DOCKET NO: A-98-49, II-A4-122

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION OF THE CENTRAL CHARACTERIZATION PROJECT (CCP) REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION P ROGRAM

FOR IDAHO NATIONAL LABORATORY (INL): ADDITION OF TWELVE CONTAINERS TO WASTE STREAM ID-AN LE-S5000 AND WASTE STREAM ID-HFEF-S5400-RH

December 8-9, 2009

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

January 2010i 

### TABLE OF CONTENTS

Section Page Acronyms ...........................................

................................................... ..........................................ii

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

................................................... ....................... 1

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

................................................... ..................... 2

3.0 Scope of the Tier 1 Evaluation.....................

................................................... .................... 6

4.0 Addition of Twelve Containers of M-Cell Wastes.....

................................................... ...... 7
4.1 Acceptable Knowledge ...............................

................................................... ......... 7
4.2 Radiological Characterization......................

................................................... ...... 17

5.0 Evaluation of New RH Waste Stream ID-HFEF-S5400-RH. ........................................... 22
5.1 Acceptable Knowledge ...............................

................................................... ....... 23
5.2 Radiological Characterization......................

................................................... ...... 36

6.0 Findings and Concerns..............................

................................................... ..................... 43

7.0 Conclusions ........................................

................................................... ............................ 43



### ATTACHMENTS

Attachment A: Approval Summary for INL-CCP RH Wast e Characterization Program Attachment B: Listing of Documents Reviewed Attachment C: EPA Evaluation Issue Tracking Form – Radiological Characterization Attachment D: EPA Evaluation Issue Tracking Form – Acceptable Knowledgeii ACRONYMS

AG Numbers AGHCF Numbers AGHCF Alpha Gamma Hot Cell Facility AK acceptable knowledge AKE acceptable knowledge expert AKSR acceptable knowledge summary report

Am americium ANL Argonne National Laboratory ANL-E Argonne National Laboratory– East ANL-W Argonne National Laboratory– West BDR batch data report

BR breeder reactor

CBFO Carlsbad Area Field Office CCP Central Characterization Project

Ce cerium

CFR Code of Federal Regulations

CH contact-handled

Ci curie

Co cobalt CPR cellulose, plastic, and rubber

Cr chromium CRR Characterization Reconciliation Report

Cs cesium CSSF Correlation and Surrogate Summary Form

CTAC Carlsbad Technical Assistance Contractor CTP Confirmatory Test Plan DOE U.S. Department of Energy DQO data quality objective DR discrepancy resolution

DTC dose-to-curie DU depleted uranium EBR experimental breeder reactoriii

EPA U.S. Environmental Protection Agency FCF Fuel Conditioning Facility FFTF Fast Flux Test Facility FGE fissile gram equivalent

FR Federal Register

Fs fissium

g gram g/cm3 grams per cubic centimeter

GE General Electric HAER Historic American Engineering Record HFEF Hot Fuel Examination Facility HLW high-level waste

ID Idaho IFR integral fast reactor ILTSF Intermediate Level Transuranic Storage Facili ty INL Idaho National Laboratory INEEL Idaho National Engineering and Environmental Laboratory INEL Idaho National Engineering Laboratory INTEC Idaho Nuclear Technology and Engineering Cent er ITR Independent Technical Reviewer IWMF INTEC Waste Management Facility L&O Laboratory and Office LANL Los Alamos National Laboratory

LLW low-level waste LMFBR liquid metal fast breeder reactor

LWA Land Withdrawal Act LWBR light-water breeder reactor LWR light-water reactor

m meter

m 3 cubic meter MCNP5 Monte Carlo N-Particle Transport Code RSICC Co mputer Code Collection,

Oak Ridge National Laboratory MFC Materials and Fuel Complexiv

Mn manganese mR/hr milli Roentgen per hour mRem/hr millirem per hour nCi/g nanocurie per gram NCR non-conformance report NDA nondestructive assay NWPA Nuclear Waste Policy Act ORIGEN Oak Ridge Isotope Generation ORNL Oak Ridge National Laboratory

Pb lead PE Ci plutonium equivalent curie PPE personal protective equipment Pu plutonium R/hr/Curie Roentgen per hour per curie RCRA Resource Conservation and Recovery Act

RERTR reduced enrichment research and test reactor

RH remote-handled RSWF Radioactive Scrap Waste Facility RTR real-time radiography RWMC Radiological Waste Management Complex SCG Summary Category Group SLSF Sodium Loop Safety Facility SNF spent nuclear fuel SPM Site Project Manager

Sr strontium

SRS Savannah River Site

T1 Tier 1

T2 Tier 2

TAN Test Area North

TBD to be determined TMU total measurement uncertainty

TRAMPAC Transuranic Waste Authorized Methods for Pa yload Control

TRU transuranicv

U uranium

VE visual examination VET visual examination technique WAC waste acceptance criteria

WC waste characterization WCPIP Waste Characterization Program Implementation Program

WIPP Waste Isolation Pilot Plant WIR waste incidental to reprocessing WMP waste material parameter

WSPF Waste Stream Profile Form WWIS WIPP Waste Information System Y yttrium

Zr zirconium1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA or the Agency) approval of retrievably-stored, remote-handled (RH) transura nic (TRU) debris (S5000) from two waste streams from the Idaho National Laboratory (INL). Specifically, this approval supports the addition of twelve containers to Waste Stream ID-AN LE-S5000, and new RH Waste Stream ID-HFEF-S5400-RH, Lot 1A.

On October 2, 2009, the Carlsbad Field Office (CBFO ) requested that EPA review a proposed Tier 1 (T1) change addressing the following three I NL RH waste streams:

• The addition of twelve containers to an approved RH TRU waste stream, Waste Stream ID-ANLE-S5000. EPA approved this waste stream in J anuary 2007, as part of the baseline approval, however, the addition of contain ers is a T1 change;

• New RH Waste Stream ID-HFEF 1 -S5400-RH, Lot 1A with 28 casks; and

• New RH Waste Stream ID-INTEC 2 -RH, consisting of two containers

The baseline approval is specific to a certain numb er of containers and any addition of new containers to the approved waste stream requires CB FO and INL-CCP to submit a T1 change request and EPA approval prior to its disposal at t he Waste Isolation Pilot Plant (WIPP).

