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 NAT IONAL LABORATORY

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Federal Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

September 2010i 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 Evaluationii 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 R econciliation 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/cm 3 grams per cubic centimeter

LWR light water reactor(s)

MCNP5 Monte Carlo N-Particle Transport Code

NCR Non-Conformance Reportiii ORIGEN Oak Ridge Isotopic Generation Computer Program

PTS Project Tracking System

Pu plutonium

RERTR Reduced Enrichment Res earch 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 Charact erization Program Implementation Plan

WDS Waste Data System

WIPP Waste Isolation Pilot Plant

WMP Waste Material Parameter

WSPF Waste Stream Profile Form

Y yttrium1 1.0 EXECUTIVE SUMMARY

This report supports the U.S. E nvironmental 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 Charact erization Project (CCP ). Specifically, this approval is for the addition of 30 55-gallon containers 1 of debris waste from the K-Wing in Building 205 to Waste Stream AERHDM.

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

of Waste Stream AERHDM at the Waste Isolat ion Pilot Plant (WIPP). This baseline approval applied to 45 2 containers of legacy RH debris wast e 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 Offi ce (CBFO) requested EPA approval of a T1 change to include approximately 30 55-gallon co ntainers of K-Wing debris wastes in Waste

Stream AERHDM. Because there were no new e quipment or processes on site at ANL, EPA conducted a desktop review of this change, c oncluding that the ANL-CCP has used the EPAapproved systems of controls to characterize th e additional 30 RH debr is containers from KWing to the Waste Stream AERHDM (See Secti on 5.0 for details). ANL-CCP estimates that there are, however, approximately 75 55-gallon c ontainers that would be generated from the KWing activity. The systems of controls evaluated as pa rt of this review con tinue 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 St ream AERHDM, no T1 change reque st 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) determina tion of the radiologica l 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; ho wever, documentation from ANL-CCP indicates that the original waste stream contained 44 dr ums. 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, characte rization 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 characte rization documents have been changed.

From the list mentioned in #3 above, EPA may sel ect a few containers fo r a detailed review to verify that the additional cont ainers belong to the approved wa ste stream and are adequately characterized to demonstrate regulatory compliance.

The ANL-CCP’s compliance with the above conditi ons is necessary when adding containers to the approved Waste Stream AE RHDM. When adding containers to an approved waste stream, however, if different or new sca ling factors are used, the T1 ch ange approval is necessary.

