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 P ROGRAM

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 2010i 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-H andled Waste

Characterization Program Attachment B: Listing of Documents Reviewed for Th is Evaluationii 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/cm 3 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 spectromet ryiii

ID Idaho

INEEL Idaho National Environmental and Engineering Laboratory

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Cent er
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 Manageriv

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 yttrium1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of an additional remote-handled (RH) transuranic (TRU) sl udge (S3000) waste stream from the Department of Energy’s (DOE) Idaho National Laborat ory (INL). Specifically, this approval supports the addition of Waste Stream ID-RTC-S3000.

On February 8, 2010, the Carlsbad Field Office (CBF O) 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 a t INL using the system of controls, which EPA evaluated during the baseline inspection conduc ted in July 2006 and approved in January 2007. A summary of EPA’s approvals of the INL-CCP R H 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 o f 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 concern s during this evaluation. No open issues remain relative to this change. EPA did not identif y any new T1 or Tier 2 (T2) changes during
the course of this evaluation. Table 1 below identi fies tiering changes that are applicable to the RH waste at INL. EPA determines that the EPA-approv ed 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 containers 1 from Waste Stream ID-RTC-S3000 to INLCCP’s RH baseline approval as a T1 change. The T1 a pproval 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 d ifferent 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 s tream, 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 th eir radiological and physical contents.2Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised November 1, 2010)RH Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH Process - T2 Changes2Acceptable Knowledge (AK)Addition of containers to approved waste streams ifnew ordifferent radionuclide scaling factors or a different radiologicalcharacterization process are requiredAny new RH waste streams not approved to dateSubstantive modification(s) that have the potentialto affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL501, or CCP-AK-INL-502Load management for any RH waste streamNotification to EPA when updates to AK Summary Reports(AKSRs), Radiological Characterization Reports, andConfirmationTest Plans (e.g., CCP-AK-INL-500, CCP-AK-INL-501, and CCPAK-INL-502) are approved by CBFONotification to EPA when changes to AK documentation as a resultof Waste Characterization Program Implementation Plan (WCPIP)revisions have been made (e.g., Characterization ReconciliationReports (CRRs))Notification to EPA when a Correlation or SurrogateSummaryForm is completed for each of the RH containers inthis wastestream identified as contact-handled (CH), based upon measureddose rates that present nondestructive assay (NDA)results forassayed containersNotification to EPA once waste stream data packagefor debriswaste stream and any modifications to the Waste Stream ProfileForm (WSPF), including the CRR and AKSR, are completedNotification to EPA that the final dose-to-curie (DTC)determination is complete for RH containers 728 through 737, asidentified in AK Reference P030AK accuracy reports (prepared annually, at a minimum)Notification to EPA when additional containers areadded to RHTRU debris or sludge waste streams that have been approved to dateand the containers were characterized using the same radionuclidescaling factors*Notification to EPA of availability of a revised AKSR and sourcedocuments supporting the addition of containers tothe approvedwaste streams*Notification to EPA when Attachment 4 of CCP-TP-005isgenerated to reflect the updated AKSR Source Document ReferenceListNotification of availability of additional discrepancy resolutionspertinent to Waste Stream IN-ID-NRF-153Radiological Characterization, including DTCApplication of new scaling factors for isotopic determinationother than those documented in CCP-AK-INL-501Notification to EPA upon completion of revisions ofCCP-AK-INL501 or CCP-TP-504 that require CBFO approval3Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised November 1, 2010)RH Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH Process - T2 Changes2Use of any alternate radiological characterizationprocedureother than DTC with established scaling factors asdocumentedin CCP-TP-504 or substantive modification of the DTCprocedureUse of any alternate gamma detector with the OSPREYTMsystem characterization procedure other than the La3Br(Ce)detector observed in July 2010Any new RH waste stream not approved to date or theadditionof containers to an approved waste stream that requireschanging the established radionuclide scaling factors orradiological characterization processNotification to EPA of availability of a revised radiologicalcharacterization report, if required for the addition of containers tothe approved waste streams*Radiological content data provided in batch data reports (BDRs) forthe population of additional containers*Visual Examination (VE) VE using audio/video mediato characterize additional debrisor sludge waste streams other than those approved to dateNotification to EPA upon completion of changes to VEprocedure(s) that require CBFO approvalPhysical content data provided in BDRs for the population ofadditional containers*Real-Time Radiography (RTR) Any new RH debris or sludge waste stream not approved todateNotification to EPA prior to addition of a new RTRunit(s)Notification to EPA upon completion of changes to RTRprocedure(s) that require CBFO approvalPhysical content data provided in BDRs for the population ofadditional containers*WIPP Waste Data System (WDS) (previouslyknown as WWIS)NoneChanges made to WDS procedure(s) that require CBFOapprovalNotes:- This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 or T2 element is discussed.- INL-CCP will report all T2 changes to EPA everythree months.- Notification to EPA is not necessary when document updates are editorial in nature or are requiredto address administrative concerns.-Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., theuse of an inherently different type of measurementinstrument 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 using the same radionuclide scalingfactors or radiological characterization process aswere used to characterize the original approved waste stream. Unlike the other T2 change submissionsdone on a quarterly basis,EPA notification is required when the site identifies the need to characterize additional containers belonging to the approved waste stream. In addition,when available, CBFOmust submit revised AKSR, new or revised source documents, and radiological, VE/ RTR BDRs, and other pertinent information documenting addition of containers to EPA forreview.4

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes to the waste characterization activ ities 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 Attachmen t A.