The Central Characterization Project (CCP) is respo nsible for characterizing the above wastes using the system of controls, which EPA evaluated d uring the baseline inspection conducted in July 2006 and approved in January 2007. A summary of EPA’s approval of the INL RH TRU waste characterization program is included as Attac hment A. Because there were no new equipment or processes on site at INL to examine, E PA conducted the evaluation at EPA Headquarters in Washington, DC, on December 8-9, 20 09.

The scope of this T1 evaluation initially included the three waste streams mentioned above. However, during the December evaluation in Washingt on, EPA became aware that INL-CCP was using certain radiological data for generating scaling factors in support of the ID-INTEC-RH waste stream. These data were generated by samplin g the two INTEC waste containers and performing radiochemical analysis using processes/p rocedures not previously evaluated or approved by EPA. EPA determined that all processes /procedures implemented for sampling and analysis must be first evaluated for technical adeq uacy before EPA can assess the use of scaling factors and approve the subject waste stream. Cons equently, EPA removed the ID-INTEC-RH waste stream from the scope of this T1 evaluation a nd informed CBFO that the sampling and analysis process implemented must be evaluated befo re considering approval of the INTEC waste. EPA committed to perform this evaluation du ring the month of January 2010.

Pending completion of EPA’s onsite evaluation of th e sample collection and analyses that support this waste stream, EPA will issue a separat e report addressing this waste stream. This

1 HFEF is the Hot Fuel Examination Facility at the M aterials and Fuel Complex (MFC), formerly known as Argonne National Laboratory-West (ANL-W), which is part of INL.

2 INTEC is the Idaho Nuclear Technology and Engineer ing Center.2

inspection report, therefore, excludes any discussi on or approval of the INTEC waste (IDINTEC-RH).

This report presents the results of the T1 evaluati on. Section 4.0 discusses EPA’s evaluation of the addition of twelve containers to Waste Stream I D-ANLE-S5000 and Section 5.0 discusses EPA’s evaluation of Waste Stream ID-HFEF-S5400-RH, Lot 1A. EPA identified two concerns during the evaluation, both of which were satisfact orily resolved subsequent to the Washington, DC, meeting and no issues remain open relative to t his T1 change. EPA has identified new Tier 2 (T2) changes under Acceptable Knowledge (AK) resulting from the evaluation of both RH waste streams. These T2 changes, when made, must b e provided to EPA for review on a quarterly basis. We have revised the INL-CCP RH Ti ering Table to incorporate these T2 changes, as shown below in Table 1. EPA determined that the procedures and processes used by INL-CCP for the addition of twelve containers to RH TRU Waste Stream ID-ANLE-S5000 and new RH Waste Stream ID-HFEF-S5400-RH, Lot 1A were a dequate. EPA, therefore, approves the two waste streams, ID-ANLE-S5000 and ID-HFEF-S5 400-RH, Lot 1A, as a T1 change. The addition of any waste to either of these two waste streams is a T1 change requiring EPA approval. As mentioned above, at this time, EPA is not approving ID-INTEC-RH, and IDHFEF-S5400-RH, Lot 1B.

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes to the waste characterization activ ities from the date of the site’s baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulations and incorporated in the INL-CCP RH Baseline Final Report cited in Attachment 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. DOE may choose to characteri ze and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU waste usin g processes/procedures/equipment implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may conduct continued compliance inspections to evaluat e implemented T2 changes to verify adequacy.34Table 1. Tiering of RH TRU WC Processes Implementedby INL-CCP (Revised January 28, 2010*)RH WC Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH WC Process - T2 ChangesAcceptable Knowledge (AK)Addition of containers to approved Waste StreamsAny new waste streams not approved under this baselineSubstantive modification(s) that have the potentialto affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL-501, orCCP-AK-INL-502Load management for any RH waste streamNotification to EPA whenAKSRs, RadiologicalCharacterization Reports and CertificationConfirmation Test Plans (e.g.,CCP-INL-AK-500, CCPINL-AK-501, and CCP-INL-AK-502) updatesareapproved by CBFONotification to EPA when changes to AK documentation asa result of WCPIP revisions have been made (e.g., CRR)Notification to EPA when a Correlation or SurrogateSummary Form is completed for each of the RH containersin this waste stream identified as CH, based upon measureddose rates that present NDA results for assayed containersNotification to EPA once waste stream data packagefordebris waste stream and any modifications to the WSPF,including the CRR and AK Summary, are completedNotification to EPA that the final Dose-to-Curie (DTC)determination is complete for RH containers numbers728through 737, as identified in AK Reference P030AK accuracy reports (prepared annually, at a minimum)Radiological Characterization, includingDose-to-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501Use of any alternate radiological characterizationprocedure otherthan DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedureAny new waste stream not approved under this baseline or additionof containers to Waste Stream ID-ANLE-S5000 that requireschanging the established radionuclide scaling factorsNotification to EPA upon completion of revisions ofCCPAK-INL-501 or CCP-TP-504 that require CBFO approvalVisual Examination of audio/video media(VE)Implementation of VE following this baseline approval; if INLCCP decides to use VE in the future, EPA approval is necessaryNoneReal-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 orwastes from an S3000 or S4000 waste streamNotification to EPA upon completion of changes to RTRprocedure(s) that require CBFO approval.Notification to EPA upon addition of a new RTR unit(s).WIPP Waste Information System (WWIS) NoneChanges made to WWIS procedure(s) that require CBFOapproval5Notes:-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 every three months.-Excluding changes that are editorial in nature or are required to address administrative concerns.-Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measurement instrumentor the use of the high-range probe as described inCCP-TP-504.-Additions to the original tiering table from the 2007 baseline inspection appear inbold.6

3.0 SCOPE OF THE TIER 1 EVALUATION

This T1 evaluation encompassed the following two IN L RH waste streams:

• The addition of twelve containers to RH Waste Strea m ID-ANLE-S5000, which had been approved previously, is discussed in Section 4.0

• INL RH Waste Stream ID-HFEF-S5400-RH, Lot 1A, consi sting of 28 HFEF-5 cans, is discussed in Section 5.0

The RH wastes that were the subject of this T1 eval uation are retrievably-stored debris that INL-CCP plans to characterize for disposal at WIPP. Technical aspects of the waste characterization processes implemented to character ize these two waste streams vary. As a result, the details of the evaluation of each waste stream for technical adequacy are presented separately in Sections 4.0 and 5.0, below.

