufficient number of containers from this population to generate 1-2 BDRs, 

ANL-CCP must provide the list of characterized containers and an updated radiological 

characterization report. From this list, EPA may select a few containers for detailed review to 

verify that the additional containers belong to the approved waste stream. However, if the 

containers require new or different radionuclide scaling factors, the additional containers will be 

subjected to EPA’s T1 evaluation and approval prior to disposal at WIPP. 

6.0 SUMMARY OF RESULTS 

Findings and Concerns 

The EPA Inspection Team did not identify any findings or concerns relative to the inclusion of 

approximately 30 55-gallon containers of K-Wing debris waste to Waste Stream AERHDM 

during this T1 change evaluation. 

Tiering Changes

EPA revised the tiering table to modify one T1 change under AK and add four T2 changes under 

AK, two T2 changes under radiological characterization and one T2 change under VE as 

follows: 

 One AK T1 change is modified pertaining to the addition of containers to an approved 

waste stream when new scaling factors are used for their characterization 

 Four AK T2 changes requiring EPA notification when (1) additional containers 

characterized using the same scaling factors are added to the approved waste stream, (2) a 

revised AKSR addressing addition of containers to the approved waste stream and 

supporting source documents are complete, (3) Attachment 4 of CCP-TP-005 is 

generated to reflect the updated AKSR Source Document Reference List, and (4) 

Attachment 8 of CCP-TP-005 is formally updated to reflect the additional containers 

 Two radiological characterization T2 changes requiring notification when a revised 

radiological characterization report associated with the addition of containers to the 

approved waste stream and providing radiological BDRs for these containers 

 One VE T2 change requiring the submission of the appropriate BDRs for the population 

of waste containers that are being added to the approved waste stream 

Addition of containers to the approved waste stream:
26 

In the future, when ANL-CCP characterizes the remaining 45+ containers of the K-Wing waste 

to add to the approved waste stream AERHDM, no T1 change request for approval is necessary 

if ANL-CCP can demonstrate the following: 

 The additional containers have the same pedigree as the approved waste stream; and 

 The radionuclide scaling factors used for the RH waste stream are technically appropriate 

for use in the DTC determination of the radiological characterization of the additional 

containers 

In addition, ANL-CCP must: 

1. Notify EPA concerning the approximate number of additional containers and the 

approximate additional volume of waste. 

2. Provide the timeframe for waste generation, characterization and disposal. 

3. Submit to EPA, upon characterizing a sufficient number of containers to generate 1-2 

BDRs, the following: 

a. the list of characterized containers 

b. a revised AKSR and supporting source documents 

c. an updated radiological characterization report 

4. Inform EPA if any other waste characterization documents have been changed. 

From the list mentioned in #3 above, EPA may select a few containers for a detailed review 

to verify that the additional containers belong to the approved waste stream and are 

adequately characterized to demonstrate regulatory compliance. 

The ANL-CCP’s compliance with the above conditions is necessary when adding containers to 

an approved waste stream AERHDM. When adding containers to an approved waste stream, 

however, if different or new scaling factors are necessary it is a T1 change requiring EPA 

approval. 

7.0 CONCLUSIONS 

During this T1 change evaluation, EPA examined the inclusion of approximately 30 55-gallon 

containers of K-Wing debris wastes to Waste Stream AERHDM. Based on the results of this 

evaluation, EPA is approving inclusion of approximately 30 55-gallon containers of K-Wing 

debris wastes to Waste Stream AERHDM with the limitations discussed above. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION 

PROGRAM 

ANL-CCP RH Approvals Date EPA Docket Number 

ANL RH Baseline Approval January 2007 A-98-49; II-A4-73 

Tier 1 Change – Approval of WIPP Waste Information System January 2007 A-98-49; II-A4-74 

Tier 1 Change – Approval of Visual Examination for Newly 

Generated Waste June 2008 A-98-49; II-A4-102 

Approval of 100 additional drums of AGHCF debris waste to Waste 

Stream AERHDM October 2008 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

CCP-AK-ANLE-500 Central Characterization Project Acceptable Knowledge Summary Report 

For Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM, Revision 5, January 14, 

2010 

CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste 

From Argonne National Laboratory-East, Revision 2, May 10, 2010 

CCP-AK-ANLE-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, 

Revision 2, Draft A, 2010 

CCP-AK-ANL-505A, Central Characterization Project Sampling and Analysis Plan for Argonne 