Under the changes to 40 CFR 194.8 promulgated in th e 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 4 2571–42583, 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 a pplicable 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 authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1), and those re quiring post-implementation (T2) notification, are identified in the site-specific b aseline 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 q uarterly basis, and EPA may conduct continued compliance inspections to evaluate implem ented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of T1 changes to 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 evalua tion are listed at the end of the report. Any of these documents can be requested from the fo llowing:

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 consisti ng of four 55-gallon drums.5

The evaluation of this waste stream included two wa ste characterization areas: AK and radiological characterization. Table 2 lists partic ipants 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 Ch aracterization, 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 Ma tter Expert, CCP James Holderness Radiological Characterization Subj ect 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 ino rganic sludge waste generated during the remediation and removal of the four Building TR A-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 o ut and replaced with the current tank vault (TRA-730) and four new tanks (TRA-730-1, -2, -3, an d -4). The sludge from three of the TRA630 tanks was determined to be low-level waste; how ever, 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 origina ting 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-8 8-22A and TRA-88-22B) that were then placed into 55-gallon-drum overpacks, resultin g in a waste stream of four 55-gallon drums. These four drums constitute the scope of this T1 ev aluation. The waste is primarily contaminated with fissile materials and mixed fission products ( MFP), with the predominant radionuclides by mass being uranium-235 ( 235 U) and uranium-238 ( 238 U). The majority of the drums’ gamma activity is from cesium-137 ( 137 Cs), cobalt-60 ( 60 Co), americium-241 ( 241 Am), and europium-154 ( 154 Eu).

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 r eview, confirmatory testing, or demonstration of data acquisition under an equivalent quality ass urance (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 inf ormation when defining the isotopic ratios, physical form, and absence of residual liquids asso ciated 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 137 Cs scaling factors that were applied to the four 55 -gallon drums. The6

radiological sampling and analyses data were not us ed 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 s ubsequent dose to curie (DTC) measurements. However, visual exam (VE) data were obtained and us ed 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 Att achment 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 informat ion to approve the T1 request for RH

Waste Stream ID-RTC-S3000.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the followi ng 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 nuclea r fuel

• AK documentation and assembly of required informati on, 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, a nd Certification Plan/Confirmation Test Plan (CTP) preparation/adequacy

• Waste Stream Profile form (WSPF) and CRR adequacy7

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

• Personnel training

• Nonconformance reports (NCRs) and AK discrepancy re solution 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 res pect to waste stream definition and was found to be adequate.

The WCPIP, Revision 0, defines a waste stream as co nsisting of “waste material generated from a single process or activity, or as waste with simi lar physical, chemical, and radiological properties.” EPA evaluated the waste stream against this definition to determine whether the processes and activities associated with waste gene ration were adequately addressed, and to determine whether the physical, chemical, and radio logical 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 wastewat er from the Materials Test Reactor (MTR) in Building TRA-603, the Radiochemistry Labor atories and the Vent Scrubber (TRA604), the RTC Hot Cells (TRA-632), the Reactor Serv ices Building (TRA-635), and the laboratories in the Alpha Wing (TRA-661). Wastewate r from these areas was routed to the CTS, which in turn discharged to other wastewater treatm ent 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 orig inal 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 re actor 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 reconfigure d 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 va lves 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 contamina tion between the catch tanks (C253).

EPA evaluated radiological data to see if they supp ort 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 waste8

sludge and developed scaling factors from the analy tical data. Data from the three catch tank sampling events show relatively good correlation an d 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 radi ological composition of the current waste

stream.

When taken as a whole, the AKSR, Radiological Chara cterization Report, Certification Plan, and source document references (e.g., C252) did not pre sent 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 in dicate the two drums originated only from Catch Tank 2 (e.g., C252). However, INL-CCP submitt ed freeze file 2 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 radio logical 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 repack aged into four drums. Also, the drums contained sludge sourced from Catch Tank 2, as disc ussed in CCP-AK-INL-521 and reference C252. Therefore, this approval is limited to the ap proximately 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 adequatel y defined. EPA concluded that the AKSR will be sufficient upon inclusion of the revision a nd expects a formal revision of the AKSR to be completed prior to INL-CCP’s first quarter 2011 sub mission of T2 changes to EPA for review and concurrence. Notification of changes to the AKS R 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 containe rs to the waste stream beyond the four repackaged 55-gallon drums from Catch Tank 2 is a T 1 change.

