EPA DOCKET NO: A-98-49, II-A4-137 

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

AT THE IDAHO NATIONAL LABORATORY: 

ADDITION OF WASTE STREAM ID-RTC-S3000 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

November 2010
i

TABLE OF CONTENTS 

Section Page

Acronyms ........................................................................................................................................ ii

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

2.0 Purpose of Tier 1 Evaluation ...............................................................................................4

3.0 Purpose of This Report ........................................................................................................4

4.0 Scope of the Tier 1 Evaluation.............................................................................................4

5.0 Evaluation of New Waste Stream ID-RTC-S3000 ..............................................................5

5.1 Acceptable Knowledge ............................................................................................6

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

6.0 Summary of Results ...........................................................................................................23

7.0 Conclusions ........................................................................................................................24

ATTACHMENTS 

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

Characterization Program 

Attachment B: Listing of Documents Reviewed for This Evaluation 
ii

ACRONYMS 

AK acceptable knowledge 

AKE acceptable knowledge expert 

AKSR acceptable knowledge summary report 

Am americium 

ANL Argonne National Laboratory 

BDR batch data report 

CBFO Carlsbad Area Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations 

CH contact-handled 

Ci curie 

Co cobalt 

CRR Characterization Reconciliation Report 

Cs cesium 

CSSF Correlation and Surrogate Summary Form 

CTP Confirmatory Test Plan 

CTS Catch Tank System 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 

DTC dose-to-curie 

EDF engineering design file 

EPA U.S. Environmental Protection Agency 

Eu europium 

FGE fissile gram equivalent 

g/cm3

 grams per cubic centimeter 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

HWS Hot Waste System 

ICP inductively coupled plasma 

ICP-MS inductively coupled plasma - mass spectrometry 
iii

ID Idaho 

INEEL Idaho National Environmental and Engineering Laboratory 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

ITR Independent Technical Review 

IWTS Integrated Waste Tracking System 

LWA Land Withdrawal Act 

MFC Materials and Fuel Complex 

MFP mixed fission products 

mR/h milliRoentgen per hour 

MTR Materials Test Reactor 

nCi/g nanocurie per gram 

NCR non-conformance report 

NDA nondestructive assay 

NRF Naval Reactors Facility 

NWPA Nuclear Waste Policy Act 

ORIGEN Oak Ridge Isotope Generation 

pdf portable document format 

PE Ci Pu equivalent curies 

PTS Project Tracking System 

Pu plutonium 

QA quality assurance 

Rem Roentgen Equivalent Man 

R&D research and development 

RCRA Resource Conservation and Recovery Act 

RH remote-handled 

RML Radiation Measurements Laboratory 

RPD relative percent difference 

RTC Reactor Technology Complex 

RTR real-time radiography 

SAP Sampling and Analysis Plan 

SNF spent nuclear fuel 

SPM Site Project Manager 
iv

Sr strontium 

STR submarine thermal reactor 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRA Test Reactor Area 

TRU transuranic 

U uranium 

U.S. United States 

VE visual examination 

VCO voluntary consent order 

WC waste characterization 

WCPIP Waste Characterization Program Implementation Program 

WDS Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WSPF Waste Stream Profile Form 

WWIS WIPP Waste Information System 

Y yttrium 
1

1.0 EXECUTIVE SUMMARY 

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

additional remote-handled (RH) transuranic (TRU) sludge (S3000) waste stream from the 

Department of Energy’s (DOE) Idaho National Laboratory (INL). Specifically, this approval 

supports the addition of Waste Stream ID-RTC-S3000.

On February 8, 2010, the Carlsbad Field Office (CBFO) requested that EPA review a proposed 

Tier 1 (T1) change approving the above waste stream. The Central Characterization Project 

(CCP) is responsible for characterizing RH wastes at INL using the system of controls, which 

EPA evaluated during the baseline inspection conducted in July 2006 and approved in January 

2007. A summary of EPA’s approvals of the INL-CCP RH TRU waste characterization program 

is included as Attachment A. Because there were no new equipment or processes changes on site 

at INL to examine, EPA conducted a desktop review of this change in August – September 2010. 

Section 5.0 of this report presents the results of the T1 evaluation to add Waste Stream ID-RTCS3000. EPA did not identify any findings or concerns during this evaluation. No open issues 

remain relative to this change. EPA did not identify any new T1 or Tier 2 (T2) changes during 

the course of this evaluation. Table 1 below identifies tiering changes that are applicable to the 

RH waste at INL. EPA determines that the EPA-approved procedures and processes used by 

INL-CCP for characterization of Waste Stream ID-RTC-S3000 are adequate. EPA, therefore, 

approves the addition of four 55-gallon containers1

 from Waste Stream ID-RTC-S3000 to INLCCP’s RH baseline approval as a T1 change. The T1 approval of any additional RH sludge waste 

streams, requires EPA approval. Also, CBFO and INL-CCP are required to submit a T1 change 

request and receive EPA approval prior to disposal at the Waste Isolation Pilot Plant (WIPP) of 

any additional containers belonging to ID-RTC-S3000 that were characterized using a different 

radiological characterization process and/or with different scaling factors. The addition of 

containers with the same pedigree and characterized using the same radiological characterization 

process and scaling factors as the approved waste stream, is a T2 change, as shown in Table 1 

below. Minor grammatical changes were made to this table to better summarize the previous 

INL-CCP RH approvals. 

 

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

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

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised N

RH Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH P

Acceptable Knowledge (AK) Addition of containers to approved waste streams if new or 

different radionuclide scaling factors or a different radiological characterization process are required Any new RH waste streams not approved to date Substantive modification(s) that have the potential to affect the 

characterization process: CCP-AK-INL-500, CCP-AK-INL501, or CCP-AK-INL-502 Load management for any RH waste stream 

Notification to EPA when upda

(AKSRs), Radiological Charac

Test Plans (e.g., CCP-AK-INLAK-INL-502) are approved by 

Notification to EPA when chan

of Waste Characterization Prog

revisions have been made (e.g.

Reports (CRRs))

Notification to EPA when a Co

Form is completed for each of stream identified as contact-handose rates that present nondestrassayed containers 

Notification to EPA once waste 

waste stream and any modificaForm (WSPF), including the C

Notification to EPA that the fin

determination is complete for Ridentified in AK Reference P03AK accuracy reports (prepared 

Notification to EPA when addi

TRU debris or sludge waste strand the containers were characscaling factors* 

Notification to EPA of availabi

documents supporting the additwaste streams* 

Notification to EPA when Atta

generated to reflect the updated List 

Notification of availability of apertinent to Waste Stream IN-I

Radiological Characterization, including DTC Application of new scaling factors for isotopic determination 

other than those documented in CCP-AK-INL-501 

Notification to EPA upon comp

501 or CCP-TP-504 that requir
3

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised N

RH Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH P

Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP-504 or substantive modification of the DTC 

procedure 

Use of any alternate gamma detector with the OSPREYTM system characterization procedure other than the La3Br(Ce) detector observed in July 2010

Any new RH waste stream not approved to date or the addition of containers to an approved waste stream that requires changing the established radionuclide scaling factors or radiological characterization process 

Notification to EPA of availabi

characterization report, if requithe approved waste streams* Radiological content data provthe population of additional con

Visual Examination (VE) VE using audio/video media to characterize additional debris 

or sludge waste streams other than those approved to date 

Notification to EPA upon compprocedure(s) that require CBFO 

Physical content data provided additional containers* 

Real-Time Radiography (RTR) Any new RH debris or sludge waste stream not approved to 

date 

Notification to EPA prior to addition of a new RTR unit(s) 

Notification to EPA upon comp

procedure(s) that require CBFO 

Physical content data provided 

additional containers* 

WIPP Waste Data System (WDS) (previously known as WWIS) 

None Changes made to WDS proced

Notes: 

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

- INL-CCP will report all T2 changes to EPA every three months. - 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 INL-CCP’s RH waste characterization process, e.g., the use of an inher

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

* These marked T2 changes apply when containers are added to any approved INL RH debris and sludge waste streams and are characterized u

factors or radiological characterization process as were used to characterize the original approved waste stream. Unlike the other T2 change suEPA notification is required when the site identifies the need to characterize additional containers belonging to the approved waste stream. In 

must submit revised AKSR, new or revised source documents, and radiological, VE/ RTR BDRs, and other pertinent information documentin

review.
4

2.0 PURPOSE OF TIER 1 EVALUATION 

Certain changes to the waste characterization activities after the date of the site’s baseline 

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

requirements set forth in 40 Code of Federal Regulations (CFR) 194.8 and incorporated in the 

INL-CCP RH Baseline Final Report cited in Attachment A. 

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 (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

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

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

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

TRU wastes destined for disposal at the WIPP. 

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

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

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

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

notification, are identified in the site-specific baseline inspection reports. When evaluating 

proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the 

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

specific to a change. EPA reviews T2 changes on a quarterly basis, and EPA may conduct 

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

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of T1 changes to approve Waste Stream 

ID-RTC-S3000, containing four 55-gallon containers of RH TRU sludge waste (see Section 5.0, 

below), as described in CCP-AK-INL-520, Revision 1. This report presents the technical basis 

and results of EPA’s approval decision, 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 listed at the end of the report. 