The evaluation of both waste streams included two w aste characterization areas, AK and radiological characterization, each of which is add ressed separately in this report. Personnel who participated in the T1 evaluation are listed in Tab le 2, along with each person’s affiliation and function during the evaluation.

Table 2. T1 Evaluation Participants

Name Affiliation & Function Rajani Joglekar EPA Headquarters, Lead Inspector Ed Feltcorn EPA Headquarters, Inspector Lindsey Bender EPA Headquarters, Inspector Connie Walker SC&A, Technical Evaluator – AK Patrick Kelly SC&A, Technical Evaluator – Radiologi cal Characterization Amir Mobasheran SC&A, Technical Evaluator – Radiolo gical Characterization Kevin Peters CCP, AK Scott Smith CCP, AK Jene Vance* CCP, Technical Support, Radiological Ch aracterization Mark Doherty CCP, AK Thomas Clements CWI-INL, Observer Irene Quintana CCP, SPM David Moody CCP, Technical Support for Radiological Characterization Jessie Klingensmith CCP, Technical Support for Radi ological Characterization Joe Harvill WTS/CCP, Observer Mike Sensibaugh CCP, Technical Support for Radiolog ical Characterization Kira Darlow SC&A, Observer Jim Oliver CTAC Observer *Jene Vance did not attend the evaluation in Washin gton, DC, but was involved in several discussions with EPA technical personnel by telepho ne prior to the Washington meeting in December.7

4.0 ADDITION OF TWELVE CONTAINERS OF M-CELL WASTES

This evaluation covers twelve containers of M-4 Cel l being added to INL RH Waste Stream ID-ANLE-S5000. This waste stream consists of debri s wastes that were generated at Argonne National Laboratory-East (ANL-E) in the Alpha Gamma Hot Cell Facility (AGHCF) during the examination of irradiated and un-irradiated fuel pi ns from various reactor programs at ANL-W and other DOE and commercial reactors that were tra nsferred to INL between 1976 and 1995. The examinations consisted of sectioning, grinding and polishing fuel pins for metallography and a variety of nondestructive and destructive testing

.

4.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion to determine whether the INL-CCP waste characterization program demonstrated complia nce with the requirements of 40 CFR 194.8 for the addition of twelve containers of retrievabl y-stored RH debris waste from the M-4 Cell to Waste Stream ID-ANLE-S5000.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the followi ng with respect to the use of AK for characterizing twelve containers of M-4 Cell RH deb ris waste for addition to EPA-approved Waste Stream No. ID-ANLE-S5000:

• Waste stream identification and definition

• Radionuclide content of M-4 Cell waste

• Physical composition of M-4 Cell waste

• Sufficiency of modified AK Summary Report (AKSR) to include the M-4 Cell waste

• Drum data traceability

• Defense origin of M-4 Cell waste

• AK source document sufficiency

• Modifications to the Confirmatory Test Plan (CTP)

• Modifications to the Waste Stream Profile Form (WSP F) and Characterization Reconciliation Report (CRR)

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

• Personnel training

• Non Conformance Reports (NCRs) and AK Discrepancy Re solutions (DRs)

• AK accuracy

• Load management8

Documents, Waste Containers, and Batch Data Reports Provided

EPA evaluated the documentation that INL-CCP had pr epared to support including twelve containers of M-4 Cell wastes in Waste Stream No. I D-ANLE-S5000. The list of all documents that EPA reviewed is included in Attachment B.

Waste Container and Batch Data Reports Reviewed

Typically, batch data reports (BDRs) containing the results of radiological (Dose-to-Curie 3 [DTC]) and non destructive examination analysis, (i .e., Real-Time Radiography [RTR] or Visual Examination [VE]) are reviewed as part of EPA’s tra ceability examination. An analysis of M-4 Cell containers had not been performed prior to the 2007 EPA baseline inspection, so traceability was evaluated by examining AK data for three of the twelve containers. This evaluation provided an understanding of the information availa ble for drums as they were packaged, shipped to INL for storage, and subsequently subjec ted to characterization processes as part of the INL-CCP program. The results of this analysis are presented below. The BDRs that were provided to EPA are listed in Table 3 below.

Table 3. BDRs Provided to EPA

Drum* RTR BDR No. VET BDR No. DTC BDR No. 1004 RHRTR09007 NA INLDTC09007 1002 RHRTR09007 NA INLDTC09007 397 NA RHINLVE09004 INLDTC09007 396 NA RHINLVE09004 INLDTC09007 395 NA RHINLVE09004 INLDTC09007 398 NA RHINLVE09004 INLDTC09007 399 NA RHINLVE09004 INLDTC09007 400 NA RHINLVE09004 INLDTC09007 393 NA RHINLVE09004 INLDTC09007 394 NA RHINLVE09004 INLDTC09007 1005 NA RHINLVE09004 Not provided 1003 NA RHINLVE09004 INLDTC09007 *All drum numbers are preceded by IDAE000000 or IDA ERH000

AK was used to characterize Waste Stream ID-ANLE-S5 000 with respect to most of the Data Quality Objectives (DQOs), and confirmatory testing was performed using VET and RTR. The twelve containers of M-4 Cell debris were character ized using the same processes that the EPA approved in January 2007, except for the use of the VET, which was implemented for 10 of the twelve containers, while the remaining two underwen t RTR. EPA subsequently approved the INL-CCP’s RTR process in February 2007 and the VET process in September 2009.

Unlike CH containers, RH containers were not subjec ted to AK confirmation using nondestructive assay (NDA). Instead, confirmation of the AK-reported radiological contents of the RH debris waste containers, TRU waste designati on, and activity-related DQOs were

3 DTC uses the terms “Dose” or “Dose Rate” to descri be what is more properly called an external dose equivalent or external dose equivalent rate that is measured in units of Rem.9

performed through the application of the DTC techni que supported by radionuclide scaling factors that were derived through modeling. Note t hat the scaling factors for Waste Stream ID-ANLE-S5000 were not modified by the addition of the twelve containers of M-4 Cell debris waste, indicating that the composition of fuel pins tested in the M-4 Cell was consistent with the composition of fuel pins in the original ID-ANLE-S5 000 waste stream that EPA approved in January 2007.

This evaluation assessed the AK process and related activities necessary for determining whether the twelve containers of M-4 Cell debris waste belo ng in the ID-ANLE-S5000 waste stream, based upon process information, as well as the wast e’s physical and radionuclide composition.