(2) The radiological characteristics of the waste s tream 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 rad iation 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 ta nk 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 replac ed in 1987–1988, and wastes from the replacement tanks were sampled in 1999 and 2002 (P0 92, 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 revis e documents to address EPA issues, CCP makes those changes and provides a copy to EPA as objecti ve evidence for the changes made. These revisions a re then processed by CCP’s document control process to gene rate an official version as the most current revisi on.9

Tanks 1–4 as a whole, so INL-CCP used the older dat a to generate the estimated radiological distribution for Waste Stream ID-RTC-S3000 presente d in Table 6 of the AKSR. The two predominant radionuclides by weight are 235 U and 238 U, and the two predominant radionuclides by activity are 137 Cs and 60 Co. Over 95 percent of the total activity in the wa ste stream is from

137 Cs, 60 Co, 241 Am, and 154 Eu. EPA concludes that the radiological information obtained by sampling the Catch Tank 2 containers reflects the c omposition 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 w ere examined, including the presence of prohibited items (liquids), and found to be adequat ely 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 de termined that the waste consists predominantly of homogeneous inorganic solids, but it may also contain limited amounts of heterogeneous debris generated during sludge remedi ation, including cellulosics (e.g., the filter socks themselves, wipes, personal protective equipm ent), plastics (e.g., hose, rope, sheeting, tape), rubber (e.g., gloves), and glass (e.g., samp le bottles). Sorbent was added to the waste when it was originally packaged in 1987 for liquid adsor ption (C123, C129, DR004, C133, P208, and P211), and the waste stream was assigned Waste Matr ix Code (WMC) S3120, Inorganic Sludges.

INL-CCP estimated the waste material parameter weig hts for the waste stream based on Fast Scan RTR records (U152) performed in 2008, which sh owed 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 ta blespoons liquid, and drum 88-22 contained one cup of liquid; No-Char was added as a sorbent t o 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, a nd 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 n uclear fuel or high-level waste. This freeze10

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 fiss ionable material irradiated for research and development only, and not production of power or pl utonium, 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 s eparate 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 n uclear fuel, including liquid waste produced directly in reprocessing and any solid material der ived from such liquid waste that contains fission products in sufficient concentrations, and other highly radioactive material that the Commission, consistent with existing law, determine s by rule requires permanent isolation.”

INL-CCP concluded that Waste Stream ID-RTC-S3000 co nsists of materials that originated from test reactors that were operated for research and d evelopment (R&D) purposes only. For example, the MTR was a test reactor that operated f or R&D only and contributed contamination to Catch Tank 2 sludge directly in the form of cont aminated cooling or decontamination water. Further, wastes generated from laboratory or hot ce ll operations with irradiated fuel or sample materials were also considered to be test samples o r 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 operat ions contributing wastewater to the CTS involved reprocessing of constituent elements from reactor fuel. INL-CCP cited several references (C079, C136, C137, C145, P002, P011, P05 4, P071, P088, and P098) that document the activities of the hot cells, laboratories, reac tor use, and tank remediation. Reference C136 is an interview with three INL employees who are famil iar with generation of the TRA sludge. The individuals indicated that “[none] of the waste gen erated 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 w ith liquid wastewater inputs to the CTS or HWS. The only irradiated fuel processing/handling i n 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 Summar y Report and implementation of the Acceptable Knowledge process were evaluated and fou nd 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 dr ums that originated from Catch Tank 2 and did not provide sufficient detail about the fuel pin or igin, pin testing, and potential generation of spent nuclear fuel and high-level waste. INL-CCP pr epared a freeze file modification (C253) that better explained waste flow, as well as why the was te stream now contains only four drums11

originating from two Catch Tank 2 drums. The freeze file mentioned above also better justifies the spent nuclear fuel and high-level waste exclusi ons, as required under the LWA. With the proposed modifications, the AKSR is adequate. See i tem (1), above.

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

The traceability of radiological data from the orig inal drum records through various RTR activities and subsequent repackaging VE was evalua ted for the two original Catch Tank 2 drums, as presented below in Table 4. INL-CCP state d 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, repackagin g, and VE. Drums were tracked using the site Integrated Waste Tracking System (IWTS) (U 175) and are currently tracked in INLCCP’s Project Tracking System (PTS). EPA concluded that data traceability was adequate.

(7) Sufficiency of Acceptable Knowledge support do cuments 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 TRA88-22B12

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 ot her references will be updated. For example, the FRM-880s relevant to repackaging are to be adde d to the reference list, and reference U152 is to be updated. EPA expects the AKSR and Attachme nt 4 to be updated to include all relevant references, including any references cited within C CP-AK-INL-521. The AKSR reference list will be updated in conjunction with text modificati ons [see item (1), above]. Notification of availability of updates to Attachment 4 remains a T 2 change, as stated previously in the INL RH baseline inspection report.

(8) Interpretation of the Waste Characterization Progra m Implementation Program, with respect to contents of the Certification Plan and t he Confirmatory Test Plan, was evaluated and found to be adequate, including manda tory content and the use of sampling
data.