Any of these documents can be requested from the following: 

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 

This T1 evaluation encompassed the addition of INL RH Waste Stream ID-RTC-S3000, 

currently described by CBFO and INL-CCP as consisting of four 55-gallon drums. 
5

The evaluation of this waste stream included two waste characterization areas: AK and 

radiological characterization. Table 2 lists participants in the T1 evaluation. 

Table 2. Tier 1 Evaluation Participants 

Name Affiliation & Function 

Edward Feltcorn Lead Inspector, U.S. EPA 

Rajani Joglekar Inspector, U.S. EPA 

Connie Walker Technical Evaluator – AK, SC&A 

Kira Darlow Technical Evaluator – AK, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 

Scott Smith Acceptable Knowledge Expert, CCP 

Mark Doherty Acceptable Knowledge Expert, CCP 

Irene Quintana Site Project Manager, INL-CCP, WTS 

Jene Vance Radiological Characterization Subject Matter Expert, CCP 

James Holderness Radiological Characterization Subject Matter Expert, CCP 

5.0 EVALUATION OF NEW WASTE STREAM ID-RTC-S3000 

The Reactor Technology Complex (RTC), formerly the Test Reactor Area (TRA), is part of INL. 

Waste Stream ID-RTC-S3000 is composed of RH TRU inorganic sludge waste generated during 

the remediation and removal of the four Building TRA-630 catch tanks that composed the 

building’s Catch Tank System (CTS). The four catch tanks were put into use in 1952, and waste 

was generated in 1987 when the tanks were cleaned out and replaced with the current tank vault 

(TRA-730) and four new tanks (TRA-730-1, -2, -3, and -4). The sludge from three of the TRA630 tanks was determined to be low-level waste; however, the sludge from Catch Tank 2 was 

determined to be RH TRU waste. Waste Stream ID-RTC-S3000 consists of approximately 

0.4 cubic meters of RH TRU inorganic sludge originating from Catch Tank 2. This waste was 

initially contained in two 55-gallon drums (TRA-88-21 and TRA-88-22). It was repacked into 

four 30-gallon drums (TRA-88-21A, TRA-88-21B, TRA-88-22A and TRA-88-22B) that were 

then placed into 55-gallon-drum overpacks, resulting in a waste stream of four 55-gallon drums. 

These four drums constitute the scope of this T1 evaluation. The waste is primarily contaminated 

with fissile materials and mixed fission products (MFP), with the predominant radionuclides by 

mass being uranium-235 (235U) and uranium-238 (238U). The majority of the drums’ gamma 

activity is from cesium-137 (137Cs), cobalt-60 (60Co), americium-241 (241Am), and europium-154 

(

154Eu). 

40 CFR 194.24(c) states that if AK data are used to quantify parameters, that data must be 

qualified by an acceptable method, including peer review, confirmatory testing, or demonstration 

of data acquisition under an equivalent quality assurance (QA) program. The WCPIP also allows 

the use of a combination of qualification methods, so INL-CCP used a combination of methods 

to obtain measurement data or to qualify the AK information when defining the isotopic ratios, 

physical form, and absence of residual liquids associated with this waste stream. Isotopic ratios 

were determined by sampling and analysis of sludge in the Catch Tank 2 containers. The values 

were used to derive 137Cs scaling factors that were applied to the four 55-gallon drums. The 
6

radiological sampling and analyses data were not used to “confirm” previous AK data but were 

implemented as a stand-alone measurement technique to obtain the necessary data for isotopic 

distribution determinations, scaling factors, and subsequent dose to curie (DTC) measurements. 

However, visual exam (VE) data were obtained and used to qualify previous AK physical form 

data. Prohibited items or excess liquids identified by quick screen radiography were remediated. 

Documents, Waste Containers, and Batch Data Reports Reviewed

In conducting this T1 inspection, EPA examined the batch data reports (BDRs) presented in 

Table 3. Other documents reviewed are listed in Attachment B to this report. 

Table 3. Batch Data Reports Examined 

Drum Number VE BDR Number DTC BDR Number Radiochemistry BDR Number 

TRA-88-21A 

TRA-88-21B RHINLVE100001 INLRHDTC10009 ALD09029A, ALD09029B, ALD09029G, ALD09029I_R1, ALD09029L, IDRH0904 

TRA-88-22A 

TRA-88-22B RHINLVE100001 INLRHDTC10009 ALD09029A, ALD09029B, ALD09029G, ALD09029I_R1, ALD09029L, IDRH0904 

5.1 Acceptable Knowledge 

EPA examined the AK process and associated information to approve the T1 request for RH 

Waste Stream ID-RTC-S3000. 

Waste Characterization Element Description

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

characterization: 

• Definition and identification of the waste stream 

• Radiological characteristics of the waste 

• Physical composition of the waste 

• Sampling Plan and use of AK data 

• Identification of high-level waste and spent nuclear fuel 

• AK documentation and assembly of required information, including the acceptable 

knowledge summary report (AKSR) and adequacy of the RH TRU WCPIP AK process 

implementation 

• AK data traceability 

• AK source document sufficiency 

• WCPIP interpretation, including AK qualification, and Certification Plan/Confirmation 

Test Plan (CTP) preparation/adequacy 

• Waste Stream Profile form (WSPF) and CRR adequacy 
7

• Correlation Surrogate Summary Form (CSSF) and CH-RH correlation 

• Personnel training 

• Nonconformance reports (NCRs) and AK discrepancy resolution forms 

• AK accuracy 

• Defense determination 

• Load management 

• Data Quality Objectives (DQOs) attained through AK qualification or other means 

Technical Evaluation

(1) Waste Stream ID-RTC-S3000 was examined with respect to waste stream definition and 

was found to be adequate. 

The WCPIP, Revision 0, defines a waste stream as consisting of “waste material generated from 

a single process or activity, or as waste with similar physical, chemical, and radiological 

properties.” EPA evaluated the waste stream against this definition to determine whether the 

processes and activities associated with waste generation were adequately addressed, and to 

determine whether the physical, chemical, and radiological composition of the stream was 

adequately defined. 

The processes contributing to sludge deposition in and removal from the CTS are well 

documented in the AKSR and related source documents. The AKSR states that Waste Stream 

ID-RTC-S3000 is composed of sludges that originated from the TRA-630 facility CTS. The 

TRA-630 CTS was used to manage radioactive wastewater from the Materials Test Reactor 

(MTR) in Building TRA-603, the Radiochemistry Laboratories and the Vent Scrubber (TRA604), the RTC Hot Cells (TRA-632), the Reactor Services Building (TRA-635), and the 

laboratories in the Alpha Wing (TRA-661). Wastewater from these areas was routed to the CTS, 

which in turn discharged to other wastewater treatment facilities based on the wastewater’s 

radioactivity content (C079, P001, P007, P009, P011, P014, P015, P017, P021, P027, P028, 

P054, P074, P093, P151, P209, U002, U052). The original CTS was composed of four catch 

tanks (1-4). According to the AKSR (Revision 1) and source documents (e.g., P054), Catch 

Tanks 1 and 2 collected waste primarily from the reactor drain tank located in TRA-603. Catch 

Tanks 3 and 4 collected waste from TRA-632, TRA-635, TRA-604, and TRA-661. In 1981, the 

original TRA-630 CTS Tanks 1 and 2 were reconfigured to accept waste generated only from the 

RTC Hot Cells, and discharge from the MTR Building was diverted to Catch Tanks 3 and 4. 

INL-CCP stated that the tanks were controlled by valves to allow any tank to receive wastewater 

from any of these facilities (P007 and U002), or to transfer the wastewater between the tanks, 

thus introducing the possibility of cross contamination between the catch tanks (C253). 

EPA evaluated radiological data to see if they support the waste stream definition. The AKSR 

includes radiological data for all catch tanks from the sampling events in 1986, 1999, and 2002. 

However, these data were not used directly and INL-CCP sampled and analyzed the waste 
8

sludge and developed scaling factors from the analytical data. Data from the three catch tank 

sampling events show relatively good correlation and provide a sufficient understanding of the 

general radiological composition of Catch Tanks 1-4. The Catch Tank 2 sampling data obtained 

by INL-CCP provide a good understanding of the radiological composition of the current waste 

stream. 

When taken as a whole, the AKSR, Radiological Characterization Report, Certification Plan, and 

source document references (e.g., C252) did not present a sufficiently clear picture of the waste 

stream. Specifically, the AKSR infers that the two original drums in the waste stream originated 

from Catch Tanks 1–4, but other source documents indicate the two drums originated only from 

Catch Tank 2 (e.g., C252). However, INL-CCP submitted freeze file2 changes (C253) to the 

AKSR that explained the waste stream determination. 