EPA has revised the original tie ring table to add the modified T1 change and the above-listed conditions as Tier 2 (T2) cha nges, 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 a ccordance with 40 CFR 194.8(b)(3).3Table 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 CharacterizationProcess ElementsANL-CCP RH Waste Characterization Process –T1 ChangesANL-CCP RH Waste Characterization Process –T2 ChangesAcceptable Knowledge (AK)Any new waste streams not approved under this baselineModification of the approvedWaste Stream AERHDM toinclude additional containers beyond the approximately 45included in CCP-AK-ANLE-500, Revision 1,if new ordifferent radionuclide scaling factors are requiredSubstantive modification(s) that have the potential to affectthe characterization process to CCP-AK-ANLE-500,CCP-AK-ANLE-501 orCCP-AK-ANLE-502Implementation of load management for any RH wastestreamNotification to EPA that the final DTC determination is completefor RH containers in the approved waste streamNotification to EPA when updates are made to AK documentationas a result of WCPIP revisionsNotification that updates have been completed to the followingdocuments:All future revisions of CCP-ANLE-AK-500,CCP-ANLE-AK-501Listing of the references that document the assembly of fuelpin data and review processAll future revisions of CCP-ANLE-AK-502CCP-AK-ANLE-500 and CCP-AK-ANLE-502 to addressfreeze file changesNotification to EPA that the data package for this debris wastestream is completed, including any modifications to the WSPFincluding the CRR and AK SummaryNotification to EPA when AK accuracy reports are completed,prepared annually at a minimumNotification to EPA when additional containers are added toRH TRU Waste Stream AERHDMand the containers werecharacterized using the same radionuclide scaling factors*Notification to EPA of availability of a revised AKSR andsource documents supporting theaddition of containers to theapproved waste stream*Notification to EPA when Attachment 4 of CCP-TP-005 isgenerated to reflect the updated AKSR Source DocumentReference ListNotification to EPA when Attachment 8 of CCP-TP-005 hasbeen formally updated4Table 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 CharacterizationProcess ElementsANL-CCP RH Waste Characterization Process –T1 ChangesANL-CCP RH Waste Characterization Process –T2 ChangesRadiological Characterization, includingDose-To-Curie (DTC)Use of any alternate radiological characterization procedureother than DTC with established scaling factors asdocumented in CCP-TP-504 and CCP-AK-ANLE-501,Revision 0, respectively, or substantive modification thereofAny new waste stream not approved under this baseline oraddition of containers to Waste Stream AERHDM thatrequire changing the established radionuclide scaling factorsApplication of new scaling factors for isotopic determinationother than those documented in CCP-AK-ANLE-501Notification to EPA that revisions of CCP-AK-ANLE-501 or CCPTP-504 that require CBFO approval are completeNotification to EPA of availability of a revised radiologicalcharacterization report, if generated when containers are addedto the approved waste stream*Radiological content data provided in BDRs for the populationof additional containers*Visual Examination (VE) VE by reviewing existing audio/visual recordings forsummary waste category not covered by this approvalVE by any new process for S5000 debris wastesNotification to EPA that revisions of any VE procedure that requireCBFO approval are completeAddition of new S5000 debris waste streamsPhysical content data providedin BDRs for the population ofadditional containers*Real-time Radiography (RTR) Any use of RTR requires EPA approval NoneWIPP Waste Data System (WDS) None Changes madeto WDS procedure(s) that require CBFO approvalNotes:-This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 orT2 element is discussed.-ANL-CCP will report all T2 changes to EPA quarterly.-Notification to EPA is not necessary when document updates areeditorial in nature or are required to address administrative concerns.-Substantive modificationrefers to a change with the potential toaffect ANL-CCP’s RH waste characterization process, e.g., the use of an inherently different type ofmeasurement instrument or the use of the high-range probe as described in CCP-TP-504 for radiological characterization.-Additions to the original tiering table asa result of this T1 evaluation appear inbold.*These marked changes apply when containers are added to Waste Stream AERHDM and are characterized using the same radionucliudescaling factors as were used tocharacterize the original approved waste stream. EPA notification is required when thesite identifies the need to characterizeadditional containers belonging to the approvedwaste 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 ba seline 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 demonstr ation that the program’s components, with applicable conditions and limitati ons, 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 ve rify that the site’s system of controls is technically adequate and properly implemented.

Following the EPA’s approval of waste characteri zation processes evaluated during the baseline inspection, EPA is authorized to evaluate and approve, if necessary, ch anges 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 ch aracterize the waste and remain s in compliance with all the regulatory requirements. Based on the adequacies of the waste characterization processes demonstrated during the baseline inspecti on, including all conditions and limitations, EPA specified which subsequent waste characteriza tion 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 as pect of the ANL-CCP’s characterization program. T1 activities have more stringent reporting requirements a nd 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 evalua tion of T1 changes to include approximately 30 55-gallon containers of RH TRU debris K-Wing waste (see Section 5.0, be low in Waste Stream AERHDM, as described in CCP -AK-ANLE-500, Revision 5 and Di screpancy 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 previ ously, 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 wa s 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 el ements. 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 in corporate new containers and not the addition of a new Summary Category Group or waste stre am, an inspection checklist was not used.

This approval is limited to th e addition of approximately 30 55- gallon containers of K-Wing RH TRU debris waste. If the remaining approxima tely 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 ta ble (see Table 1 above) apply. EP A approval is necessary when any other RH waste stream generated at ANL whic h is not an approved debris waste stream is characterized for the disposal at the WIPP.

EPA examined the acceptable knowledge (AK) a nd 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 St ream AERHDM. Personnel who participated in the T1 evaluation are listed in Table 2, along wi th 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 Evaluato r – Acceptable Knowledge, SC&A

Kira Darlow Technical Evaluato r – 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 Characteriza tion Subject Matter Expert, ANL-CCP7 5.0 TECHNICAL EVALUATION OF THE ADDI TION OF 30 DRUMS OF K-WING

DEBRIS WASTE

5.1 Acceptable Knowledge

EPA examined the AK process and associated in formation to determine whether the ANL-CCP waste characterization program demonstrated co mpliance with the requirements of 40 CFR 194.8 for the addition of approximately 30 K-Wing contai ners of RH TRU debris waste to ANL Waste