EPA’s March 26, 2004, RH WCPIP letter indicated tha t sites must generate a Certification Plan that explains how RH waste characterization will ta ke place at each site, as well as a CTP when this plan is required as part of the AK qualificati on process. EPA intended that the sites specify and document exactly how characterization is to tak e place on a waste stream basis, followed by a detailed plan explaining implementation of confir matory testing when this is to take place.

CCP-AK-INL-522, Revision 1, explains that INL-CCP i ntended to use a combination of methods to qualify the AK information defining the radionuc lide 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 it ems will be qualified using either radiography or VE, which will also be used to deter mine that packaging DQOs are met. Prescreening with radiography has identified liquid s, 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, establi shment 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 ef fort designed to characterize the two drums that were included in the sampling program. While t he 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 analy tical 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 s ample population size. The sludge sampling plan (CCP-AK-INL-525, Revision 0 or SAP) was prepar ed 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 collecte d were representative of the two Catch Tank 2 drums, and EPA agrees with this determinatio n.

Although not directly referenced in the Certificati on Plan, results of the sample analyses were summarized and interpreted in reference C252, which presents an extensive evaluation of the13

analytical data, as discussed in detail in Section 5.2. Reference C252 concluded that sampling was executed in accordance with the SAP, and the sa mples were representative of the two original drums and provided an adequate basis for t he 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-IN L-522, Revision 1, with respect to how the waste stream was presented and how radiological cha racterization was to be accomplished. INLCCP addressed these concerns through freeze file mo difications. 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, R evision 1; CCP-AK-INL-525, Revision 0; reference C252; CCP-AK-INL-520, Revisio n 1; the freeze file change (C253); and the supporting source documents indicate that the D QOs, as specified in the WCPIP, have been
met. EPA finds that CCP-AK-INL-522 will be sufficie nt upon inclusion of the revisions and expects a formal revision of this document be compl eted 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 i nspection purposes only, without the required signatures or attachments. The document wa s 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 bet ween source documents and references about
the different catch tank sources for the waste stre am, and because the sampling clearly applies to the two drums (repackaged into four) from Catch Tan k 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 basel ine 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 W aste Acceptable Knowledge Characterization Reconciliation Report . Specifically, EPA evaluated the CRR to determine the completeness and adequacy of its contents, as requi red in the WCPIP, and found it to be adequate. The CRR addresses only the four container s originating from Catch Tank 2. Notification of availability of a final and/or revi sed CRR remains a T2 change, as stated previously in the INL RH baseline inspection report

.

(10) Use of a Correlation and Surrogate Summary Fo rm was evaluated and found to be adequate.

Completion of a Correlation and Surrogate Summary F orm (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 thi s 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 e xpert (AKE)], Mike Papp (who authored several source documents), and Hillary Neely (site project manager). Jim Holderness prepared the sampling memorandum, and Jene Vance prepared th e Radiological Characterization Report; while both interpreted AK data, their training reco rds were examined as part of EPA’s radiological characterization analyses. EPA reviewe d 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 requirem ents, nor that they are trained with respect to radiological characterization aspects, both of w hich 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 docum entation that all AKEs and other individuals who prepared, edited, contributed to, o r signed off on AK-related documents have up-to-date training on the WCPIP and its requiremen ts, as well as related AK procedures.

(12) Non-conformance Reports and Discrepancy Resol ution 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 o f waste, which was not included in the AK record. Notification of the availability of additio nal DR Forms pertinent to this waste stream is a T2 change, as stated previously in the INL RH basel ine inspection report.

INL-CCP provided a single example NCR. NCR-RHINL-02 00-09 was issued because Container TRA-88-12 had too much absorbent above the waste, s o that waste contents could not be reached for RCRA sampling. The BDRs provided did not includ e any NCRs.

Preparation of NCRs and DR Forms was adequate.

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

The AK accuracy report for Waste Stream ID-RTC-S300 0, Lot 1, consists of four RH TRU containers. The AKSR did not include any radiologic al comparisons based on INL-CCP sampling because INL-CCP chose not to use these dat a to qualify AK. INL-CCP contends that comparison of AK data against measurement informati on is not required when the measurement
data are not used to confirm AK. While not the inte nt of the WCPIP, the WCPIP (Revision 0d) uses the term “confirmation” in the AK accuracy sec tion, so EPA will not require revision of the AK accuracy report. However, the WCPIP has been rev ised, and EPA will examine this document with respect to this interpretation and th e intended comparison in forthcoming inspections under the new WCPIP. Any revision of th e AK accuracy report remains a T2 change, as stated previously in the INL RH baseline inspect ion report.