INL-CCP originally determined that the waste stream included all 11 drums generated from the 

clean-out of the CTS in 1987, and the general radiological information presented in the AKSR 

applies to all 11 containers (e.g., Table 6 in the AKSR). However, INL-CCP later determined 

that only two of the original 11 drums were RH TRU waste, so the waste stream volume was 

reduced to these two drums, which were later repackaged into four drums. Also, the drums 

contained sludge sourced from Catch Tank 2, as discussed in CCP-AK-INL-521 and reference 

C252. Therefore, this approval is limited to the approximately 0.4 cubic meters of RH TRU 

inorganic sludge originating from Catch Tank 2 that was initially contained in two 55-gallon 

drums that have been repackaged into four 55-gallon drums. 

Based on the information reviewed and modifications to the AKSR presented in freeze file 

reference C253, the waste stream has been adequately defined. EPA concluded that the AKSR 

will be sufficient upon inclusion of the revision and expects a formal revision of the AKSR to be 

completed prior to INL-CCP’s first quarter 2011 submission of T2 changes to EPA for review 

and concurrence. Notification of changes to the AKSR after integration of the freeze file is a T2 

change. Consistent with the approach defined above to make addition of containers with different 

pedigrees a T1 change, the addition of any containers to the waste stream beyond the four 

repackaged 55-gallon drums from Catch Tank 2 is a T1 change.

(2) The radiological characteristics of the waste stream were evaluated and found to be 

adequately described. 

Waste Stream ID-RTC-S3000 is composed of catch tank sludge that is contaminated by 

radionuclides from various sources. The contact radiation readings of the catch tanks varied from 

150 milliRem per hour (mrem/h) to 2,500 mR/h (C079, C133, P011, P014, P208, P209, P211, 

and P236). As described above, sludges from each tank were analyzed in 1986 for alpha, gamma 

and beta radioactivity (Table 5 of the AKSR, C079, C133, P208, P211, P236, U052, U115, 

U116, and U117). The original CTS tanks were replaced in 1987–1988, and wastes from the 

replacement tanks were sampled in 1999 and 2002 (P092, P236). INL-CCP compared the data 

and concluded that the 1986 data and the 1999/2002 data are statistically consistent for Catch 

 

2 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. 
9

Tanks 1–4 as a whole, so INL-CCP used the older data to generate the estimated radiological 

distribution for Waste Stream ID-RTC-S3000 presented in Table 6 of the AKSR. The two 

predominant radionuclides by weight are 235U and 238U, and the two predominant radionuclides 

by activity are 137Cs and 60Co. Over 95 percent of the total activity in the waste stream is from 

137Cs, 60Co, 241Am, and 154Eu. EPA concludes that the radiological information obtained by 

sampling the Catch Tank 2 containers reflects the composition of the sampled containers, and 

additional justification and analysis are required if INL-CCP wishes to consider these to be 

representative of all catch tank wastes. 

The radiological composition of Waste Stream ID-RTC-3000 is adequately presented in the AK 

record and in INL-CCP sampling and analysis records. Table 6 of the AKSR reflects the overall 

composition of the sludge in Catch Tanks 1–4, while the radiological information presented in 

reference C252 and CCP-AK-INL-521, Revision 0, are specific to Catch Tank 2 sludge. 

Notification of availability of future revisions to CCP-AK-INL-521 is a T2 change, as stated 

previously in the INL RH baseline inspection report. 

(3) Physical characteristics of the waste stream were examined, including the presence of 

prohibited items (liquids), and found to be adequately addressed. 

Waste Stream ID-RTC-S3000 is composed primarily of inorganic sludges from the TRA-630 

catch tanks. Sludges were removed from the tanks by spraying water into the tanks and draining 

the tank slurry into filter socks. The filter socks were then tied off and allowed to drain (C079, 

C133, P007, P208, P211, P236, and U093). INL-CCP determined that the waste consists 

predominantly of homogeneous inorganic solids, but it may also contain limited amounts of 

heterogeneous debris generated during sludge remediation, including cellulosics (e.g., the filter 

socks themselves, wipes, personal protective equipment), plastics (e.g., hose, rope, sheeting, 

tape), rubber (e.g., gloves), and glass (e.g., sample bottles). Sorbent was added to the waste when 

it was originally packaged in 1987 for liquid adsorption (C123, C129, DR004, C133, P208, and 

P211), and the waste stream was assigned Waste Matrix Code (WMC) S3120, Inorganic 

Sludges. 

INL-CCP estimated the waste material parameter weights for the waste stream based on Fast 

Scan RTR records (U152) performed in 2008, which showed the drums were composed of a 50-

gallon poly container that contained sludge (90–98%) and metal wire (2–8%), with some 

sorbent. Drum 88-21 contained a glass jar with 2 tablespoons liquid, and drum 88-22 contained 

one cup of liquid; No-Char was added as a sorbent to the drums prior to repackaging. The drums 

underwent subsequent VE when the two original drums were repackaged into four separate 

drums. Examination of the associated BDRs confirmed that the physical composition of the 

drums corresponds to the description in the AKSR, and the physical composition of the stream is 

well defined. 

(4) The identification of the waste as transuranic and not high-level waste or spent nuclear 

fuel was examined and found to be adequate. 

INL-CCP provided a freeze file modification to the AKSR (C253) that clarified how it 

determined the waste stream did not contain spent nuclear fuel or high-level waste. This freeze 
10

file change states that the WIPP Land Withdrawal Act (LWA) prohibits the disposal of spent 

nuclear fuel and high-level waste as defined by the Nuclear Waste Policy Act of 1982 (NWPA), 

which states that 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 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, and not production of power or plutonium, may be classified as waste, and 

managed in accordance with the requirements of this Order when it is technically infeasible, cost 

prohibitive, or would increase worker exposure to separate the remaining test specimens from 

other contaminated material.” The NWPA defines high-level waste 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.” 

INL-CCP concluded that Waste Stream ID-RTC-S3000 consists of materials that originated from 

test reactors that were operated for research and development (R&D) purposes only. For 

example, the MTR was a test reactor that operated for R&D only and contributed contamination 

to Catch Tank 2 sludge directly in the form of contaminated cooling or decontamination water. 

Further, wastes generated from laboratory or hot cell operations with irradiated fuel or sample 

materials were also considered to be test samples or to have originated from test reactors that 

were operated for R&D only. INL-CCP concluded that since the waste stream does not contain 

irradiated fuel elements withdrawn from a reactor, the waste was not spent nuclear fuel and none 

of the laboratory, hot cell, and maintenance operations contributing wastewater to the CTS 

involved reprocessing of constituent elements from reactor fuel. INL-CCP cited several 

references (C079, C136, C137, C145, P002, P011, P054, P071, P088, and P098) that document 

the activities of the hot cells, laboratories, reactor use, and tank remediation. Reference C136 is 

an interview with three INL employees who are familiar with generation of the TRA sludge. The 

individuals indicated that “[none] of the waste generated from CTS or Hot Waste System (HWS) 

remediation and removal operations is classified as high-level waste or spent nuclear fuel. No 

fuel reprocessing was conducted in the facilities with liquid wastewater inputs to the CTS or 

HWS. The only irradiated fuel processing/handling in RTC facilities consists of fuel pin 

disassembly and destructive sample preparation and analysis conducted in the RTC Hot Cells 

facility.” INL-CCP concludes that the waste is not spent nuclear fuel, high-level waste, or a 

waste historically managed as high-level waste, and is eligible for disposal at the WIPP as RH 

TRU waste. EPA accepts INL-CCP’s conclusion. 

(5) Sufficiency of the Acceptable Knowledge Summary Report and implementation of the 

Acceptable Knowledge process were evaluated and found to be adequate. 

EPA found that CCP-AK-INL-520, Revision 1, did not adequately define the waste stream or 

address high-level waste and spent nuclear fuel, as discussed above. Specifically, the AKSR did 

not adequately address the evolution of the four drums that originated from Catch Tank 2 and did 

not provide sufficient detail about the fuel pin origin, pin testing, and potential generation of 

spent nuclear fuel and high-level waste. INL-CCP prepared a freeze file modification (C253) that 

better explained waste flow, as well as why the waste stream now contains only four drums 
11

originating from two Catch Tank 2 drums. The freeze file mentioned above also better justifies 

the spent nuclear fuel and high-level waste exclusions, as required under the LWA. With the 

proposed modifications, the AKSR is adequate. See item (1), above. 

(6) Data traceability was examined and found to be adequate. 

The traceability of radiological data from the original drum records through various RTR 

activities and subsequent repackaging VE was evaluated for the two original Catch Tank 2 

drums, as presented below in Table 4. INL-CCP stated there was little original paperwork 

associated with the original packaging event, even though the catch tanks were sampled in 1986 

and abundant data are available that summarize this sampling event (e.g., C079, C133, U052). 

Documentation presented above shows that drum data are traceable, particularly since 2008 

when the drums underwent Quick Scan RTR, repackaging, and VE. Drums were tracked using 

the site Integrated Waste Tracking System (IWTS) (U175) and are currently tracked in INLCCP’s Project Tracking System (PTS). EPA concluded that data traceability was adequate. 

(7) Sufficiency of Acceptable Knowledge support documents and related document tracking 

was evaluated and found to be adequate. 