Technical Evaluation

Modification of the waste stream to include twelve containers of the RH waste from M-4 Cell in Building 200 was assessed to determine the followin g: how these data had been integrated; impacts of the information on the waste stream; cha nges to the radiological and physical characteristics of the waste; and other elements th at could affect the characteristics of Waste Stream ID-ANLE-S5000. Results of the analysis are presented below. When information presented in the text is supported directly by one of the AK references, that reference is cited in parentheses. Note that several of the technical el ements typically included in a T1 review are presented for completeness, but were not changed fr om the original baseline determination by the addition of the twelve containers.

(1) The adequacy of the definition of Waste Stream ID-A NLE-S5000 was examined with respect to the addition of the M-4 Cell wastes, inc luding drum traceability, and was found to be adequate.

The Remote-Handled TRU Waste Characterization Progr am Implementation Plan (WCPIP) defines a waste stream as “waste material generated from a single process or activity, or as waste with similar physical, chemical, and radiological p roperties.” Waste Stream ID-ANLE-S5000 is a debris waste stream generated in the ANL-E AGHCF and Cells K-1, K-2, and M-4 of the M-Wing. EPA found that the original waste stream w as adequately defined, but it did not include M-4 Cell waste at that time. Physical and radionuclide compositions of the twelve containers of M-4 Cell waste were assessed to deter mine whether these drums fit within the approval of the original waste stream. The discuss ion provided in CCP-AK-INL-500, Revision 7 elaborates on waste origin and is similar to the or iginal waste stream.

To better understand the movement of materials betw een the AGHCF in Building 212 and Building 200 (which included the M-4 Cell), INL-CCP prepared Reference C1031 which documented the review process and the material flow during the M-4 time period. This reference corroborates that M-4 Cell waste is similar to the previously approved waste stream and the addition of twelve containers is appropriate.

As indicated in the AKSR, M-4 Cell waste was packag ed in 30-gallon drums during three campaigns:10

• January 8-10, 1979: Drums 00395, 00396, 00397, 00 398

• October 8 and 11, 1979: Drums 00393, 00394, 00399 , 00400

• March 12 and 16, 1981: Drums 001002, 001003, 0010 04, 001005

A traceability analysis (the paper “pedigree”), sho wn below in Table 4, supports the contention that the subject drums “fit” in Waste Stream ID-ANL E-S5000.

Table 4. Traceability Analysis

Drum No. Examples of Documentation

Examined Analysis of Documentation Comment

398 C1031 BDR INLDTC09007 BDR RHINLVE09004 Fast Scan (U1002) Log of Intermediate Gamma Cell Transuranic Waste References U1003, P1004 Drum did not have any transfer paperwork or Special Survey reports to show internal contents, but was packaged with other drums of the campaign and was identified on Log of Intermediate Gamma Cell Transuranic Waste. Documentation associated the material with AG# 165 P12. VE BDR showed the drum contained plastic bottle with vermiculite absorbents, as well as plastics, rubber gaskets, glass, cardboard, and other material. No solidified organics mentioned or noted in reviewed information. Data verified container fit within the general physical parameters of the stream, was associated with a Big Rock/Exxon AG# 165, and did not contain prohibited items upon repackaging.

394 C1031 BDR INLDTC09007 BDR RHINLVE09004 Fast Scan (U1002) Log of Intermediate Gamma Cell Transuranic Waste Transfer paperwork signed by John Vanloon, John Hoh Special Survey Report-interior
contents References U1003, P1004 VE indicated presence of leaded disks, shielding, broken plastic bottles, metals pipes, absorbent, solidified organic sludge, labware, magnet cores. Original paperwork also identified AG Nos. 165M8 and R8, associated with Big Rock/Exxon fuels. It should be noted that the EPA Inspector saw a Quick Screen RTR of this drum wherein free liquids were noted. However, only solidified organics and/or inorganics were present on VET. No NCR had been prepared. INL-CCP indicated this was because the waste was treated as “newly-generated”- repackaged, so removal of the liquid was part of the original remediation process during packaging. 1003 C1031 BDR INLDTC09007 BDR INLVE09004 Fast Scan (U1002) Log of Intermediate Gamma Cell Transuranic Waste Transfer paperwork signed by John Vanloon, John Hoh Special Survey Report-interior
contents References U1003, P1004, U1005, U1001 INL-CCP indicated that the original paperwork was marked with 165 PG-7 PA-5, R16, and also had markings associated with S13, GB-10, 175 A6, 165 R3, although these were not visible on VET sheets. VET identified cans, lead shielding, ultrasonic cleaner, rubber, plastic, metal, grinding paper, paper towels, etc. Containers fell within general physical parameters of waste stream and contained BigRock/Exxon, as well as EBRII related materials that were addressed in the previous scaling factor development.11

To ensure that the M-4 Cell wastes are part of the original AGHCF waste stream, several references were examined to understand the cell pro cesses, inputs, and activities. Data examined included several references, including numerous EXX ON references discussing the Big Rock fuel projects (e.g., C355, C357, C1031). These dat a indicate that the same procedures (i.e., testing) were implemented in the M-4 and AGHCF Cell s, and INL-CCP representatives stated that the fuel pins managed in M-4 Cells are directl y traceable to the same fuel pins/AG Nos. in the AGHCF Cells, as evidenced in References C1031 a nd CCP-AK-501. INL-CCP representatives stated their research indicated tha t while there were some fuels or identifiers associated with Building 200 activities that they c ould not trace, the majority of data they obtained showed a clean and substantiated link betw een Building 200 (and M-4 Cell activities) and Building 212, which housed the AGHCF. Therefor e, data indicate that common processes were implemented for testing and waste generation/m anagement in the AGHCF and other cells within the M-Wing, and AGHCF processes and material s were managed in the M-4 Cell, according to INL-CCP representatives.