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

The WIPP requires generator sites to use AK to dete rmine that a TRU waste stream meets the definition of TRU defense waste. TRU waste is eligi ble 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 ref erences 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 mater ials and was used for experiments related to the U.S. Navy, Army, and Air Force. Research perfor med at RTC-sourced facilities included defense-related Hanford fuel element design and per formance (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 Catc h Tank 2. These include, but are not limited to, the following:

• Samples for Westinghouse in support of the developm ent, design, and construction of the submarine thermal reactor (STR), later named S1W, a land-based prototype water-cooled reactor power plant suitable for submarine propulsi on. The STR was located at the Naval Reactors Facility (NRF) and was the prototype react or for the USS Nautilus

.

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

• Knolls Atomic Power Laboratory L-42, an experimenta l loop related to R&D of nuclear propulsion for the U.S. Navy.

The AKSR also states that the RTC Hot Cells provide d examination of fuels from a variety of
defense-related sources and included fuel examinati on 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). Exa mples of defense-related Hot Cell work include the following:

• Gas-Cooled Reactor Experiment Fuel Specimens Identi fied in Hot Cell #2 Logbook from May 1961 to January 1963. Work included labeling, e tching, hardness testing, and photographing.

• Bettis Atomic Power Laboratory Target Fabrication L ine 3&6 16700-510-804. Identified in Hot Cell #2 Logbook from March to April 1978. Wo rk 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 fo r disposal at the WIPP as a commingled16

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

(15) Load management was assessed and determined n ot 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 chan ge, 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 adequat e.

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 a ddressed as per the WCPIP:

• Defense determination

• TRU waste determination

• RH waste determination

• Activity determination (total and activity per cani ster, including quantification and
identification of the 10 EPA WIPP-tracked radionucl ides)

• Residual liquids

• Physical form, including metals and cellulose, plas tic 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 sour ce 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 findin gs 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 t he AK T1 and T2 designations identified during the Baseline Inspection and subsequent T1 ev aluations.

Conclusions

Based on the results of this evaluation, EPA is app roving the T1 request for Waste Stream IDRTC-S3000, with the limitations discussed previousl y.17

5.2 Radiological Characterization

EPA examined the radiological characterization proc ess and associated information to determine whether INL-CCP demonstrated compliance with 40 CFR194.8 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 techn ique that EPA has observed and approved at several RH TRU sites previously. However, the absen ce of detailed information on the materials examined and the potential for the separation of 137 Cs in wastewater prevented the development
of 137 Cs-based scaling factors using ORIGEN as has been d one for other wastes. Specifically, there was a potential depletion of 137 Cs because of its greater solubility relative to th e other reportable radionuclides, considering that water wa s used in removing the sludge from the tanks. Instead, sample collection and analysis were the on ly viable methods and the radionuclides of interest in each sample were identified and quantif ied by radiochemistry and mass spectrometry. A single set of 137 Cs-based scaling factors was developed for the radi ological characterization of
the waste stream.

An overview of the radiological characterization pr ocess 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 radionuclides18 Figure 1. Flow Diagram of the Radiological Charact erization Process,

Waste Stream ID-RTC-S3000

Documents Reviewed

To support this T1 evaluation, EPA examined the doc uments related to the INL-CCP RH TRU radiological characterization program listed in Att achment 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 d ocuments, procedures, and controls, and the knowledge and understanding of the personnel involv ed in the RH waste characterization program. During this T1 evaluation, EPA examined th e 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 ino rganic 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-88-2 1. The physical condition of the waste and the sampling method employed (collecting two sc oops of sludge from each drum) resulted in representative samples from the sludge waste. The s ampling and the analysis of sample data are explained in a memorandum from J. Holderness to Ire ne Quintana, dated February 21, 2010, as listed in Attachment B to this report. The sampling analysis results were used to determine the

137 Cs-based scaling factors for the five samples. The scaling factors correlate a waste drum’s
measurable 137 Cs gamma dose and waste density to quantify specifi c radionuclides in each of the four repackaged waste drums. These activities are d ocumented in the sample-specific calculation packages listed in Attachment B. The development of the 137 Cs-based scaling factors was supported by the following sources of information:

• Radiochemistry and mass spectrometry measurements m ade on all of the samples

• Scaling factors obtained from the sampling results

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

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

• Associated uncertainty for all values listed in pre vious bullet19

• Plutonium equivalent curies (PE Ci)

• Decay heat in watts

• Fissile gram equivalent (FGE)

The constants and other values required for these c alculations 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 us ing MicroShield ® with the 1-curie source of

137 Cs uniformly distributed throughout a 55-gallon was te 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/cm 3 to 1.8 g/cm 3 in increments of 0.2 g/cm 3 . The
results were then used to derive a DTC correlation as a function of density for 137 Cs, 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 foll owing:

• 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 metri cs using the mean and standard
deviation values for each radionuclide

• Adequacy of the number of samples for the homogeneo us waste

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

• Isotopic activity values are correlated to the radi onuclides whose physical half-lives are such that they could be responsible for the measure d external dose rate (i.e., 137 Cs for the Waste Stream ID-RTC-S3000)

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

• Compliance with the INL-CCP procedure for dose meas urements (CCP-TP-504, Revision 9)