Table 4. Data Traceability for Catch Tank 2 Drums 

Drums 

Original 

Drum 

Tracking 

Reference 

Additional Catch 

Tank 2 Transfer 

or Packaging 

Records 

Reference 

Prescreen or 

Quick Scan 

RTR 

Reference 

CCP 

Radiological 

Sampling 

Reference 

Repackaging 

Records 

Reference VE BDRs 

TRA-88-21 C079 p. 9-11 

of pdf, 

Uniform 

Hazardous 

Waste 

Manifest, 

1990 

C123, Waste 

Profile Statement, 

TRA-88-21, 1990 

RH TRU RTR 

Prescreen for 

Repackaging/

AK 

Worksheet, 

Form 828, 

Reference 

U152, 2008 

C252, 

Analysis of 

Sample Data 

for RH TRU 

Waste Stream 

ID-RTC-S3000, 

2010 

RH TRU 

Repackaging 

Data Sheet--

FRM-880s, 

Reference 

U201, 2010. 

Repackaged to 

generate drums 

TRA-88-21A 

and TRA-88-

21B 

RHINLVE100001, 

2010, includes 

both drums TRA88-21A and TRA88-21B 

TRA-88-22 C079 p. 9-11 

of pdf, 

Uniform 

Hazardous 

Waste 

Manifest, 

1990 

C123, Waste 

Profile Statement, 

TRA-88-22, 1990 

RH TRU RTR 

Prescreen for 

Repackaging/

AK 

Worksheet, 

Form 828 

Reference 

U152 p. 4, 

2008 

C252, Analysis 

of Sample Data 

for RH TRU 

Waste Stream 

ID-RTC-S3000, 

2010 

RH TRU 

Repackaging 

Data Sheet 

FRM-880s, 

Reference 

U201, 2010. 

Repackaged to 

generate drums 

TRA-88-22A 

and TRA-88-

22B 

RHINLVE100001, 

2010, includes 

both drums TRA88-22A and TRA88-22B 
12

Examination of Attachment 4; reference lists in CCP-AK-INL-520, Revision 1, and CCP-AKINL-521, Revision 0; in combination with references provided during the T1 review indicate that 

references are to be added to the AK record, and other references will be updated. For example, 

the FRM-880s relevant to repackaging are to be added to the reference list, and reference U152 

is to be updated. EPA expects the AKSR and Attachment 4 to be updated to include all relevant 

references, including any references cited within CCP-AK-INL-521. The AKSR reference list 

will be updated in conjunction with text modifications [see item (1), above]. Notification of 

availability of updates to Attachment 4 remains a T2 change, as stated previously in the INL RH 

baseline inspection report. 

(8) Interpretation of the Waste Characterization Program Implementation Program, with 

respect to contents of the Certification Plan and the Confirmatory Test Plan, was 

evaluated and found to be adequate, including mandatory content and the use of sampling 

data. 

EPA’s March 26, 2004, RH WCPIP letter indicated that 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 the AK qualification process. EPA intended that the sites specify 

and document exactly how characterization is to take place on a waste stream basis, followed by 

a detailed plan explaining implementation of confirmatory testing when this is to take place. 

CCP-AK-INL-522, Revision 1, explains that INL-CCP intended to use a combination of methods 

to qualify the AK information defining the radionuclide ratios, physical form, and absence of 

prohibited items associated with this waste stream. CCP-AK-INL-522, Revision 1, states that 

AK determination of physical form and prohibited items will be qualified using either 

radiography or VE, which will also be used to determine that packaging DQOs are met. 

Prescreening with radiography has identified liquids, and some remediation is expected. The 

DQO for defense determination is met solely through documented AK information compiled and 

reported using the procedure found in Attachment A of the WCPIP, Revision 0d. 

Radiological components and, in particular, establishment of the isotopic distribution, were 

determined through sampling of sludge data and were not used to confirm existing AK data. 

Instead, sampling and analysis was a stand-alone effort designed to characterize the two drums 

that were included in the sampling program. While the AK record includes 1986 sampling and 

analysis data specific to each of the catch tanks (Table 5 of the AKSR), the data were not 

collected under an approved QA program, so attempts to use this information were unsuccessful. 

INL-CCP did not elect to confirm any previous analytical data by sampling and analysis, but 

instead chose to characterize the two drums without associating these values with the AK record, 

other than to use AK information to determine the sample population size. The sludge sampling 

plan (CCP-AK-INL-525, Revision 0 or SAP) was prepared in November 2009, and EPA did not 

review the plan prior to implementation. The sample process is described in CCP-AK-INL-525, 

Revision 0. INL-CCP concluded that samples collected were representative of the two Catch 

Tank 2 drums, and EPA agrees with this determination. 

Although not directly referenced in the Certification Plan, results of the sample analyses were 

summarized and interpreted in reference C252, which presents an extensive evaluation of the 
13

analytical data, as discussed in detail in Section 5.2. Reference C252 concluded that sampling 

was executed in accordance with the SAP, and the samples were representative of the two 

original drums and provided an adequate basis for the characterization of the waste stream, 

assuming that the waste stream includes only those two drums. EPA agrees with this 

determination. 

EPA identified several inconsistencies in CCP-AK-INL-522, Revision 1, with respect to how the 

waste stream was presented and how radiological characterization was to be accomplished. INLCCP addressed these concerns through freeze file modifications. EPA evaluated the Certification 

Plan and CTP to determine whether INL-CCP included the specific elements as defined in the 

WCPIP. When evaluated as a whole, CCP-AK-INL-522, Revision 1; CCP-AK-INL-525, 

Revision 0; reference C252; CCP-AK-INL-520, Revision 1; the freeze file change (C253); and 

the supporting source documents indicate that the DQOs, as specified in the WCPIP, have been 

met. EPA finds that CCP-AK-INL-522 will be sufficient upon inclusion of the revisions and 

expects a formal revision of this document be completed prior to the INL-CCPs first quarter 

2011 submission of T2 changes to EPA for review and concurrence. 

(9) Content and technical adequacy of the Waste Stream Profile Form and Characterization 

Reconciliation Report were evaluated and both were found to be adequate. 

INL-CCP representatives provided a draft WSPF for inspection purposes only, without the 

required signatures or attachments. The document was not complete; for example, it did not 

include all necessary program information. See item (1) above for more information about the 

waste stream. Because there are inconsistencies between source documents and references about 

the different catch tank sources for the waste stream, and because the sampling clearly applies to 

the two drums (repackaged into four) from Catch Tank 2 alone, EPA’s approval is limited to 

containers sourced from Catch Tank 2. Notification of availability of the final WSPF remains a 

T2 change, as stated previously in the INL RH baseline inspection report. 

EPA examined the content of the CRR to ensure that it reflected requirements of CCP-TP-506, 

CCP Preparation of the Remote-Handled Transuranic Waste Acceptable Knowledge 

Characterization Reconciliation Report. Specifically, EPA evaluated the CRR to determine the 

completeness and adequacy of its contents, as required in the WCPIP, and found it to be 

adequate. The CRR addresses only the four containers originating from Catch Tank 2. 

Notification of availability of a final and/or revised CRR remains a T2 change, as stated 

previously in the INL RH baseline inspection report. 

(10) Use of a Correlation and Surrogate Summary Form was evaluated and found to be 

adequate. 

Completion of a Correlation and Surrogate Summary Form (CSSF) is required when AK 

information from a related CH waste stream is used in the RH waste characterization process. 

INL-CCP indicated that CH data were not used in this manner, so a CSSF was not required for 

this waste stream. 

(11) Personnel training was evaluated and found to be adequate. 
14

EPA reviewed training records for Scott Smith [AK expert (AKE)], Mike Papp (who authored 

several source documents), and Hillary Neely (site project manager). Jim Holderness prepared 

the sampling memorandum, and Jene Vance prepared the Radiological Characterization Report; 

while both interpreted AK data, their training records were examined as part of EPA’s 

radiological characterization analyses. EPA reviewed the AKE and RH Qualification Cards for 

Mr. Smith, but neither showed that he has had WCPIP or EPA regulation training. Training 

records for Ms. Neely and Mr. Papp showed they were trained to the WCPIP and had some onthe-job training with respect to EPA requirements. There is no documentation to indicate that 

INL-CCP individuals are trained to all EPA requirements, nor that they are 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 modified 

WCPIP. However, EPA expects to be able to see documentation that all AKEs and other 

individuals who prepared, edited, contributed to, or signed off on AK-related documents have 

up-to-date training on the WCPIP and its requirements, as well as related AK procedures. 

(12) Non-conformance Reports and Discrepancy Resolution Forms were examined and found 

to be adequate. 

INL-CCP provided three discrepancy resolution (DR) reports. DR002 deals with assignment of 

Resource Conservation and Recovery Act (RCRA) hazardous waste numbers, as does DR003. 

DR004 addresses the discovery of absorbent on top of waste, which was not included in the AK 

record. Notification of the availability of additional DR Forms pertinent to this waste stream is a 

T2 change, as stated previously in the INL RH baseline inspection report. 

INL-CCP provided a single example NCR. NCR-RHINL-0200-09 was issued because Container 

TRA-88-12 had too much absorbent above the waste, so that waste contents could not be reached 

for RCRA sampling. The BDRs provided did not include any NCRs. 

Preparation of NCRs and DR Forms was adequate. 