With regard to radionuclide composition of the M-4 Cell containers, INL-CCP representatives indicated that fuel pins accepted at the AGHCF were sometimes moved to Building 200 and hence M-4 for additional sectioning and testing pri or to shipment back to the AGHCF for further analysis. Building 200 also sometimes accepted fue l pins for testing or sectioning prior to shipment to the AGHCF. Regardless, INL-CCP represe ntatives stated that all fuel pins within the “system” of the AGHCF/M-Wing operated in a clos ed loop, in that all fuel pins tested in the Building 200 M-Wing either originated in or were se nt back to the AGHCF following initial work. This indicated that the M-4 Cell fuel pin po pulation is a subset of the total population of fuel pins managed or tested in the AGHCF. Accordin gly, the radionuclide composition of the M-4 Cell wastes is a subset of the waste stream’s o verall radionuclide composition. See Item (2), below, for additional examination of data pertaining to the radionuclide content of M-Cell wastes.

Based on the above analysis, the twelve containers of M-4 Cell debris waste fit into Waste Stream ID-ANLE-S5000.

(2) Radionuclide characteristics of the M-4 Cell waste were assessed with respect to their similarity to Waste Stream ID-ANLE-5000 and were fo und to be adequate.

As indicated in Item 1, INL-CCP identified several EXXON/Big Rock, EBR-II, and other fuel samples that were transferred to and through the M- 4 cell. INL-CCP evaluated the M-4 cell drums individually.

Reference C1031 summarizes information pertaining t o the fuel pins tested in the M-4 Cell. This reference, as well as new information obtained thro ugh VE of the containers (BDRs), indicates that the following AGHCF Numbers (AG Numbers) are am ong those associated with M-4 Cell
wastes:

• 165 R9, R6, M14, P16, P20, M9, P12, M8, R8, P15, P8 , M3, R3, and J1-10

• S13

• GB1012

• 175A6

• 119

• 135

• 45B

EPA found some discrepancies in discussion in relev ant references. When questioned, INL-CCP representatives indicated that all data showed that AG Nos. 165 M, P, and R were associated with the same uranium oxide fuels as found in the c ited AG No. 165 (e.g., A, B, and C). Therefore, INL-CCP determined that modification of the scaling factors is not required by inclusion of the twelve M-4 Cell drums.

In addition, to demonstrate the general association of AG Nos. with reactors, INL-CCP provided the following information in Reference C1031 (as Ta ble 5, below) that shows the identified materials managed in the M-4 Cell, related sources, and indicates whether the source was considered in the original AGHCF Scaling Factors, i .e., that M-4 Cell components are a subset of the AGHCF waste stream.

Table 5. Fuel Sample Association and Inclusion in Original

AGHCF Scaling Factors

Example M-4 Cell Fuel Sample AG No. Association Reactor in Original AGHCF Scaling Factors M165 R9 Big Rock/Exxon Yes M165 R6 Big Rock/Exxon Yes M165 M14 Big Rock/Exxon Yes M165 P16 Big Rock/Exxon Yes M165 P20 Big Rock/Exxon Yes M165 M9 Big Rock/Exxon Yes M165 M8 Big Rock/Exxon Yes M165 R8 Big Rock/Exxon Yes M165 P8 Big Rock/Exxon Yes M165 M3 Big Rock/Exxon Yes M165 P12 Big Rock/Exxon Yes M165 P15 Big Rock/Exxon Yes M165 J-1 Big Rock/Exxon Yes
119 EBR-II Yes
135 EBR-II Yes
173 EBR-II Yes 45B (45G on Table 2) EBR-II Yes 175A6 EBR-II Not Specified

EPA evaluated the radiological composition of the w aste stream as part of the baseline inspection. At the time, EPA concluded that EDF-66 85 showed that 72% of the identified fuel pins contain both plutonium and uranium (Pu and U), with 28% containing only 235 U. Because the M-4 Cell wastes are associated with the same pr ocesses and activities and are a part of the same fuel pin population, this conclusion should no t be modified by inclusion of the M-4 Cell13

drums in the ID-ANLE-S5000 waste stream, although d rum-specific characterization will verify this assumption. Based on this information, the ra dionuclide composition of M-4 Cell wastes is bounded by the composition as presented in the AKSR for Waste Stream ID-ANLE-S5000.

(3) Physical characteristics of the M-4 Cell waste were assessed with respect to the physical characteristics of Waste Stream ID-ANLE-S5000 and w ere found to be adequate.

EPA noted that the containers have a long pedigree of VE or RTR that was obtained either during or post-packaging. During the original pack aging activities, general information was kept pertaining to drum contents and general configurati on of the waste. Quick Scan RTR was performed by INL-CCP on the drums, because the orig inal packaging information was not available for some drums, and to verify and assess waste content. These two events showed that the drums generally contained a bottom and top lead -lined paint can. Written documentation obtained during packaging indicates that the drums contained several items including, but not limited to, the following:

• Drums 395-398: Plastic bottles, caps, and bags, metal flask hold er, glass flasks (roundbottom and Erlenmeyer), ground glass stoppers; smal l amounts of liquid in the bottom of bottles and flasks.

• Drums 393, 394, 399, 400: Metal pipe nipples (4” diameter) containing plast ic bottles (750-1000 ml.) containing immobilized material or “ dense solidified material;” one bottle contains liquid (100-200 ml); absorbent or other ho mogenous material visible at the bottom of the can between the lead sheeting and ins ide; metal caps (dishes) placed on top of lead liner.

• Drums 01002-01005: Metal paint cans (with lids), plastic bottles, me tal caps, plastic caps, rubber stopper, plastic bags, and cardboard; floor sweepings, metal paint cans (with lids), cardboard, rubber O-ring, wire, broken glass , plastic bags containing 2 metal 1- gallon paint cans (with lids) containing scrap plas tic, plastic caps, bottles, tubing, and bags, and metal washers possible cladding, 0-rings, razor knife, electric outlet box, plastic bottle, scrap metal, and roll of tape; documentatio n also suggested the presence of floor sweepings, plastic bags, glass bottles (beakers) co ntaining metal rings, (cladding?), plastic disc with screws.

These data suggest that the three drum-generation p eriods may have different physical compositions. To explore this observation, INL-CCP representatives were interviewed and current VET data were examined. INL-CCP representa tives indicated that the 1979 drums were generated primarily during research in the M-Wing M -4 Cell in conjunction with the AGHCF and focused primarily on the preparation of fuel sa mples for burn-up and fission gas analysis of Big Rock Point Reactor specimens. The resultant wa ste required shielding in the containers and the presence of solidified material in internal con tainers. Later waste (1981) resulted from general clean-out of the M-4 cell.