Stream AERHDM.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with resp ect to the use of AK for waste characterization as impacted by th e addition of ne w 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 Confir matory Testing Plan (CTP)

 Modifications to the Waste Stream Pr ofile 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 a nd Batch Data Reports Provided

EPA evaluated the documentation that ANL-CCP had prepared to suppor t the inclusion of approximately 30 55-gallon containers of K-Wi ng 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 sati sfactorily support inclus ion of K-Wing waste in Waste Stream AERHDM. Therefore, EPA based th eir evaluation and subs equent approval on the8 draft AKSR, Revision 6, as provided by ANL-CCP representatives through Freeze File 3
documentation. The listing of all doc umentation 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-gall on 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 c ould 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 debr is waste stream generated by ANL in two locations – the alpha gamma hot cell facility (AGHCF) and the K-Wing 4 . 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 AE RHDM 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 characteriza tion) and demonstration of Uranium Extraction (UREX) ch emical separation processes in support of advanced nuclear fuel cycles. EPA evaluated an ANL-CCP-provi ded comparison of the accountable materials identified in the K-Wing inventory and the materials identified in AK source documents collected during the character ization of the original AGHC F 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 mu st revise documents to address EPA issues, CCP makes those changes and provides a copy to EPA as objective ev idence 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 transf erred between the AGHCF and the K-Wing, those samples may have been contaminated/commingled with minor amo unts 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 concerni ng 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 comp osition 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 suppor tive activities. Therefore, the modified AKSR and support documen tation, as presented to EPA, as well as other contaminant transfer information, adequately support inclusion of K-Wing wa ste in Waste Stream AERHDM.

(2) Radiological characteristics of the K-Wing waste were assessed with respect to their similarity to Waste Stream AE RHDM and found to be adequate.

The AKSR states that most of the sources a nd 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 significan t isotopes calculated in the fuel s 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 determin ed using these data and ORIGEN2.2 modeling because of the potential separation of cesium-137 ( 137 Cs) during the UREX process. Therefore,

ANL-CCP decided that the radiol ogical 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 sw ipe 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 ( 235/238 U) ratios were in good agreement, thus indicating that the waste composition was dominated by LWR fuels used in the UREX process. Because 234 U could not be

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

ANL-CCP then used 234 U information from LWR fuel AK data to develop scaling factors for this10 isotope. These data indicate th at the AK record is very usef ul and provides a good understanding of the radiological material in the K-Wing, a nd 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 AER HDM 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, r ubber and plastic (waste materials), which are the same WMPs previous ly 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 estima ted based on observati on and a review of documentation regarding historical operations in the K-Wing, and WMP we ights were estimated based on observation and experience with similar debris in other locations. Based on the results of this evaluation, ANL-CCP concl uded that the K-Wing debris wast e is physically similar to the AGHCF debris waste, and that the WMP para meters 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 It ems and Packaging to support the physical waste description

of Waste Stream AERHDM.

ANL-CCP representatives indicated that all or ganic 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 prio r to packaging and inclusion in Waste Stream AERHDM. Visual Examination (VE) will be perfor med 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 cont ained all the necessary pieces prescribed in Attachment A of the WC IP, but the waste stream was not defined well enough to support inclusion of th e 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 ju stification, 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 demonstrate d. 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 argume nt 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, 2 nd paragraph, page 26, 1 st and 2 nd paragraphs), but source document references are only provided for AGHCF. Additi onal 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 s ource document (C2027) to EPA that addresses the majority of the points raised in the above tw o issues. Now the source document more clearly explained the relationship between AGHCF wast e 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 de bris waste. The document also more clearly describes historic waste manage ment practices in the K-Wing a nd AGHCF, including mention of historic waste commingling and procedures that had been in place, before being changed for

reasons unrelated to the technica l aspects of the waste, to transfer all K-Wing waste to the AGHCF for packaging. This information also expl ains that ANL-CCP cons iders that the UREX waste belongs in Waste Stream AERHDM becau se 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 prov ided to EPA (and the AK record) a copy of the draft Revision 6 of the AKSR (U911) demonstrati ng how reference C2027 is to be incorporated

into the document. This draft a ddresses both of the above EPA i ssues 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 e xpects a formal revision of the AKSR to be completed prior to the ANL-CCP’s 2011 1 st 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 charac terization 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 a nd 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 ar e no original data pack aging sheets or other generator documentation associated with individual drums. ANL-CCP indicated that prior to the submission of a T1 change request five drum s 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 cl amps, 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 st ream content presented in the AKSR.