 (13) Acceptable Knowledge accuracy was assessed and found to be adequate. 

The AK accuracy report for Waste Stream ID-RTC-S3000, Lot 1, consists of four RH TRU 

containers. The AKSR did not include any radiological comparisons based on INL-CCP 

sampling because INL-CCP chose not to use these data to qualify AK. INL-CCP contends that 

comparison of AK data against measurement information is not required when the measurement 

data are not used to confirm AK. While not the intent of the WCPIP, the WCPIP (Revision 0d) 

uses the term “confirmation” in the AK accuracy section, so EPA will not require revision of the 

AK accuracy report. However, the WCPIP has been revised, and EPA will examine this 

document with respect to this interpretation and the intended comparison in forthcoming 

inspections under the new WCPIP. Any revision of the AK accuracy report remains a T2 change, 

as stated previously in the INL RH baseline inspection report.

(14) Defense status of the waste was evaluated and found to be adequate. 
15

The WIPP requires generator sites to use AK to determine that a TRU waste stream meets the 

definition of TRU defense waste. TRU waste is eligible for disposal at the WIPP if it has been 

generated in whole or in part by one of the atomic energy defense activities listed in 

Section 10101(3) of the NWPA. INL-CCP presented references and data that indicate the TRA 

sludges are contaminated with materials from atomic energy defense activities associated with 

naval reactors development, materials security and safeguards, and defense R&D activities. For 

example, the MTR was built solely for testing materials and was used for experiments related to 

the U.S. Navy, Army, and Air Force. Research performed at RTC-sourced facilities included 

defense-related Hanford fuel element design and performance (P071, P054). The AKSR lists a 

number of defense-related experiments performed in buildings, reactors, or laboratories that 

provided liquid to the catch basins, including Catch Tank 2. These include, but are not limited to, 

the following: 

• Samples for Westinghouse in support of the development, design, and construction of the 

submarine thermal reactor (STR), later named S1W, a land-based prototype water-cooled 

reactor power plant suitable for submarine propulsion. The STR was located at the Naval 

Reactors Facility (NRF) and was the prototype reactor for the USS Nautilus. 

• Aerojet General Nucleonics-302, related to U.S. Army portable and stationary reactor 

designs. 

• Knolls Atomic Power Laboratory L-42, an experimental loop related to R&D of nuclear 

propulsion for the U.S. Navy. 

The AKSR also states that the RTC Hot Cells provided examination of fuels from a variety of 

defense-related sources and included fuel examination by methods that generated wastewater. 

The AKSR does state that later missions of the hot cells during the late 1980s and 1990s were 

commercial in nature, but activities performed when the cells provided wastewater to the original 

CTS included defense support activities (P054). Examples of defense-related Hot Cell work 

include the following: 

• Gas-Cooled Reactor Experiment Fuel Specimens Identified in Hot Cell #2 Logbook from 

May 1961 to January 1963. Work included labeling, etching, hardness testing, and 

photographing. 

• Bettis Atomic Power Laboratory Target Fabrication Line 3&6 16700-510-804. Identified 

in Hot Cell #2 Logbook from March to April 1978. Work included grinding, sectioning, 

scanning, polishing, and etching. 

• Naval Reactors Facility hot-die-size element 81-1, identified in Hot Cell #2 Logbook 

from October 1980. Sample identification indicates that the sample came from the Naval 

Reactor Facility. 

The AKSR concludes that as a result of the inherent commingling of materials originating from 

the numerous defense activities, segregation of non-defense wastes stream is not possible. 

Therefore, Waste Stream ID-RTC-S3000 is eligible for disposal at the WIPP as a commingled 
16

defense waste stream generated “in part” by atomic energy defense activities. EPA accepts these 

arguments. 

(15) Load management was assessed and determined not to apply to this waste stream. 

INL-CCP indicated that load management will not be performed for this waste stream. 

Implementation of load management remains a T1 change, as stated previously in the INL RH 

baseline inspection report. 

(16) Attainment of Data Quality Objectives (DQO) through Acceptable Knowledge 

qualification was evaluated and found to be adequate. 

As a result of the analysis presented in items (1)-(15) 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 and cellulose, plastic and rubber 

When evaluated as a whole, CCP-AK-INL-520, Revision 1; CCP-AK-INL-521, Revision 0; 

CCP-AK-INL-562, Revision 1; and the supporting source documents presented in Attachment B 

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

Summary of Results

Findings or Concerns 

The EPA Inspection Team did not identify any findings or concerns relative to Waste Stream IDRTC-S3000, which was the subject of this T1 change evaluation. 

Tiering Changes

Based on this evaluation, there are no changes to the AK T1 and T2 designations identified 

during the Baseline Inspection and subsequent T1 evaluations. 

Conclusions 

Based on the results of this evaluation, EPA is approving the T1 request for Waste Stream IDRTC-S3000, with the limitations discussed previously. 
17

5.2 Radiological Characterization 

EPA examined the radiological characterization process and associated information to determine 

whether INL-CCP demonstrated compliance with 40 CFR 194.8 for RH Waste Stream ID-RTCS3000. 

Radiological Characterization Overview

The approach to the characterization of the ID-RTC-S3000 waste drums is DTC in conjunction 

with radionuclide-specific scaling factors, a technique that EPA has observed and approved at 

several RH TRU sites previously. However, the absence of detailed information on the materials 

examined and the potential for the separation of 137Cs in wastewater prevented the development 

of 137Cs-based scaling factors using ORIGEN as has been done for other wastes. Specifically, 

there was a potential depletion of 137Cs because of its greater solubility relative to the other 

reportable radionuclides, considering that water was used in removing the sludge from the tanks. 

Instead, sample collection and analysis were the only viable methods and the radionuclides of 

interest in each sample were identified and quantified by radiochemistry and mass spectrometry. 

A single set of 137Cs-based scaling factors was developed for the radiological characterization of 

the waste stream. 

An overview of the radiological characterization process used for the ID-RTC-S3000 waste is 

provided in Figure 1, below, which is the enhanced version of the flow diagram provided in 

Figure 2-1 of CCP-AK-INL-521, Revision 0. 

Collect relevant AK 

information 

Develop Certification 

Plan

Use MicroShield to model the 

one-meter gamma dose rate as 

a function of waste density 

based on a 1-Ci source of Cs137

Develop plan to 

sample the two drums 

Submit samples to the ICP 

Analytical Laboratory for 

radiochemistry and ICP-MS 

analyses 

Using the laboratory results, 

develop the Cs-137 scaling 

factors for all reportable 

radionuclides 

Calculate the activity and 

mass content of the drums 

for reportable radionuclides 

Develop the DTC conversion 

factor–density correlation 

equation for Cs-137 in units of 

mR/hr/Ci 

Find the mean one-meter gamma 

dose rate. Determine drum net 

weight and estimate fill percentage 

to calculate density.

Using the calculated density, 

the measured dose rate and the 

DTC correlation, calculate the 

Cs-137 content of the drums

Determine uncertainties in the 

reported activities and masses 

of reportable radionuclides 
18

Figure 1. Flow Diagram of the Radiological Characterization Process, 

Waste Stream ID-RTC-S3000 

Documents Reviewed

To support this T1 evaluation, EPA examined the documents related to the INL-CCP RH TRU 

radiological characterization program listed in Attachment B to this report. 

Technical Evaluation

EPA evaluated the characterization method used for the TRA RH TRU sludge waste for 

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 INL-CCP 

radiological characterization program: 

(1) The EPA inspection team evaluated the sampling method applied to obtain samples from 

the existing two 55-gallon drums containing the inorganic sludge waste and found them 

to be adequate. 

Five grab samples (including one “co-located sample”) were collected from the two drums. Two 

primary samples were taken from drum TRA-88-22, a “co-located” sample from drum TRA-88-

22, and two more primary samples from drum TRA-88-21. The physical condition of the waste 

and the sampling method employed (collecting two scoops of sludge from each drum) resulted in 

representative samples from the sludge waste. The sampling and the analysis of sample data are 

explained in a memorandum from J. Holderness to Irene Quintana, dated February 21, 2010, as 

listed in Attachment B to this report. The sampling analysis results were used to determine the 

137Cs-based scaling factors for the five samples. The scaling factors correlate a waste drum’s 

measurable 137Cs gamma dose and waste density to quantify specific radionuclides in each of the 

four repackaged waste drums. These activities are documented in the sample-specific calculation 

packages listed in Attachment B. The development of the 137Cs-based scaling factors was 

supported by the following sources of information: 

• Radiochemistry and mass spectrometry measurements made on all of the samples 

• Scaling factors obtained from the sampling results 

Determination of the 137Cs activity for a container allows the calculation of the following 

quantities for each container: 

• Activity in curies (Ci) and mass in grams (g) for each of the 10 WIPP-tracked 

radionuclides (i.e., 137Cs, 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) 

• Associated uncertainty for all values listed in previous bullet 
19

• Plutonium equivalent curies (PE Ci) 

• Decay heat in watts 

• Fissile gram equivalent (FGE) 

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

sources (Reference 13 in CCP-AK-INL-521, Rev 0) and were spot-checked for accuracy. 