INL-CCP representatives have not yet examined wheth er the Waste Material Parameters (WMP) calculations in the AKSR require revision based on the results of RTR and VET. When these changes are made in future modifications to the AKS R, EPA expects to be notified under the T214

change notification, as required in the baseline ap proval. EPA notes that while slight revisions to weight percentages and other values in Table 6 of t he AKSR may be necessary to incorporate the additional twelve containers, these changes are not likely to be significant.

Based on the above, the VET and RTR data confirm th at the physical form of the waste fits into the general waste descriptions of Waste Stream ID-A NLE-S5000.

(4) Sufficiency of the AKSR and implementation of AK as required in Attachment A of the WCPIP were evaluated and were found to be adequate.

EPA noted that a few changes had been made to the A KSR to add the twelve drums to the waste stream. Much of the characterization data associat ed with these drums had yet to be examined by the INL-CCP Acceptable Knowledge Expert (AKE) (m ost notably the VET data), so it is possible that the AKSR will be revised to incorpora te the additional information. EPA will examine future versions of the AKSR as part of the ongoing T2 notification process specified in the baseline approval.

(5) The discussion supports defense status of the M-4 C ell waste.

The AKSR states that the EBR-II reactor supported o ngoing defense-related activities under various projects. M-4 Cell wastes contain radionuc lides that originated in EBR-II. Therefore, the AKSR concludes “...the receipt, transfer, and sto rage of fuel specimens, test materials, and contaminated waste materials within hot cell areas and between the hot cell facilities resulted in commingling of contamination from the projects cond ucted in these areas. As a result of the waste management practices and analytical nature of the operations conducted in the AGHCF and M-Wing Hot Cell Facility, segregation of non-de fense waste from defense-related waste is not feasible”. While a formal evaluation of the wa ste’s defense determination is not within EPA’s purview, EPA did determine that the discussio n provided supports the defense status of the M-4 Cell wastes.

(6) Sufficiency of AK support documents and related doc ument tracking with respect to the addition of M-4 Cell references was evaluated and w as found to be adequate.

INL-CCP prepared an AK Source Document Reference Li st using unique identifiers for the different document types, a format typically used f or documents supporting CH waste. The listing is based on CCP-TP-005 Revision 18, Attachm ent 4 and was found to be relatively complete and was easy to understand. This is a liv ing document and does not always contain every reference that is cited in other AK-related d ocuments (e.g., CCP-AK-INL-501). As shown in the bulleted list in Attachment B, INL-CCP provi ded dozens of references, some of which were specific to M-4 Cell wastes. However, it must be noted that without Reference C1031, it would not have been possible to examine the provide d references and obtain the same15

conclusions drawn by INL-CCP that justify inclusion of the M-4 Cell wastes in this waste
stream 4

. (7) Modifications of the WSPF and related CRR were asse ssed and were found to be adequate.

INL-CCP representatives indicated that neither a re vision to the WSPF nor the CRR had been prepared. EPA’s baseline approval requires notific ation when changes to the WSPF and CRR are made. EPA expects to be notified if and when c hanges are made to these documents that relate to the M-4 Cell waste.

(8) Changes to the Certification Plan/CTP were evaluate d and were found to be adequate.

The Certification Plan/CTP (CCP-AK-INL-502, Revisio n 3) was revised to include VET, but the overall characterization process remained unchanged . EPA’s baseline approval requires notification when the CTP is revised, and EPA will expect to be notified if any changes are made in the future to address the M-4 Cell waste.

(9) Use of a CSSF was evaluated and was found to be ade quate.

Revisions to the CSSF were not made in response to inclusion of the M-4 Cell wastes. It is conceivable that some RH drums will be identified a s CH upon application of the DTC procedure. Should this occur and the assay data fo r the containers are available and are used for characterization, EPA’s prior approval of INL-CCP d escribes the appropriate action.

(10) NCRs and DR Forms were examined and were found to be adequate.

The VET BDR included NCR-RHINL-0506-09 that dealt w ith improper paperwork associated with drum packaging. There were no NCRs associated with the presence of prohibited items, inappropriate Summary Category Group (SCG), or othe r characterization-related elements included in the information provided to EPA. Addit ionally, a single DR, DR018, was provided that included information related to M-4 Cell waste . Specifically, the DR concludes that: “Based on the differences in the physical form of t he waste materials and packaging configuration, it was decided to exclude containers 393-400 and 1002-1005 from Waste Stream CCP-AK-INL-5000 until sufficient AK is collected fo r these containers. The remaining containers will be quick scanned by RTR and additio nal information will be collected from ANL-E to characterize these containers.” The concl usion to exclude the twelve M-4 Cell “unknown” containers presented in the DR has been a ddressed by activities performed by INLCCP since the DR was generated in 2007.

4 EPA’s review and evaluation process would be facili tated if INL-CCP specifically identified the refere nces which are most pertinent to the Tiering request amo ng those provided. It must be pointed out that EPA only examines the documentation specific to the technica l element in the AKSR that identifies a reference a s relevant to be selected for examination.16

(11) AK accuracy was assessed and was found to be adequa te.
INL-CCP revises its AK accuracy report annually and the version that was provided for this waste stream was dated February 2, 2009, and it inc luded Lots 1-27, but presumably not the M-4 Cell wastes. The report, Results of AK Accuracy Evaluation , included references to a peer review that is not discussed elsewhere in the repor t. Also, the section does not adequately discuss the results of the AK evaluation performed to assess whether the presence of liquids had been adequately addressed in the AKSR, since VE/RTR identified the presence of liquids in the waste stream. When questioned, INL-CCP revised the AK accuracy report to remove the reference to the peer review and correct typographi cal errors.

(12) Load Management was evaluated and was found to not apply to this waste stream at this time.

INL-CCP representatives indicated that load managem ent is not intended for Waste Stream No. ID-ANLE-S5000. EPA’s baseline inspection report in dicated that the implementation of load management is a T1 change requiring EPA prior appro val.

(13) The presence of Spent Nuclear Fuel (SNF) and High L evel Waste (HLW) as a result of addition of M-4 Cell waste was examined.