• Activity and uncertainty values determined for the 10 WIPP-tracked radionuclides20

• The determination of the contribution of all radion uclides to the radiological hazard 3

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

Table 5. Radionuclide-Specific Scaling Factors

Radionuclide 137 Cs-Based DTC Scaling Factor

233 U 6.82E-05

234 U 1.96E-04

235 U 1.24E-05

238 U 2.69E-05

238 Pu 8.19E-03

239 Pu 5.42E-03

240 Pu 3.94E-03

241 Pu 9.68E-02

242 Pu 5.98E-06

241 Am 2.06E-02

137 Cs 1.00E+00

137m Ba 9.46E-01

90 Sr 4.23E-01

90 Y 4.23E-01

There are no issues related to the technical adequa cy 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 wa s used for the calculations (i.e., it contained the radionuclide scaling factors that were develope d for Waste Stream ID-RTC-S300 contained in INL-RH-106 and Table 5, above). There were no is sues related to the DTC correlation and its
documentation for Waste Stream ID-RTC-S3000.

(4) Technical aspects and documentation of the rad iological 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. Th is 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-52 1. EPA found that the calculation packages cited above adequately supported the activ ities 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 as pects of a container’s radiological characterizatio n.21

characterization of the four drums in Waste Stream ID-RTC-S3000 was based. There were no
issues related to the documentation of technical as pects of the INL-CCP radiological characterization approach for the four drums in Was te Stream ID-RTC-S3000.

(5) The laboratory radiochemical and Inductively Co upled 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 sa mpling 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

137 Cs, 60 Co, 154 Eu, and 155 Eu, while the only significant contributor is 137 Cs. The scaling factors derived from the sample data exhibit relatively sma ll variations that can be represented equally well with the assumption of a normal or lognormal d istribution. 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 fac tor should be less than or equal to a factor of two, evaluated at the one standard deviation level. With the exception of 241 Pu and the “colocated” sample, all of the objectives of the SAP h ave been met. The accuracy QA objective was
not met for 241 Pu since 241 Pu is not a TRU radionuclide, and the reported resu lts can be used without significantly affecting the radiological ch aracterization. The “co-located” sample, required by CBFO, did not meet the specified criter ion that scaling factors should agree to within ±25%. While this is not a problem for the radiologi cal 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 labora tory duplicates and scaling factors using the relative percent difference (RPD), defined as the d ifference 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 docum ented 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 fo r the four drums in Waste Stream ID-RTCS3000). EPA technical personnel verified that the D TC 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 222

• Waste Container DTC Conversion Records, Attachment 3, with four dose rate measurements and their average, date of measurement s and container weights

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

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

• Type of waste in each container, cement

• Fill height of the container: < 25% full, 25–66% fu ll, 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 w ere assessed and found to be adequate.

EPA examined the determinations that these containe rs meet the definitions of TRU waste and
RH waste based on DTC BDR INLRHDTC10009. Both the R H and TRU determinations are parts of the actual DTC measurements that are perfo rmed at the INTEC Facility at INL, which were not assessed directly during this T1 evaluatio n. 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., contain ed more than 100 nanocuries per gram (nCi/g) of TRU radionuclides).

• All four containers were clearly RH (i.e., had an e xternal contact dose rate greater than 200 mRem/hr) 4

.

There were no technical or documentation-related co ncerns regarding the TRU and RH
determinations for the four drums in Waste Stream I D-RTC-S3000.

(8) The technical basis and derivation of Total Mea surement Uncertainty (TMU) were evaluated and found to be adequate.

The development of TMU for Waste Stream ID-RTC-S300 0 is based on the propagation of uncertainties present in all aspects of the determi nation of the radiological constituents of RH
TRU waste. Because of the commonness of 137 Cs activity determination to all of the radionuclides, a statistical dependency is introduc ed for parameters that are summations over multiple radionuclides, e.g., TRU determination. Fo r these cases, instead of combining in quadrature that is considered for statistical indep endence, the statistical dependency is explicitly
considered. The TMU determination included contribu tions of the following:

4 The measured external gamma dose rates for the fou r containers in mR/hr were 40, 73, 55, and 29 at on e meter. When multiplied by 18 to apoproximate the co ntact dose rates, all clearly exceed 200 mR/hr base d solely on the gamma readings. Roentgens (R) and Rems (rem) ar e units of radiation exposure and dose equivalent, respectively. Although they represent different qua ntities, by convention they are often considered eq uivalent. In this report, these terms are used interchangeably, which is a conservative approach to assigning dose equiv alent in rem.23

• 137 Cs DTC correlation – including waste density determ ination (drum weight measurement, tare weight measurement, fill percenta ge estimation), MicroShield ®
modeling, and MicroShield ® code uncertainties

• 137 Cs activity measurement – including measurement unc ertainty associated with dose rate measurement at one meter and uncertainty due t o 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 ca lculated by quadrature, were the 137 Cs activity uncertainty and the total scaling factor u ncertainty; the latter, also calculated in quadrature, having its main contributors as the unc ertainties 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, belo w, provides the TMU and its components at a density of 0.6 g/cm 3

.