Remote Handled Debris Waste, Waste Stream AERHDM, Revision 0, December 9, 2009 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, New Mexico, Washington 

TRU Solutions, LLC 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, Waste Stream AERHDM, August 8, 2007 

CCP-TP-512, Revision 3, Attachment 7, CCP Remote-Handled Waste Sampling Attachment 7 - 

Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist BDR 

No. 7, TRUA50, May 14, 2010 

Inter-Office Correspondence from I.S. Quintana to CCP Records Custodian, RE: Transmittal of 

Waste Stream Profile Form, Attachment 4, for Remote-Handled Waste Stream AEHRDM at the 

Argonne National Laboratory, July 23, 2008 

Inter-Office Correspondence, from C.M. Gomez to M. Sensibaugh, Acceptable Knowledge 

Accuracy Report, Argonne National Laboratory, Waste Stream Number AERHDM, Lots 1-5, 

May 13, 2010 

Memorandum to Hillari Neeley and Irene Quintana, CCP SPMs, from Kevin Peters, CCP AKE, 

RE: Addition of 10 Containers to Waste Stream AERHDM, March 10, 2009 

Memorandum to Hillari Neeley, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 2 

Containers to Waste Stream AERHDM, March 10, 2010 

Memorandum to Hillari Neeley, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 5 

Containers to Waste Stream AERHDM, March 22, 2010 
B-2 

Memorandum to Hillari Neeley and Irene Quintana, CCP SPMs, from Kevin Peters, CCP AKE 

RE: Addition of 15 Containers to Waste Stream AERHDM, April 16, 2009 

Memorandum to Irene Quintana, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 6 

Containers to Waste Stream AERHDM, May 20, 2008 

Memorandum to Hillari Neeley and Irene Quintana, CCP SPM, from Kevin Peters, CCP AKE, 

RE: Addition of 2 Containers to Waste Stream AERHDM, Date: June 27, 2008 

Memorandum to Hillari Neeley and Irene Quintana, CCP SPMs, from Kevin Peters, CCP AKE, 

RE: Addition of 9 Containers to Waste Stream AERHDM, September 14, 2009 

RH Tiering of TRU Waste Characterization Processes Implemented by CCP at ANL (Based on 

EPA Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8) DOCKET # A-98-49; II-A4-73, 

August 2008 

C006, Interview with Larry Neimark re: AGHCF samples, applicable programs, defense 

relationship to materials and commingling of waste, ROC-C6, Cheryl Schultz, July 17, 2001 

C812, Memo from T. S. Bray & R. V. Strain to M. Goldberg, Characterization of N-Reactor Fuel 

Samples, T. S. Bray, R. V. Strain, October 4, 2000. 

C2004, Safety Review for Unsaturated Testing of Uranium Metal Spent Fuel in Bldg. 205 Senior 

Cave and K-116 Facilities, CMT50-0 US-Draft, R.D. Wolson, March 7, 2009 

C2006, Work Plan for the Preparation of Unirradiated Al-clad Specimens for CMT, 

IPS-329-00-00, T.S. Bray, December 2, 1999 

C2007, Work Plan for the Preparation of Specimens from the Characterization of Pins UW02010 

(A/G 498A) and UW08036 (A/G 498B), IPS-284-00-00, L.A.Neimark, June 17, 1998 

C2010, Evaluation of the Physical Waste Composition for K-Wing Waste in Waste Stream 

AERHDM, C. Chancellor, September 24, 2009 

C2027, Waste Stream Delineation Evaluation for Waste Stream AERHDM to Include K-Wing 

Waste, K. Peters, July 14, 2010 

DR023, Waste Stream AERHDM Volume Projection Corrections, K. J. Peters, June 23, 2010. 

P051, AGHCF Operations Manual: 11.0 Waste Management, IPS-2-00-00, October 23, 1996. 