CCP-AK-INL-500, Revision 7 presents a statement tha t is consistent with language in other CCP AKSRs with respect to SNF and HLW, and INL-CCP pers onnel stated this applied to the M-4 Cell wastes. The statement is excerpted below:

The WIPP LWA (Reference 6) prohibits the disposal o f spent nuclear fuel and high-level waste as defined by the NWPA (Reference 10) at WIPP. According to the NWPA, spent nuclear fuel is “fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elem ents of which have not been separated by reprocessing.” DOE M 435.1-1, Radioact ive Waste Management Manual (Reference 22), expands on this definition t o 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.” High-level waste is defined by the NWPA as “the highly radioactive material result ing from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste t hat contains fission products in sufficient concentrations, and other highly radioac tive material that the Commission, consistent with existing law, determine s by rule requires permanent isolation.” Waste stream ID-ANLE-S5000 consists of debris waste generated during the examination of irradiated fuel specimens . These operations did not involve separation or reprocessing of constituent e lements from reactor fuel. The waste stream is contaminated with residues from the preparation of irradiated test specimens and does not contain the irradiated fuel elements withdrawn from17

a reactor. Therefore, the waste is not a spent nuc lear fuel or high-level waste and is eligible for disposal at WIPP as RH TRU waste.

EPA accepts the INL-CCP statement as adequately add ressing the SNF and HLW issues with respect to the addition of M-4 Cell wastes.

Summary of Results

Findings or Concerns

The EPA Inspection Team did not identify any findin gs or concerns relative to the inclusion of the twelve containers of M-4 Cell wastes to Waste S tream No. ID-ANLE-S5000 during this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations assigned to AK during the baseline approval.

4.2 Radiological Characterization

RH Waste Overview

INL RH Waste Stream ID-ANLE-S5000 consists of debri s wastes that were generated at ANL-E in the AGHFC during the examination of irradiated a nd un-irradiated fuel pins from various reactor programs at ANL-W and other DOE and commerc ial reactors that were transferred to INL between 1976 and 1995. The fuel examinations c onsisted of sectioning, grinding and polishing fuel pins for metallography and a variety of nondestructive and destructive testing. Based on the nature of the waste materials and the types and quantities of information available, INL-CCP chose the approach of developing a waste ch aracterization protocol that was suited for characterizing the population of all RH TRU waste c ontainers within this waste stream. EPA evaluated and approved this approach during the bas eline inspection, and it applied to Lots 1 through 20 from Waste Stream ID-ANLE-S5000. This c onceptual approach is the equivalent of what EPA has evaluated and approved via a baseline inspection at CCP TRU generator sites previously 5 . The twelve 55-gallon containers that were the su bject of this T1 evaluation differed from the other containers in this waste stream in t hat a combination of RTR and VE revealed that nine of the drums had internal lead shielding. The se containers had bottles of solidified material wrapped in 1/8” thick lead that had been placed in a 3.5-, 5-, 7- or 10-gallon can. This required the generation of a new 137 Cs correlation for these nine containers. The addi tional three containers without internal shielding required addi tional modeling to allow the application of the DTC technique, as described in this section.

5 EPA has provided a baseline approval of CCP RH TRU radiological programs at six sites: INL, ANL-E, LANL, SRS-Battelle, ORNL, and GE Vallecitos. All o f these sites used the approach of DTC with radionu clidespecific scaling factors and the baseline inspectio n reports that document them provide considerable d etails regarding this technique.18

Radiological Characterization Overview

The radiological characterization approach for INL RH Waste Stream ID-ANLE-S5000 is described in detail in Section 8.2 of the baseline inspection report cited in Attachment A. Figure 1 in the baseline inspection report represen ts the process with one exception—the presence of internal lead shielding in nine of thes e twelve 55-gallon containers that were the subject of this T1 evaluation required a separate 137 Cs correlation expressed in units of R/hr/Curie 137 Cs, which was developed using Microshield®. For th e remaining three containers without shielding, a 137 Cs correlation was modeled for 30-gallon and 55-gal lon configurations using MCNP5 6 . Apart from these two aspects, the remainder of the radiological characterization process was essentially the same as that which EPA inspected and approved in January 2007.

During the baseline inspection, the characterizatio n methods used for the containers of INL-CCP RH wastes were evaluated in terms of the technical adequacy of the approach 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 radi ological characterization program:

• Development of a DTC correlation as a function of w aste density using MCNP5 in a 30-gallon and 55-gallon geometry based on each cont ainer’s measured dose rate, assuming the main contributor to the external expos ure was 137 Cs

• Derivation of radionuclide scaling factors for quan tification of the 10 WIPP-tracked radionuclides, as supported by calculation packages that documented the use of ORIGEN2.2 runs for 506 equivalent fuel pins; the sc aling factors represented the average composition of the RH TRU wastes

Documents Reviewed

The list provided in Attachment B includes all docu ments related to the INL-CCP RH TRU radiological characterization program that were exa mined to support this T1 evaluation.

Technical Evaluation

The EPA inspection team evaluated the technical ade quacy and documentation of the correlation of the radionuclide inventory values to the 137 Cs concentrations in INL-CCP RH wastes and the technical development and documentation of radionuc lide scaling factors. Specifically, the EPA inspection team evaluated the following aspects:

6 MCNP5 is Monte Carlo N-Particle Transport Code RSI CC Computer Code Collection, Oak Ridge National Laboratory.19

(1) The technical adequacy and documentation of radionu clide scaling factors were evaluated and were found to be adequate.

Specifically, the EPA evaluation team assessed the following aspects relative to the twelve containers to be added to Waste Stream ID-ANLE-S500 0:

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

• Correlation of isotopic activity values 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

• Contributions of the short-lived radionuclides to t he total measured dose rate

• Appropriate decay correction according to INL-CCP p rocedure (CCP-TP-504, Revision 8) of all radionuclide values for purposes of model development and routine assays performed via DTC

• The calculated results are used to develop the scal ing factors and convert the measured external dose rates obtained via DTC to radionuclid e activity levels

• Activity and uncertainty values determined for the ten WIPP-tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs and 90 Sr)

• The determination of the contribution of all radion uclides to the radiological hazard 7

• Shielding and other calculations supporting the sca ling factors performed using MCNP5 to derive the appropriate DTC relationships as a fu nction of waste density for the geometry appropriate to the waste following repacka ging (55-gallon drum)

There are no issues related to the technical adequa cy or documentation of radionuclide scaling factors for the twelve containers of INL RH Waste S tream ID-ANLE-S5000.

(2) The technical basis of the DTC correlation and its documentation were evaluated and both aspects were acceptable.