Table 6. Total Measurement Uncertainty and Its Com ponents

at a Density of 0.6 g/cm 3

Radionuclide 137 Cs Activity

Uncertainty Total Scaling Factor

Uncertainty Total Uncertainty

233 U 27.2% 7.5% 28.2%

234 U 27.2% 3.9% 27.5%

235 U 27.2% 4.1% 27.5%

238 U 27.2% 2.1% 27.3%

238 Pu 27.2% 3.5% 27.4%

239 Pu 27.2% 8.1% 28.4%

240 Pu 27.2% 6.8% 28.1%

241 Pu 27.2% 10.4% 29.1%

242 Pu 27.2% 5.0% 27.7%

241 Am 27.2% 7.2% 28.1%

90 Sr 27.2% 9.6% 28.9%

137 Cs 27.2% 0.0% 27.2%

6.0 SUMMARY OF RESULTS

Findings and Concerns

The EPA inspection team did not identify any findin gs 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 t he AK T1 and T2 designations identified during the Baseline Inspection and subsequent T1 ev aluations.

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 wast e. 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 R H 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 Janu ary 2007 A-98-49; II-A4-75

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

Tier 1 Change – Approval of K Cell Wastes January 2 008 A-98-49; II-A4-97

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

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

Tier 1 Change – Addition of Twelve Containers to Wa ste Stream
ID-ANLE-S5000 and Addition of Waste Stream

ID-HFEF-S5400-RH January 2010 A-98-49; II-A4-122

Tier 1 Change – Approval of Waste Stream ID-MFC-S54 00-RH June 2010 A-98-49; II-A4-126

Tier 1 Change – Approval of Waste Stream ID-INTEC-S 5400-RH August 2010 A-98-49; II-A4-130

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

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

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

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION

CCP-AK-INL-520, Central Characterization Project Ac ceptable Knowledge Summary Report for Stored Remote-Handled Transuranic Sludge Waste Reactor Technology Complex at the Idaho National Laboratory, Waste Stream ID-RTC-S300 0 Revision 1, February 24, 2010

DOE/WIPP-02-3214, Remote-Handled TRU Waste Characte rization Program Implementation Plan, Carlsbad, New Mexico, U.S. DOE Carlsbad 2. CCP-TP-005, CCP Acceptable Knowledge Documentati on, Carlsbad, Revision 0d, 2004

CCP-AK-INL-521, Revision Number 0, Central Characte rization 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 Wast e Certification Plan for 40 CFR 194 Compliance and Confirmation Test Plans for INL Wast e Stream ID-RTC-S3000 , Carlsbad, New Mexico, Washington TRU Solutions, LLC, May 21, 2010

CCP-AK-INL-525, Revision Number 0, Central Characte rization Project Sampling and Analysis Plan for Remote-Handled Transuranic Sludge Waste fr om 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, Co ntainer Nos. TRA 88-12, TRA 88-22, TRA 88-32, TRA 88-11, TRA 88-31, TRA 88-43; Contain er TRA 88-12 has too much absorbent above the waste to reach the waste contents to samp le, June 25, 2009

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

2010

Characterization Reconciliation Report for Waste St ream ID-RTC-S3000, provided September 13, 2010

Interoffice Correspondence, from C.M. Gomez to M. S ensibaugh, Acceptable Knowledge Accuracy Report: Transuranic Sludge Waste from Reac tor Technology Complex at the Idaho National Laboratory Waste Stream Number ID-RDC-S300 0, 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 T racking Spreadsheet, provided September 13, 2010

EDF-7692, Isotopic Scaling Parameters for the React or 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 Mat erial 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 W aste 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 Analysi s 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: P ollution Prevention/Waste Minimization Proposal MEP-28-98, M. E. Patrick, February 12, 199 8

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

1990

C129 TRA Waste Sludge Excluded from FMCA Requiremen ts DES-09-88, D. E. Sheldon, March 18, 1988

C133 TRA – MTR, No Author, undated

C136 Interview of Kirk Winterholler, Brett Welty, a nd Doug Collins of the RTC VCO Project conducted by Mike Papp and Scott Smith, “TRA-630 Ca tch Tank System and TRA-613 Hot Waste System,” Mike Papp and Scott Smith, February 20 and 21, 2007B-3

C137 Interview of John Baker, RTC Radiological Labo ratories, 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) se lected pages from C138 Sludge letter NA, Jim Schoen, undated

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

C145 Interview with Richard S. Cain (RTC Hot Cell F acility), Tony Jones (Hot Cell Operator), John C. Martin (DOE Idaho), Steven K. McClaskey (CW I WGS), and Todd Morris (Manipulator Operator), re: RTC Hot Cell Facility Operations, Sc ott Smith and Mike Papp, July 26, 2007 C155 Interview with Mike Huyck, re: Management of S odium 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, p rovided September 23, 2010 DR004 Waste Stream ID-RTC-S3000, Absorbent in Sludg e 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. J ones, August 18,1960