 A DTC BDR (ANLRHDTC10005) that included measurem ents for drums RW18870, RW18871, RW18872, RW18873 and RW18874. Docume ntation in the BDR included

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

indicated that the radionuclid e 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 wa s 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 docum entation 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 addr essed the K-Wing waste. Also, the five KWing drums mentioned above had not been entere d into the WDS. EPA re quested provision of a CRR that addressed the K-Wing wast e, 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 pr ovided in draft form solely for the purpose of EPA’s T1

review. Provision of these data demonstrates that ANL-CCP is ab le 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 de fense waste determination of Waste Stream AERHDM for the AGHCF waste during the ba seline inspection (N o. 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, Shippingpor t 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 mate rials... accumulated throughout the... operational history” and the impossibility of “separation of contamination from destructively examined13specimens,” all RH TRU debris waste from the K-Wing meets the WIPP requirement of defenserelated waste (C2027).

(7) Identification of high-level wast e, transuranic versus low-leve l 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 irradi ation, the constituent el ements of which have not been separated by reprocessing. DOE’s M 435.1-1, DOE Radioactive Waste Management

Manual expands on this definition to cl arify that test specimens of fissionable material irradiated for research and development only may be classi fied as waste. ANL-CCP determined that the wastes generated during deactivation, decomm issioning and demolition activities of the K-Wing facility are contaminat ed with residual radiological c ontamination from various operations conducted from 1996 until 2007, and do not contain irra diated fuel elements withdrawn from a reactor. EPA inspected the K-Wing inventory do cumentation and agrees that the radiological materials managed in the K-Wing were primarily fu el samples and swarf, as indicated by the size of the material and the segment/s ample ID record (U2004). ANL-CCP also states that the intact irradiated fuel pin test specime ns were managed separately an d are not included in the waste stream. As a result, the K-Wing waste materi al is not considered spent nuclear fuel.

High-level waste is defined by the NWPA as the highly radioactive materi al resulting from the reprocessing of spent nuclear fu el, including liquid waste produced directly in reprocessing and any solid material derived from such liquid wast e that contains fission products in sufficient concentrations, and other highly radioactive material that th e Commission, consistent with existing law, determines by rule requires perman ent isolation. ANL-CCP de termined 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 pr ocess demonstrations in cluded reprocessing research, by virtue of taking place within a ho t cell, these R&D laborat ory operations were not production operations involving th e separation or reprocessing of constituent elements from reactor fuels; therefore, no high-level wa ste was generated (P2019, P2023, P2024). ANL-CCP concluded that the waste is not a spent nuclear fuel or high-level wast e, 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-leve l waste or waste surrogates from West Valley and Savannah River Site used during Yucca Mount ain corrosion studies and stored in the KWing, pending further evaluation.

(8) Sufficiency of AK support documents and rela ted document tracking with respect to the addition of K-Wing references was eval uated and was found to be adequate.

An AK Source Document Reference List was prepar ed using unique identifi ers 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 iden tified 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 additi onal source document (C2027) was provided [see Items (1) and (4), above, for details]. ANL-CCP representatives also pr ovided a draft Revision 614 of the AKSR to demonstrate that references to source document C2027 were added to the text,

and the reference list at the back of th e 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 specifi c to the technical elements discussed in the

AKSR and not the individual source documents us ed by the AK Expert (AKE) to prepare the AK basis for the waste stream in question (see Atta chment B for a list of reviewed references).

(9) Modifications of the Waste Stream Prof ile Form and related Characterization Reconciliation Report were assessed and were found to be adequate.

ANL-CCP representatives indicated that a revision to the WSPF ha s not yet been prepared, but did provide a draft revision of the CRR. EP A 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 re ceive notification of these changes when they

are made.

(10) Evaluation of the Certification Plan and C onfirmatory Testing Plan was found to be satisfactory.