Individual shielding calculations were performed using MicroShield® with the 1-curie source of 

137Cs uniformly distributed throughout a 55-gallon waste drum, using the geometry of a 30-

gallon drum inside of a 55-gallon drum that will be used for packaging the RH TRU sludge 

waste, for a range of waste densities from 0.2 g/cm3 to 1.8 g/cm3 in increments of 0.2 g/cm3. The 

results were then used to derive a DTC correlation as a function of density for 137Cs, as shown in 

CCP-AK-INL-521, Revision 0, Figure 5-1. The actual DTC calculations are performed using an 

Excel spreadsheet where the input includes the following: 

• Container identification number 

• Dose rate measurement date 

• Container gross weight 

• Estimated 30-gallon drum fill height in percent 

• Four external dose rate measurements 

There were no concerns regarding the correlation of waste records for the four 55-gallon drums 

constituting Waste Stream ID-RTC-S3000. 

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

technically adequate and appropriately documented. 

EPA evaluated the following aspects: 

• Activity values were derived from statistical metrics using the mean and standard 

deviation values for each radionuclide 

• Adequacy of the number of samples for the homogeneous waste 

• 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.), when needed, and the technical correctness of the values 

assigned to each attribute 

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

such that they could be responsible for the measured external dose rate (i.e., 137Cs for the 

Waste Stream ID-RTC-S3000) 

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

• Compliance with the INL-CCP procedure for dose measurements (CCP-TP-504, 

Revision 9) 

• Activity and uncertainty values determined for the 10 WIPP-tracked radionuclides 
20

• The determination of the contribution of all radionuclides to the radiological hazard3

Table 5 shows the radionuclide-specific scaling factors developed for Waste Stream ID-RTCS3000, taken from INL-RH-106. 

Table 5. Radionuclide-Specific Scaling Factors 

Radionuclide 137Cs-Based DTC Scaling Factor

233U 6.82E-05 

234U 1.96E-04 

235U 1.24E-05 

238U 2.69E-05 

238Pu 8.19E-03 

239Pu 5.42E-03 

240Pu 3.94E-03 

241Pu 9.68E-02 

242Pu 5.98E-06 

241Am 2.06E-02 

137Cs 1.00E+00 

137mBa 9.46E-01 

90Sr 4.23E-01 

90Y 4.23E-01 

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

factors for Waste Stream ID-RTC-S3000. 

(3) The technical basis of the DTC correlation and its documentation were evaluated and 

both aspects were acceptable. 

 

The correct version of the DTC Excel spreadsheet was used for the calculations (i.e., it contained 

the radionuclide scaling factors that were developed for Waste Stream ID-RTC-S300 contained 

in INL-RH-106 and Table 5, above). There were no issues related to the DTC correlation and its 

documentation for Waste Stream ID-RTC-S3000. 

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

evaluated and found to be acceptable. 

CCP-AK-INL-521 is the main document that describes the radiological characterization process 

that INL-CCP used for Waste Stream ID-RTC-S3000. This document is supported by a series of 

six calculation packages that had been prepared and reviewed initially by Jene Vance and Jim 

Holderness, listed in Attachment 1 to CCP-AK-INL-521. EPA found that the calculation 

packages cited above adequately supported the activities upon which the radiological 

 

3

 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. 
21

characterization of the four drums in Waste Stream ID-RTC-S3000 was based. There were no 

issues related to the documentation of technical aspects of the INL-CCP radiological 

characterization approach for the four drums in Waste Stream ID-RTC-S3000. 

(5) The laboratory radiochemical and Inductively Coupled Plasma-Mass Spectrometry (ICPMS) analyses were evaluated for technical adequacy and were acceptable to support the 

development of radionuclide scaling factors. 

The sampling was executed in accordance with the sampling and analysis plan (SAP) and 

provided sufficient information to use as the basis for deriving scaling factors for all reportable 

radionuclides. The sample results indicate that the only contributors to the gamma dose rate are 

137Cs, 60Co, 154Eu, and 155Eu, while the only significant contributor is 137Cs. The scaling factors 

derived from the sample data exhibit relatively small variations that can be represented equally 

well with the assumption of a normal or lognormal distribution. There is very little drum-to-drum 

variation, and a single set of scaling factors can be used to characterize the four containers from 

this waste stream. The number of samples taken was sufficient to meet the performance criterion 

that the uncertainty in the sample mean scaling factor should be less than or equal to a factor of 

two, evaluated at the one standard deviation level. With the exception of 241Pu and the “colocated” sample, all of the objectives of the SAP have been met. The accuracy QA objective was 

not met for 241Pu since 241Pu is not a TRU radionuclide, and the reported results can be used 

without significantly affecting the radiological characterization. The “co-located” sample, 

required by CBFO, did not meet the specified criterion that scaling factors should agree to within 

±25%. While this is not a problem for the radiological characterization effort since these samples 

could hardly be expected to be true duplicates, the SAP states that an NCR should be issued. 

Precision was assessed via the comparison of laboratory duplicates and scaling factors using the 

relative percent difference (RPD), defined as the difference between two values divided by onehalf their sum. There are no concerns regarding the technical adequacy of the sample analytical 

results to support the development of radionuclide scaling factors for the four drums in Waste 

Stream ID-RTC-S3000. 

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

evaluated and found to be adequate. 

The DTC determinations for all four drums are documented in a single DTC BDR, 

INLRHDTC1009, which INL-CCP provided during the T1 evaluation. The correct version of the 

DTC Excel spreadsheet was used for the calculations (i.e., it contained the appropriate 

radionuclide scaling factors that were developed for the four drums in Waste Stream ID-RTCS3000). EPA technical personnel verified that the DTC BDR included the following: 

• BDR Cover Sheet, Attachment 4 

• BDR Table of Contents, Attachment 5 

• BDR Narrative Summary, Attachment 6 

• Independent Technical review (ITR) Review Checklist, Attachment 7 

• Measurement Control Report, Attachment 1 

• Container Data Sheets, Attachment 2 
22

• Waste Container DTC Conversion Records, Attachment 3, with four dose rate 

measurements and their average, date of measurements and container weights 

• Evidence of the current version of CCP-TP-504, Revision 9 

• Evidence of signatures by the ITR and a site project manager (SPM) 

• Type of waste in each container, cement 

• Fill height of the container: < 25% full, 25–66% full, 66–90% full, > 90% full 

There were no issues related to the DTC correlation and its documentation for the four drums in 

Waste Stream ID-RTC-S3000. 

(7) Remote-handled and Transuranic determinations were assessed and found to be adequate. 

EPA examined the determinations that these containers meet the definitions of TRU waste and 

RH waste based on DTC BDR INLRHDTC10009. Both the RH and TRU determinations are 

parts of the actual DTC measurements that are performed at the INTEC Facility at INL, which 

were not assessed directly during this T1 evaluation. EPA did verify that no aspects of the DTC 

process had changed significantly from what EPA had observed during the baseline inspection. 

The results for these four containers as documented in DTC BDR INLRHDTC10009 indicated 

the following: 

• All four containers were clearly TRU (i.e., contained more than 100 nanocuries per gram 

(nCi/g) of TRU radionuclides). 

• All four containers were clearly RH (i.e., had an external contact dose rate greater than 

200 mRem/hr)4

. 

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

determinations for the four drums in Waste Stream ID-RTC-S3000. 

(8) The technical basis and derivation of Total Measurement Uncertainty (TMU) were 

evaluated and found to be adequate. 

 

The development of TMU for Waste Stream ID-RTC-S3000 is based on the propagation of 

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

TRU waste. Because of the commonness of 137Cs activity determination to all of the 

radionuclides, a statistical dependency is introduced for parameters that are summations over 

multiple radionuclides, e.g., TRU determination. For these cases, instead of combining in 

quadrature that is considered for statistical independence, the statistical dependency is explicitly 

considered. The TMU determination included contributions of the following: 

 

4

 The measured external gamma dose rates for the four containers in mR/hr were 40, 73, 55, and 29 at one 

meter. When multiplied by 18 to apoproximate the contact dose rates, all clearly exceed 200 mR/hr based solely on 

the gamma readings. Roentgens (R) and Rems (rem) are units of radiation exposure and dose equivalent, 

respectively. Although they represent different quantities, by convention they are often considered equivalent. In this 

report, these terms are used interchangeably, which is a conservative approach to assigning dose equivalent in rem. 
23

•

137Cs DTC correlation – including waste density determination (drum weight 

measurement, tare weight measurement, fill percentage estimation), MicroShield®

modeling, and MicroShield® code uncertainties 

•

137Cs activity measurement – including measurement uncertainty associated with dose 

rate measurement at one meter and uncertainty due to the contributions of other gamma 

emitters to the dose rate 

• Scaling factor – including sample data measurement uncertainty 

• Uncertainty in the mean scaling factor 

• Drum-to-drum variations in the scaling factor

A general treatment of TMU for this waste stream is presented in CCP-AK-INL-521, Revision 0, 

and Calculation Package INL-RH-105, Revision 0, Uncertainty Analysis for INL Sludge Waste. 