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

P007 Materials Testing Reactor Operating Manual, Vo lume 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 Ord er 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 Tes t Reactor Area Catch Tank System (TRA-630), Voluntary Consent Order Action Plan VCO- 5.8.d DOE/ID-10823 Idaho National Engineering and Environmental Labora tory Voluntary Consent Order Program,
March 2005

P014 System Identification for the Test Reactor Are a 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 Ord er Tank Systems Characterization for TRA-007 – TRA/MTR Warm Waste System and TRA-010 – T RA Warm Waste Treatment System EDF-2749, June 10, 2004B-4

P017 Engineering Design File, Voluntary Consent Ord er 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 I dentification, TRA Hot Waste Management System (TRA-004), Book 3-TRA, Volume I I NEEL/EXT- 2000-00037 Idaho National Engineering and Environmental Labora tory Voluntary Consent Order Service Team, March 2005

P027 Voluntary Consent Order SITE-TANK-005 System I dentification, TRA Warm Waste Treatment System (TRA-010), Book 3-TRA, Volume I IN EEL/EXT- 2000-00037, Idaho National Engineering and Environmental Laboratory V oluntary Consent Order Program September 2001

P028 Voluntary Consent Order SITE-TANK-005 System I dentification TRA Retention Basin System (TRA-011), Book 3-TRA, Volume I INEEL/EXT- 2 000-00037, 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 ID O-16503 R. L. Gump, undated

P056 ETR Operations Branch Progress Report for Cycl e 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 Coll ection Project Plan NA, J. L Sherick, December, 1997

P088 NMEO South Operating and Maintenance Manual Ge neral Facility, 1.1.1 – TRA Hot Cell Facility NA, Not Given, July 14, 1986

P092 LMITCO Internal Procedure, Radiation Measureme nts Laboratory (RML) Gamma-Ray Analysis of TRA-730 Materials Test Reactor (MTR) Ca tch Tanks EMS-086-98 INEEL/INT-99- 00190, T. C. Sorensen and J. W. Roger s, February 1999

P093 Health and Safety Plan for the HWMA/RCRA Closu re of the Test Reactor Area Catch Tank System (TRA-630) INEEL/EXT- 01-00720, M. F. Ni elsen, D. H. Hovis, and K. D. Sessions, June 2001

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

Order 4330.4A, undated

P113 NMEO South Operating and Maintenance Manual Ge neral 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 Invento ry as of August 2003, EDF-4064, J. L. Lopez, September 2, 2003

P159 Hazard Assessment Document Activity-Specific H azard Categorization Hazard Categorization for the TRA Hot Cell Waste Boxes, HA D-126, S. L. Silberman, September 2001

P208 MTR Hot Catch Tank Cleanup Procedure, Septembe r 29, 1987

P209 Amended System Identification for the Test Rea ctor Area Catch Tank System (TRA-630), Voluntary Consent Order Action Plan VCO-5.8.d ICP/E XT-04-00320, Idaho Completion Project, November 2004 P211 TRA Standard Maintenance Procedure, MTR Hot Ca tch Tank Cleanup 2.1.16, Not Given, November 20, 1987

P234 Evaluation of Closure Options for the Transura nic-Contaminated Components Associated with the TRA-630 Catch Tank System, Volu ntary Consent Order Action Plan VCO-5.8.d RPT-351, Idaho Cleanup Project, March 200 7

P236 Engineering Design File, Isotopic Scaling Para meters for the Reactor Technology Complex Catch Tank Sludge Waste EDF-7692, Yale D. H arker, February 8, 2008

U002 TRA Outer Area Operating and Maintenance Manua l 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, 199 7

U047 Hot Cell Epicor Waste Characterization, undate d

U052 Tank History, undated

U060 Waste Minimization, Pat Stephens, 1993B-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, BN W P-7-2 Fission Break INC-69-2, Ralph E. Fearnow, December 22, 1968

U093 An Environmental Evaluation for the Test React or Area Catch Tank Upgrade, Environmental Sciences, Earth and Life Sciences Bra nch, October 1984

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

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

U117 Packet of documents concerning the sludge in t he MTR Catch Tanks NA, August 15, 1986 to January 4, 1990 (not inclusi ve)

CCP-AK-INL-521, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d 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 Ac ceptable 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 & Ga mma Spectrometry Data Input Check, Revision 0, INL-RH-101, Jene Vance, April 09, 2010

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

U242, CCP Calculation Package – Determination of IN L 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 Analysi s 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, 2010B-7

DTC BDR No. INLRHDTC10009, dated June 7, 2010, cont aining DTC results for containers IDIRTRA8821A, IDIRTRA8821B, IDIRTRA8822B and IDIRTR A8822B

Analysis of Sample Data for RH TRU Waste Stream ID- RTC-S3000, memorandum from J. Holderness to Irene Quintana dated February 21, 201 0