P330, Work Plan for the Characterization and Sectioning of H. B. Robinson Rod R01 (A/G 615) 

and Surry Rod H7 (A/G 593) for the Sandia HEDD Project Memo to IPS Document File, IPS433-00-00, Hanchung Tsai, ET-IPS, October 14, 2003 
B-3 

P344, Analysis of Spent Nuclear Fuel Sample A/G 574B2 (Limerick Reactor) to Determine 

Selected Isotopes and Estimate Fuel Burnup, N/A, D.G. Graczyk, April 2003 

P515, Work Plan for Determining Hydrogen Contents in TMI-1 Cladding Memo to IPS 

Document File, IPS-331-00-00 and IPS-331-00-01, Hanchung Tsai, IPS-ET, October 20, 1999 

and February 3, 2000 

P518, Work Plan for the Steam Oxidation Tests at 1200 degrees on Unirradiated Zry-4 and 

Irradiated TMI-1 Cladding Memo to NRC Program File Several Supplemental Instructions, IPS335-00-00 and IPS-335-01-00, Y. Yan, February 11, 2000 

P523, Work Plan for CMT Samples from TMI Fuel Rod Segments Memo to Distribution, IPS342-00-00, R. V. Strain, January 31, 2000 

P551, Work Plan for the Examination of Fuel Plates from the RERTR-4 Experiment in ATR; 

Work Plan for Cutting H. B. Robinson Rod Sections and Loading into Shipping Tubes and 

Supplemental Instruction 153, IPS-375-00-00, -01-00, IPS-376-00-00, R. V. Strain, March 16, 

2001, April 12, 2001 and March 26, 2001 

P575, Work Plan for the Examination of Fuel Plates from the RERTR-4 Experiment in ATR, 

Revision 1, IPS-400-01-00, R. V. Strain, February 22, 2002 

P802, Extended Burnup Demonstration, Reactor Fuel Program, Pre-Irradiation Characterization 

and Summary of Pre-Program Poolside Examinations, Big Rock Point Extended Burnup Fuel, 

XN-NF-80-40; UC-78; DOE/ET/34006-3, C. A. Exarhos, L.F. Van Swam, F.P. Wahlquist, 

December 1981 

P819, IPS-306-00-00, Work Plan for the Characterization of N-Reactor Fuel Specimens (A/G 

562), IPS-306-00-00, T. Bray, March 09, 1999 

P2019, Test Plan for the Characterization of an Approved Testing Material Mixed Oxide Fuel 

Source Document Reference Information, Lawrence A. Neimark, SNF-3A-004, Revision 0, 

April 8, 1998 

P2023, Attachment 3: Results of the UREX+2 Spent Fuel Demonstration (OUO), D. Bowers, 

et.al., February 28, 2005 

P2024, Attachment 3: Results of the UREX+1a Spent Fuel Demonstration (OUO), C. Pereira, 

et.al., March 31, 2006 

P2033, Revised Estimate of the Radioactive Inventory in the AGHCF, NOD-155-00-00, R.J. 

Page, January 7, 2009 

U001, AGHCF Position Statement Regarding Defense Versus Non-Defense TRU Waste, April 

7, 2000 
B-4 

U303, Notes for Correction of Fissile Ledger Database Regarding H. B. Robinson Fuel 

Shipment, T. Bray, April 17, 2004 

U304, Robinson Report, Unknown Dates 

U802, SPM Logbook Information for A/G 249, ANL ID 46232, Various Dates 

U889, CCP Calculation Package – Cs-137 Scaling Factor Development, Revision 0, ANLE-RH08, Jene Vance, April 15, 2010 

U890, CCP Calculation Package – Determination of Reportable Radionuclides, Revision 0, 

ANLE-RH-09, Jene Vance, June 14, 2010 

U891, CCP Calculation Package – ANL K-Wing Debris Cs-137 DTC Correlation, Revision 0, 

ANLE-RH-10, Jene Vance, May 04, 2010 

U894, CCP Calculation Package – Uncertainty Analysis for K-Wing Debris, Revision 0, ANLERH-11, Jene Vance, May 04, 2010 

U895, CCP Calculation Package – DTC Spreadsheet K-Wing Debris, Revision 0, ANLE-RH-12, 

Jene Vance, April 04, 2010 

U896, CCP Calculation Package – Development of U-234 Scaling Factor, ANLE-RH-13, Jene 

Vance, May 04, 2010 

U1003, Argonne Special Material Receipt and Transfer Documentation by A/G Number, 

Various Authors, 1964–1997 

U2002, CMT Nuclear Materials Inventory Database – detail report with ratios and FGEs, L.E. 

Maggos, July 21, 2009 

U2004, Material in K-Wing 07-29-09 Spreadsheet, L.E. Maggos, February 11, 2009 

U2010, Contactor Cleaning Procedure, S. Aase, R. Leonard, August 19, 2003