The principal contributors to the TMU, which was calculated by quadrature, were the 137Cs 

activity uncertainty and the total scaling factor uncertainty; the latter, also calculated in 

quadrature, having its main contributors as the uncertainties in mean scaling factor and drum-todrum variability. There were no concerns regarding the technical derivation and documentation 

of TMU for Waste Stream ID-RTC-S3000. Table 6, below, provides the TMU and its 

components at a density of 0.6 g/cm3

. 

Table 6. Total Measurement Uncertainty and Its Components 

at a Density of 0.6 g/cm3

Radionuclide 

137Cs Activity 

Uncertainty 

Total Scaling Factor 

Uncertainty Total Uncertainty

233U 27.2% 7.5% 28.2% 

234U 27.2% 3.9% 27.5%

235U 27.2% 4.1% 27.5%

238U 27.2% 2.1% 27.3%

238Pu 27.2% 3.5% 27.4%

239Pu 27.2% 8.1% 28.4%

240Pu 27.2% 6.8% 28.1%

241Pu 27.2% 10.4% 29.1%

242Pu 27.2% 5.0% 27.7%

241Am 27.2% 7.2% 28.1%

90Sr 27.2% 9.6% 28.9%

137Cs 27.2% 0.0% 27.2%

6.0 SUMMARY OF RESULTS 

Findings and Concerns 

The EPA inspection team did not identify any findings or concerns during this T1 evaluation. No 

open issues remain relative to this T1 change. 
24

Tiering Changes

Based on this evaluation, there are no changes to the AK T1 and T2 designations identified 

during the Baseline Inspection and subsequent T1 evaluations. 

7.0 CONCLUSIONS 

During this T1 change evaluation, EPA examined the addition of Waste Stream ID-RTC-S3000, 

containing four 55-gallon containers of sludge waste. Based on the results of this evaluation, 

EPA is approving the inclusion of this waste stream with the limitations discussed above. Table 

1 above identifies the tiering changes addressing RH waste streams and/or summary category 

categories at INL.
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED WASTE 

CHARACTERIZATION PROGRAM 

Specific INL RH Approval Date EPA Docket 

Number 

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

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

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

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

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

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

Tier 1 Change – Addition of Twelve Containers to Waste Stream 

ID-ANLE-S5000 and Addition of Waste Stream 

ID-HFEF-S5400-RH 

January 2010 A-98-49; II-A4-122 

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

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

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

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

Tier 1 Change – Approval of Waste Stream IN-ID-NRF-153 October 2010 A-98-49; II-A4-136 
B-1 

ATTACHMENT B 

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION 

CCP-AK-INL-520, Central Characterization Project Acceptable Knowledge Summary Report 

for Stored Remote-Handled Transuranic Sludge Waste Reactor Technology Complex at the 

Idaho National Laboratory, Waste Stream ID-RTC-S3000 Revision 1, February 24, 2010 

DOE/WIPP-02-3214, Remote-Handled TRU Waste Characterization Program 

Implementation Plan, Carlsbad, New Mexico, U.S. DOE Carlsbad 

2. CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, Revision 0d, 2004 

CCP-AK-INL-521, Revision Number 0, Central Characterization Project Remote-Handled 

Transuranic Radiological Characterization Technical Report For Remote-Handled Transuranic 

Waste From Idaho National Laboratory’s Test Reactor Area Catch Tank Sludge Waste, May 12, 

2010 

CCP-AK-INL-522, Revision Number 1, CCP RH TRU Waste Certification Plan for 40 CFR 194 

Compliance and Confirmation Test Plans for INL Waste Stream ID-RTC-S3000 , Carlsbad, New 

Mexico, Washington TRU Solutions, LLC, May 21, 2010

CCP-AK-INL-525, Revision Number 0, Central Characterization Project Sampling and Analysis 

Plan for Remote-Handled Transuranic Sludge Waste from Reactor Technology Complex at the 

Idaho National Laboratory, November 20, 2009 

CCP-TP-005 Revision 18, Attachments 1, 4, 5, 6, 8, and 10, provided on July 20, 2010 

NCR No. NCR-RHINL-0200-09 Revision 1, Lot No. 1, Container Nos. TRA 88-12, TRA 88-22, 

TRA 88-32, TRA 88-11, TRA 88-31, TRA 88-43; Container TRA 88-12 has too much absorbent 

above the waste to reach the waste contents to sample, June 25, 2009 

Draft Waste Stream Profile Form for Waste Stream ID-RTC-S3000, provided September 13, 

2010 

Characterization Reconciliation Report for Waste Stream ID-RTC-S3000, provided September 

13, 2010 

Interoffice Correspondence, from C.M. Gomez to M. Sensibaugh, Acceptable Knowledge 

Accuracy Report: Transuranic Sludge Waste from Reactor Technology Complex at the Idaho 

National Laboratory Waste Stream Number ID-RDC-S3000, Lot 1, dated April 15, 2010, and 

revision provided September 8, 2010 

Qualification Cards for Hillary Neely, Scott Smith, and Mike Papp, provided September 1-13, 

2010. 
B-2 

PTS Print Outs containers 8821A/B, 8822A/B and AK Tracking Spreadsheet, provided 

September 13, 2010 

EDF-7692, Isotopic Scaling Parameters for the Reactor Technology Complex 

Catch Tank Sludge Waste, February 8, 2008 

C079 Interoffice Correspondence to C. D. Brooks, re: Disposal of MTR Hot Catch Tanks 

DES-32-86, D. E. Sheldon, November 20, 1986 

C089 Letter to Brent Satterthwaite, re: Fissile Material Loading for TRA Hot Cell Waste 

Including EPICORE Waste JCM-11-99, John C. Martin, November 29, 1999 

C090 Letter to Darris J. Bright, re: MAC Isotopes Waste Characterization 

WSB-17-97, W. Skeen Blair, November 17, 1997 

C091 Interdepartmental Communication to S. W. Blair, re: RML Gamma-Ray Analysis of 

MACI Hot Cell Waste Box 4’x4’x4’ RKM-002-97, R. K. Murray, August 27, 1997 

C094 Letter to Dr. W. R. Young, re: EPICOR-II Liner TRU Analysis KCS-63-84, K. C. 

Sumpter, March 23, 1984 

C095 Interoffice Correspondence to J. G. Dineen, re: EPICOR-II NRC Waste Classification 

Calculations for Liner #27 SEM-11-90, S. E. MacLeod, April 2, 1990 

C104 Letter to John W. McConnell, re: Resin Analysis Results MDA-27-84, M. D. Anderson, 

March 22, 1984 

C105 Interoffice Memorandum to J. A. Van Vliet, re: Request for RRWAC Exemption for 

Disposition of TRA Hot Cell Waste RRP-99-15, R. R. Piscitella, December 2, 1999 

C106 Letter to J. D. Griffin and M. S. Litus, re: Pollution Prevention/Waste Minimization 

Proposal MEP-28-98, M. E. Patrick, February 12, 1998 

C123 Transuranic Waste Profile Statement Approval DRW-01-90, D. R. Wilkinson, January 4, 

1990 

C129 TRA Waste Sludge Excluded from FMCA Requirements DES-09-88, D. E. Sheldon, 

March 18, 1988 

C133 TRA – MTR, No Author, undated 

C136 Interview of Kirk Winterholler, Brett Welty, and Doug Collins of the RTC VCO Project 

conducted by Mike Papp and Scott Smith, “TRA-630 Catch Tank System and TRA-613 Hot 

Waste System,” Mike Papp and Scott Smith, February 20 and 21, 2007 
B-3 

C137 Interview of John Baker, RTC Radiological Laboratories, re: Alpha and Radiochemistry 

Laboratory Operations with attachments: 1) e-mails between John D. Baker, Vince E. Daniel, 

Mike Papp, and Scott Smith re: Chemicals; and 2) selected pages from C138 Sludge letter NA, 

Jim Schoen, undated 

C138 Calculation of Individual and Total Radionuclide Masses for Waste Stream # ID-RTCS3000, Jim Schoen, September 4, 2007 

C145 Interview with Richard S. Cain (RTC Hot Cell Facility), Tony Jones (Hot Cell Operator), 

John C. Martin (DOE Idaho), Steven K. McClaskey (CWI WGS), and Todd Morris (Manipulator 

Operator), re: RTC Hot Cell Facility Operations, Scott Smith and Mike Papp, July 26, 2007 

C155 Interview with Mike Huyck, re: Management of Sodium Bonding and Target Materials 

NA, Mike Papp, September 27, 2007 

C252 Memorandum to Irene Quintana from J.Holderness, Analysis of Sample Data for RH TRU 

Waste Stream ID-RTC-S3000, February 21, 2010 

C253 Freeze File Changes, CCP-AK-INL 520 and 522, provided September 23, 2010 

DR004 Waste Stream ID-RTC-S3000, Absorbent in Sludge Drums, Scott Smith, January 5, 2010 

P001 Hazards Evaluation of Proposed Site for ETR-II (now designated ATR) 

IDO-16623 D. R. deBoisblanc, R. J. Nertney, L. H. Jones, August 18,1960 

P002 Operating Manual – MTR Hot Cell PTR-293, H. T. Watanab,e April 10, 1958 

P007 Materials Testing Reactor Operating Manual, Volume III, Contaminated Air Effluent and 