RH sites must generate a Certification Plan th at 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 Ce rtification Plan and CTP for EPA review, and EPA reviewed its compatibility with the Waste Characteriz ation Program Implementation Plan (WCPIP) requirements. ANL-CCP’s characterization prog ram for the K-Wing waste includes the use of sampling and analysis information in combin ation with DTC to quantify the WIPP-tracked radionuclides and VE during packaging to iden tify the physical WMPs. ANL-CCP stated that “[although] there is considerable detailed info rmation on the composition and burnup of the fuel materials examined in all of the hot cells, the potential separation of the 137 Cs in the UREX processing relative to the actin ides and other insoluble radio nuclides would make it virtually impossible to develop scaling factors base d on ORIGEN2.2 analyses and modeling for the K-Wing hot cells. Therefore, to develop scali ng factors a sampling campaign was performed.” Smear samples were collected and analyzed at the ANL Analytical Chemistry Laboratory (ACL). EPA observed the sampling and anal ysis 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 Sec tion 5.2 of this report, to develop radionuclide scaling factors applicable to the K-Wing waste. ANL-CCP compared the 235/238 U 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 favorab ly, demonstrating that the LWR AK data can be verified by analytical data. Sampling data did not provide 234 U isotopic information; however,

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

The above clarifies the charac terization and qualification el ements of the radiological characterization process; however, this has not been clearly presen ted in the CTP. Review of the CTP showed that all of the remaining require d radiological characterization elements were adequately addressed. Based on the information above, EPA determined that ANL-CCP15 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 informa tion from a related CH waste stream is used in the RH waste characterization process. During Baseline Inspect ion 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 Stre am 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, 201 0. It should be noted that the documentation

examined did not indicate that ANL-CCP individua ls are trained to EPA requirements, nor are they trained with respect to radiological character ization aspects, both of which are required in the WCPIP. Since the WCPIP is currently unde r revision, EPA will examine future training against the next version of the WCPIP.

(13) Non-Conformance Reports and Discrepancy Re solution Forms were examined and were found to be adequate.

EPA examined NCRs and DRs related to Wast e Stream AERHDM during Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 and found the prepara tion 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. On e 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 th ese documents when necessary.

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

ANL-CCP revises its AK Accuracy Report a nnually. The last AK Accuracy Report was completed on May 13, 2010, but does not include ev aluation of the AK accuracy for any K-Wing drums. EPA’s baseline approval in cludes 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 wast e stream is available.

(15) Load Management was evaluated and it was dete rmined 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 inclusi on of the K-Wing wastes that comprise this T1 evaluation. EPA’s baseline insp ection 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 mu st 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 we re 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 th e 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, ther e 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 ra dionuclide scaling factor s for radiological characterization. Four new AK T2 changes requ ire the following: (1) EPA notification when

additional containers characteri zed using the same scaling fact ors 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 docu ments, (3) submission of Attachment 4 of

CCP-TP-005 is revised to incl ude the updated AKSR Source Docu ment Reference List, and (4)

submission of Attachment 8 of CCP-TP-005 has b een 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 pr esents difficulties with resp ect to obtaining meaningful measurement data. RH radiological characteriza tion relies on the development of radionuclide scaling factors that correlate an easily measur ed parameter like a waste container’s external exposure (dose) rate with isot opic distributions for specific TR U 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 137 Cs-based scaling factors was supported by the following fi ve sources of information:

 Sampling Plan CCP-AK-ANL-505A: This plan was specifically developed for collecting samples from the debris waste in the K-Wi ng hot cells and describes the number of samples and location to collect the smear samples

 Sampling BDR AERH1001: This BDR include s pertinent sample information, i.e., location, identification and co llection dates and times

 BDR 7TRUA50: The report summarizes th e results of smear samples analysis (radionuclide measurements) conducted by the ANL ACL

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

Excel TM spreadsheet calculates the 137 Cs-based scaling factors fo r 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 234 U

The characterization method used for the ANL K- Wing RH TRU debris waste was evaluated in terms of the technical adequacy as supporte d by the program’s documents, procedures and controls, and the knowledge and understanding of th e personnel involved in the RH waste characterization program. During this T1 evalua tion, EPA examined the following elements of the ANL-CCP radiological characterization program:

 Development of DTC relationships as a f unction of waste density using MicroShield TM

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

contributor to the ex ternal exposure was 137 Cs

 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 ge neral distribution of c ontaminants associated

with this waste stream were ev aluated and found to be adequate.