Water Disposal Systems CI #1064, R. J. Ambrosek and A. L. Kologi, October 1, 1967 

P009 Engineering Design File, Voluntary Consent Order Tank System TRA-004 – TRA Hot 

Waste Management System Characterization, EDF-5160, D. P. Collins and M. D. Clark, May 

16, 2005 

P011 HWMA/RCRA Tank System Closure Plan for the Test Reactor Area Catch Tank System 

(TRA-630), Voluntary Consent Order Action Plan VCO-5.8.d DOE/ID-10823 

Idaho National Engineering and Environmental Laboratory Voluntary Consent Order Program, 

March 2005 

P014 System Identification for the Test Reactor Area Catch Tank System (TRA-630), 

Voluntary Consent Order Action Plan VCO-5.8.d INEEL/EXT- 2000-0801, Idaho National 

Engineering and Environmental Laboratory Voluntary Consent Order Program, 

March 2005 

P015 Engineering Design File, Voluntary Consent Order Tank Systems Characterization for 

TRA-007 – TRA/MTR Warm Waste System and TRA-010 – TRA Warm Waste Treatment 

System EDF-2749, June 10, 2004 
B-4 

P017 Engineering Design File, Voluntary Consent Order Tank System TRA-011 – TRA 

Retention Basin System Characterization EDF-1996, D. P. Collins and M. D. Clark, April 20, 

2005 

P021 Voluntary Consent Order SITE-TANK-005 System Identification, TRA Hot Waste 

Management System (TRA-004), Book 3-TRA, Volume I INEEL/EXT- 2000-00037 

Idaho National Engineering and Environmental Laboratory Voluntary Consent Order Service 

Team, March 2005 

P027 Voluntary Consent Order SITE-TANK-005 System Identification, TRA Warm Waste 

Treatment System (TRA-010), Book 3-TRA, Volume I INEEL/EXT- 2000-00037, Idaho 

National Engineering and Environmental Laboratory Voluntary Consent Order Program 

September 2001 

P028 Voluntary Consent Order SITE-TANK-005 System Identification TRA Retention Basin 

System (TRA-011), Book 3-TRA, Volume I INEEL/EXT- 2000-00037, Idaho National 

Engineering and Environmental Laboratory Voluntary Consent Order Program, 

June 2003 

P054 Defense-Related Waste Determination for Legacy Transuranic Waste at the Idaho 

National Laboratory Test Reactor Area Warm and Hot Waste Systems ICP/EXT-04- 

00729, Idaho Completion Project April 2005 

P055 ETR Hazards Survey for WAPD M-13 Experiment IDO-16503 R. L. Gump, undated 

P056 ETR Operations Branch Progress Report for Cycle No. 88, March 13, 1967 – April 24, 

1967 IN-1092, E. H. Smith, et al., June 12, 1967 

P071 National Reactor Testing Station, U.S. Atomic Energy Commission NA, U.S. Atomic 

Energy Commission, July 1967 

P074 TRA-730 Catch Tanks and Hot Cell Effluent Collection Project Plan 

NA, J. L Sherick, December, 1997 

P088 NMEO South Operating and Maintenance Manual General Facility, 1.1.1 – TRA Hot Cell 

Facility NA, Not Given, July 14, 1986 

P092 LMITCO Internal Procedure, Radiation Measurements Laboratory (RML) Gamma-Ray 

Analysis of TRA-730 Materials Test Reactor (MTR) Catch Tanks EMS-086-98 

INEEL/INT-99- 00190, T. C. Sorensen and J. W. Rogers, February 1999 

P093 Health and Safety Plan for the HWMA/RCRA Closure of the Test Reactor Area Catch 

Tank System (TRA-630) INEEL/EXT- 01-00720, M. F. Nielsen, D. H. Hovis, and K. D. 

Sessions, June 2001 

P098 Test Reactor Area’s Maintenance Implementation Plan as Required by DOE 
B-5 

Order 4330.4A, undated 

P113 NMEO South Operating and Maintenance Manual General Facility Information, 1.1.1 – 

TRA Hot Cell Facility, Jay N. Davis, July 14, 1986 

P115 Operation and Maintenance Manual, TRA Hot Cell Facility Description, February 2, 1981 

P151 Engineering Design File, TRA Rad Waste System Modifications AEDL-619, Ed Anderson, 

May 15, 1997 

P154 TRA-632 Hot Cell 1 Radionuclide Source Inventory as of August 2003, 

EDF-4064, J. L. Lopez, September 2, 2003 

P159 Hazard Assessment Document Activity-Specific Hazard Categorization Hazard 

Categorization for the TRA Hot Cell Waste Boxes, HAD-126, S. L. Silberman, September 2001 

P208 MTR Hot Catch Tank Cleanup Procedure, September 29, 1987 

P209 Amended System Identification for the Test Reactor Area Catch Tank System (TRA-630), 

Voluntary Consent Order Action Plan VCO-5.8.d ICP/EXT-04-00320, Idaho Completion 

Project, November 2004 

P211 TRA Standard Maintenance Procedure, MTR Hot Catch Tank Cleanup 2.1.16, Not Given, 

November 20, 1987 

P234 Evaluation of Closure Options for the Transuranic-Contaminated Components 

Associated with the TRA-630 Catch Tank System, Voluntary Consent Order Action Plan 

VCO-5.8.d RPT-351, Idaho Cleanup Project, March 2007 

P236 Engineering Design File, Isotopic Scaling Parameters for the Reactor Technology 

Complex Catch Tank Sludge Waste EDF-7692, Yale D. Harker, February 8, 2008 

U002 TRA Outer Area Operating and Maintenance Manual OMM-7.11, ATR Operations 

Branch Manager, November 8, 1979–1982 

U032 EG&G Idaho, Inc. Experiment Log NA, D. Conley, October 6, 1980 to October 27, 1980 

U043 TRA Hot Cell Facility Business Plan, Strategy for Continued Operations, undated 

U046 Radiation Measurements Laboratory (RML) Gamma-Ray Spectrometry Summary Report, 

2x2x2 Combustible Box NA, Not Given, August 20, 1997 

U047 Hot Cell Epicor Waste Characterization, undated 

U052 Tank History, undated 

U060 Waste Minimization, Pat Stephens, 1993 
B-6 

U064 Mission Need Document for the TRA Lab Effluent Project NA, Bill Richardson and 

Lannie Workman, March 25, 1998 and May 19, 1998 

U073 USQ Safety Evaluation, Lead Retrieval from TRA Waste Vault 01-USQ-SAR- 103-005E, 

J. B. Walker, undated 

U076 Incident Report, Idaho Nuclear Corporation, BNW P-7-2 Fission Break 

INC-69-2, Ralph E. Fearnow, December 22, 1968 

U093 An Environmental Evaluation for the Test Reactor Area Catch Tank Upgrade, 

Environmental Sciences, Earth and Life Sciences Branch, October 1984 

U115 MTR Catch Tank Transuranic Waste Data, W. Kanady, January 4, 1990 

U116 Alpha Analysis of Sludge from MTR Storage Tanks, C. W. Sill, September 12, 1986 

U117 Packet of documents concerning the sludge in the MTR Catch Tanks 

NA, August 15, 1986 to January 4, 1990 (not inclusive) 

CCP-AK-INL-521, Central Characterization Project Remote-Handled Transuranic Radiological 

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

National Laboratory’s Test Reactor Area Catch Tank System, Revision 0, May 12, 2010 

CCP-AK-INL-520, Central Characterization Project Acceptable Knowledge Summary Report 

for Stored Remote-Handled Transuranic Sludge Waste From Reactor Technology Complex at 

the Idaho National Laboratory, Waste Stream: ID-RTC-S3000, Revision 1, February 24, 2010 

U240, CCP Calculation Package – Radiochemistry & Gamma Spectrometry Data Input Check, 

Revision 0, INL-RH-101, Jene Vance, April 09, 2010 

U241, CCP Calculation Package – Cs-137 Scaling Factor Development, Revision 0, INL-RH102, Jene Vance, April 09, 2010 

U242, CCP Calculation Package – Determination of INL TRA Sludge Reportable Radionuclides, 

Revision 0, INL-RH-103, Jene Vance, April 09, 2010 

U243, CCP Calculation Package – INL Cs-137 Dose-to-Curie Correlation- TRA Sludge, 

Revision 0, INL-RH-104, Jene Vance, April 09, 2010 

U244, CCP Calculation Package – Uncertainty Analysis for INL Sludge Waste, Revision 0, INLRH-105, Jim Holderness, April 09, 2010 

U245, CCP Calculation Package – DTC Spreadsheet INL Sludge Waste, Revision 0, INL-RH106, Jim Holderness, April 09, 2010 
B-7 

DTC BDR No. INLRHDTC10009, dated June 7, 2010, containing DTC results for containers 

IDIRTRA8821A, IDIRTRA8821B, IDIRTRA8822B and IDIRTRA8822B 

Analysis of Sample Data for RH TRU Waste Stream ID-RTC-S3000, memorandum from J. 

Holderness to Irene Quintana dated February 21, 2010