The nature of the activities and operations condu cted 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 137 Cs. ANL-CCP prepared a sampling Plan CCP-AK-ANL-505A for taking swipe samples of the K-Wing waste. EP A reviewed the adequacy of a sampling plan to determine if the sampling method and its impl ementation could result in the collection of a representative (statistic ally unbiased) sample from the debris waste suitable for radiochemical analysis. The minimum numbers of samples needed were less than the numb er 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 EP A 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 re viewed the BDR AERH1001 and determined that the appropriate sample-related information wa s included. Specifically, th e 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 sa mples 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 AN L’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 contaminan ts 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 tech nically 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 137 Cs, the dominant contributor to the gamma dose rate for K-Wing RH

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

correlation leads to the determination of the concentration of 137 Cs, and the activities of the reportable radionuclides, using their 137 Cs-based scaling factors.

The measurements of the radionuclide concentrati ons in the samples were used to develop the scaling factors. Except for 233 U and 234 U, which were treated differen tly, the scaling factors were19 determined by dividing the total ac tivity of each radionuclide by total 137 Cs activity. The spreadsheet in the Calculation Package ANL-RH-08, K-Wing Debris Scaling Factor Development , was reviewed (U889) for a process follo wed when generating radionuclide scaling factors and was determined as technically adequate.

The averaging procedure described above and in Calculation Packag e ANL-RH-08 (U889) could not be applied to 233 U and 234 U to determine their scaling factors. This was because only one sample had a reported measurement value for 233 U and 234 U was not measured in any of the samples analyzed. The scaling factor for 233 U was determined, as an upper bound (conservative/overestimate) value, us ing the minimum detectable activity.

The nearly exclusive UREX pr ocessing activities in the K-Wi ng hot cells (from 2003 to 2007) led to a particular method of de termining the scaling factor for 234 U. The method used was based on the assumption that the extensive UREX proce ssing 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 234 U was

determined as follows:

(a) Determine the ratio 234/238 U 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 234 U had not been measured in any of the samples collected.

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

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

The validity of the assumption made a bove (representativeness of the ratio 234/238 U obtained from the AK record) was verified via comparing the 235/238 U ratio from the sample data with the

235/238 U ratio from the AK record ; they were 5.83E-02 and 7.51E-02, respectively. A second comparison involving Pu isotopes was also conducte d, 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 scal ing factors and was determined as technically adequate.

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

debris waste at ANL.20 Figure 1. Flow Diagram Depicting the Characte rization Process for the K-Wing RH TRU

Debris Waste at ANL21 A single set of 137 Cs-based scaling factors was determin ed for the characterization of K-Wing

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

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

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

Radionuclide 137 Cs Scaling Factor

233 U 5.57E-5

234 U 1.45E-05

235 U 2.62E-07

238 U 4.48E-06

238 Pu 5.61E-02

239 Pu 5.90E-03

240 Pu 8.63E-03

241 Pu 4.03E-01

242 Pu 3.56E-05

241 Am 4.55E-02

244 Cm 1.52E-02

137 Cs 1.00E+00

137m Ba 9.46E-01

90 Sr 8.40E-01

90 Y 8.40E-01

EPA evaluated the following aspects:

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

deviation values for each measured radionuclide

 The appropriateness of the choice of physic al constants and radionuclide-specific attributes (specific activity, phys ical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technica l correctness of the values assigned to each

attribute

 Isotopic activity values are correlated to the radionuclid e whose physical half-lives possibly contribute to the meas ured external dose rate, i.e., 137 Cs

 Contributions of the short-lived radionuc lides 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 de velopment and routine assays performed via

DTC

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

external dose rates obtained via DT C to radionuclide activity levels

 Activity and uncertainty values determin ed for the ten WIPP-Tracked radionuclides
[ 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, americium-241 ( 241 Am), 137 Cs and strontium-90 ( 90 Sr)]22  The determination of the contribution of a ll radionuclides to the radiological hazard 5

 Shielding and other calculat ions supporting the scali ng factors performed using

MicroShield TM 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 rela ted to the technical ad equacy or documentation of radionuclide scaling factors for the K-Wing RH TRU debris waste at ANL.

(4) The technical basis of the Dose-To-Cu rie correlation and its documentation were evaluated and found to be unchanged from what EPA had inspected and approved previously, and both asp ects were acceptable.

The DTC correlation was based on the following assumptions:

 The waste drum 100 percent full with waste

 The radionuclides of interest disp ersed 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/cm 3 to 1.8 g/cm 3

Using MicroShield TM , 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 137 Cs. 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 137 Cs. A DTC spreadsheet similar to the DTC spreadsheet that EPA evaluated during the baseline inspection is used for K- Wing RH TRU debris wa ste at ANL as well, involving the debris waste scali ng factors. The spreadsheet cont ained 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 th e 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, Re vision 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 docu mentation 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 th at were reviewed in

5 Although the determination of a wast e container’s radiological hazard is not an EPA requi rement, this information may be useful in understanding other aspects of a container’s radiological characterization.

6 MicroShieldTM is a commercial computer code used fo r 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 re viewed by several ANL -CCP radiological characterization team members who supporte d the ANL-CCP RH baseline effort. These packages documented the following for th e K-Wing RH TRU debris waste at ANL:

 Scaling factor development

 Determination of reportable radionuclide

 DTC correlation for 137 Cs

 Uncertainty analysis

 DTC spreadsheet

 Development of 234 U scaling factor DTC spreadsheet

The EPA evaluation team revi ewed these packages and Appendix A to CCP-AK-ANLE-501, Revision 2 and found that they adequately docume nt the radiological char acterization process for K-Wing RH TRU debris waste at ANL. The calcu lation packages cited above adequately support the activities upon which the radiol ogical characterization of th e K-Wing RH TRU debris waste

at ANL is based. There were no issues related to the documentation of te chnical aspects of the radiological characterization a pproach for the K-Wing RH TR U debris waste at ANL-CCP.

(6) The technical basis and derivation of Tota l Scaling Factor Uncertainty were evaluated and were found to be adequate.

The development of Total Scaling Factor Unce rtainty (TSFU) for the K-Wing RH TRU debris waste at ANL, which belongs to the Waste St ream AERHDM, is based on the propagation of uncertainties present in all aspects of the determ ination of the radiologica l constituents of RH TRU waste. These aspects are assumed to be in dependent, which allows them to be added in quadrature. The TSFU determination in cluded contributions of the following:

 137 Cs activity measurement

- Measurement uncertainty

- Dose contribution of other gamma-emitting radionuclides

 137 Cs DTC correlation

- Waste density determination

- Drum weight measurement

- Tare weight determination

- Estimated fill percentage

- MicroShield TM modeling uncertainties (function of waste density)

- MicroShield TM code uncertainties

 Scaling factor uncertainty

- Sample data measurement uncertainty

- Uncertainty in the mean scaling fact or 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-AN LE-501, Revision 2 and Calculation Package No. ANL-RH-11. The principal contributors to the uncertainty in the total

137 Cs-based scaling factors are the uncertainty in mean scaling factors and the drum-to-drum24 uncertainty, the latter being the main contributor. The main cont ributors to the overall (total) uncertainty are 137 Cs 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

233 U 34.2% 103.2% 108.7%

234 U 34.2% 33.0% 47.5%

235 U 34.2% 28.0% 44.2%

238 U 34.2% 29.0% 44.8%

238 Pu 34.2% 30.3% 45.6%

239 Pu 34.2% 20.2% 39.7%

240 Pu 34.2% 26.8% 43.4%

241 Pu 34.2% 28.0% 44.2%

242 Pu 34.2% 45.0% 56.5%

241 Am 34.2% 28.6% 44.6%

244 Cm 34.2% 26.8% 43.4%

90 Sr 34.2% 33.5% 47.8%

137 Cs 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 insp ection. Both of these aspects ar e directly involved with the DTC measurement conducted at ANL, as was obs erved during the baselin e inspection. These were not assessed directly during this T1 evalua tion, 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 findi ngs or concerns relati ve to the radiological characterization of approximately 30 55-gallon cont ainers of K-Wing debris waste during this T1 change evaluation.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 designations and two T2 changes for radiological characterization. Th e two T2 changes added to the radiological characterization portion of the tiering table are (1) requiri ng notification regarding the25 availability of a revised radiol ogical characterization technical re port associated with the addition of containers of K-Wing wast e 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 containe rs approved as part of this T1 change request, then the following information for radiolog ical 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 characte rized containers and an updated radiological characterization report. From this list, EPA may select a few cont ainers for detailed review to verify that the additional cont ainers belong to the approved wa ste stream. However, if the containers require new or different radionuclide s caling 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-Wi ng 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 char acterization and one T2 change under VE as

follows:

 One AK T1 change is modified pertaining to the addition of contai ners to an approved waste stream when new scaling factor s 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 contai ners 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 S ource Document Reference List, and (4) Attachment 8 of CCP-TP-005 is formally upda ted to reflect the additional containers

 Two radiological characterization T2 cha nges requiring notification when a revised radiological characterization re port associated with the addi tion of containers to the approved waste stream and providing radi ological 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 st ream AERHDM, no T1 change reque st 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 radi ological characterizat ion 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, characte rization 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 characte rization documents have been changed.

From the list mentioned in #3 above, EPA may se lect 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 conditi ons is necessary when adding containers to an approved waste stream AERHDM. When addi ng containers to an approved waste stream, however, if different or new s caling 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 appr oximately 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 2008B-1 

### ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION

CCP-AK-ANLE-500 Central Characterization Proj ect 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 T echnical Report for Remote-Handled Transuranic Debris Waste From Argonne National Laborator y-East, Revision 2, May 10, 2010

CCP-AK-ANLE-502, Central Characterization Projec t 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 Proj ect Sampling and Analysis Plan for Argonne Remote Handled Debris Waste, Waste St ream 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 Knowle dge Documentation, Attachment 8 – Waste Containers List, Waste St ream AERHDM, August 8, 2007

CCP-TP-512, Revision 3, Attachment 7, CCP Remo te-Handled Waste Sampling Attachment 7 - Site Project Manager Radiochemi stry 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. Gom ez to M. Sensibaugh, Acceptable Knowledge Accuracy Report, Argonne National Laborator y, Waste Stream Number AERHDM, Lots 1-5, May 13, 2010

Memorandum to Hillari Neeley and Irene Quinta na, 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 Stre am AERHDM, March 10, 2010

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

Containers to Waste Stre am AERHDM, March 22, 2010B-2 Memorandum to Hillari Neeley and Irene Quin tana, 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 Quinta na, CCP SPM, from Kevin Peters, CCP AKE,

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

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

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

RH Tiering of TRU Waste Char acterization 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, Characteriza tion 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 Prep aration of Unirradiated Al-clad Specimens for CMT, IPS-329-00-00, T.S. Bray, December 2, 1999

C2007, Work Plan for the Prepar ation 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 Comp osition 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 Projecti on 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 Character ization and Sectioning of H. B. Robinson Rod R01 (A/G 615) and Surry Rod H7 (A/G 593) for the Sandia HE DD Project Memo to I PS Document File, IPS433-00-00, Hanchung Tsai, ET -IPS, October 14, 2003B-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 C ontents 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 Test s 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 Fu el Rod Segments Memo to Distribution, IPS342-00-00, R. V. Strain, January 31, 2000

P551, Work Plan for the Examination of Fuel Pl ates from the RERTR-4 Experiment in ATR; Work Plan for Cutting H. B. Robinson Rod S ections 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 Pl ates from the RERTR-4 Experiment in ATR, Revision 1, IPS-400-01-00, R. V. Strain, February 22, 2002

P802, Extended Burnup Demonstration, Reactor Fu el Program, Pre-Irradiation Characterization and Summary of Pre-Program Poolside Examin ations, Big Rock Point Extended Burnup Fuel, XN-NF-80-40; UC-78; DOE/ET/34006-3, C. A. Ex arhos, L.F. Van Swam, F.P. Wahlquist,

December 1981

P819, IPS-306-00-00, Work Plan for the Characteri zation 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, La wrence A. Neimark, SNF-3A-004, Revision 0, April 8, 1998

P2023, Attachment 3: Results of the UREX+2 Spent Fuel Dem onstration (OUO), D. Bowers, et.al., February 28, 2005

P2024, Attachment 3: Results of the UREX+1a Spent Fuel Dem onstration (OUO), C. Pereira, et.al., March 31, 2006

P2033, Revised Estimate of the Radioactive Inventory in the AGH CF, NOD-155-00-00, R.J. Page, January 7, 2009

U001, AGHCF Position Statement Regarding Defe nse Versus Non-Defense TRU Waste, April 7, 2000B-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 Scalin g Factor Development, Revision 0, ANLE-RH08, Jene Vance, April 15, 2010

U890, CCP Calculation Package – Determinatio n 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 An alysis for K-Wing Debris, Revision 0, ANLERH-11, Jene Vance, May 04, 2010

U895, CCP Calculation Package – DTC Spreadsh eet 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 Documenta tion by A/G Number, Various Authors, 1964–1997

U2002, CMT Nuclear Materials Inve ntory Database – detail report with ratios and FGEs, L.E. Maggos, July 21, 2009

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

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