The DTC correlations for the drums without internal shielding were performed using MCNP5 to derive the 137 Cs DTC correlation as a function of waste density f or the 30-gallon and 55-gallon geometries. The 30-gallon geometry is shown in CCP -AK-INL-501, Figure 7.1, and the 55- gallon geometry is identical to what is shown, with the exception that there is a 55-gallon drum surrounding the 30-gallon. The technical derivatio n and basis for the approach are documented in two calculation packages, INL-RH-19, INL Cs-137 Dose-to-Curie Correlation for 55-Gallon Drums and INL-RH-03, Dose-to-Curie Derivations for Cs-137 in 30-Gallon D rums . Because the fill percentage affects the density calculation , the fill percentages must be estimated for the

7 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.20

waste cans in the 30-gallon drums and a figure of 7 8% was chosen, as described in CCP-AKINL-501. For actual waste drums, the fill-height p ercentages will be provided by RTR.

The DTC correlation for the nine containers with in ternal shielding was based on the following assumptions:

• The waste density is not calculated from the gross drum weight; instead, waste material is assumed to be contained in a one-liter bottle and i s relatively homogeneous with a specific gravity of 1.2 g/cm 3

• With respect to shielding, the one-liter bottle is surrounded by either a 3.5- or 5-gallon can, which is surrounded by the 30-gallon drum and then the 50-gallon drum

• Fill heights are not relevant for the drums with in ternal lead shielding

This is detailed in calculation package INL-RH-89, Cs-137 DTC Correlation for 55-gallon Drums with Internal Lead Shielding . The exact number of times the lead sheeting was wrapped around each container varied from zero to eight, de pending on the intensity of the external radiation field associated with the sample material . Accordingly, individual Microshield® runs were made for each of the drums.

(3) Technical aspects and documentation of the radi ological characterization process were evaluated and found to be acceptable.

CCP-AK-INL-501 is the main document that describes the radiological characterization process used to characterize these RH wastes, and this docu ment is “mature” in the sense that it has been through several in-depth technical reviews since it was first written in late 2006. This document is supported by a series of calculation packages th at had been prepared and reviewed initially by Jene Vance, Jim Holderness, and Dave Moody to suppo rt the initial INL-CCP RH baseline, and many of them had been revised to incorporate the tw elve drums, as listed above. These packages documented a variety of technical aspects, includin g the following:

• Application and verification of Microshield ®

• Evaluation of all potential contributors to a conta iner’s dose rate

• Decay correction to an assumed reference date

• Contributions of short-lived radionuclides to the m easured external dose rate

• Potential sources of uncertainty

• Information input checks

• Technical development of scaling factors

• Technical derivation of the DTC approach and docume ntation of the DTC spreadsheet

The EPA evaluation team reviewed these packages and Revision 4 of CCP-AK-INL-501 in advance of the formal T1 evaluation meeting at EPA headquarters, and a conference call was held on December 2, 2009, to discuss technical aspe cts related to these twelve containers. As a result of reviewing the calculation packages and th e conference call, EPA had a question regarding the lack of documentation for the contrib ution of variations in density to Total Measurement Uncertainty (TMU). INL-CCP realized th at additional details would be necessary21

and as a result, INL-CCP personnel initiated a new calculation package, INL-RH-88, DTC Factor Uncertainty for 9 Drums w/ Pb Shielding . This was submitted to and reviewed by EPA and found to be acceptable. There were several oth er calculation packages that required revisions based on a minor discrepancy with respect to 241 Pu, and these were submitted to and reviewed by EPA and all were acceptable. Specifica lly, they were INL-RH-20, Cs-137 DTC Correlation for 55-Gallon Drums with Liners ; INL-RH-90, DTC and Related Calcs for 55-Gal Drum with Lead ; and INL-RH-89, DTC Factor for Nine Drums w/ Lead Shielding . During the Washington T1 evaluation, the EPA evaluation team d iscussed all technical concerns and apparent discrepancies with INL-CCP personnel and q uestioned INL-CCP personnel regarding a variety of technical aspects related to the twelve containers of M-4 Cell RH wastes. The EPA evaluation team found that Revision 4 of CCP-AK-ORN L-501 adequately documented the radiological characterization process for these was tes, and the calculation packages cited above adequately supported the activities upon which the radiological characterization of the twelve containers of INL-CCP RH wastes was based. There w ere no issues related to the documentation of technical aspects of the INL-CCP r adiological characterization approach for the addition of twelve containers to Waste Stream I D-ANLE-S5000.

(4) The technical basis and derivation of TMU were evaluated and were found to be adequate.

The development of TMU for INL Waste Stream No. ID- ANLE-S5000 is based on the propagation of uncertainties present in all aspects of the determination of the radiological constituents of RH TRU waste. These aspects are as sumed to be independent, which allows them to be added in quadrature. The TMU determinat ion included contributions of the following:

• Drum weight measurement for the 3 drums without int ernal lead shielding (not applicable to the nine drums with internal shielding)

• Measurement uncertainty attributed to dose rate det ermination and mass spectrometry

• DTC correlation, which incorporated MCNP5 modeling issues and drum weight measurements for the 3 drums without internal lead shielding (not applicable to the drums with internal shielding); density uncertainty for the internally shielded drums were considered to be sufficiently small to exclude from direct calculation, as documented in INL-RH-88

• Scaling factor uncertainty, which incorporated: di fferences in fuel pin compositions; individual fuel in contribution due to machining (c uts); ORIGEN2.2 code, modeling and benchmarking uncertainties; and contribution of un- irradiated fuel pins

• Microshield® and MCNP5 code and modeling issues

An overview of the approach to determining TMU for these twelve containers is presented in CCP-AK-INL-501, Revision 4, and is detailed in calc ulation package Nos. INL-RH-88, DTC Factor Uncertainty for 9 Drums w/ Pb Shielding ; INL-RH-05, Cs-137 Dose-to-Curie Correlation Uncertainty ; and INL-RH-07, Uncertainty Analysis for Drums . As discussed above, the appropriate adjustments had been made for the i nternally shielded container, and there were22

no concerns regarding the technical derivation and documentation of TMU for these twelve drums of INL RH wastes as a part of Waste Stream ID -ANLE-S5000.

(5) RH and TRU determinations were assessed and wer e found to be adequate.

The determination that the RH containers meet the d efinition of TRU wastes and RH wastes was examined during the baseline inspection. Both of t hese aspects are directly involved with the DTC measurement at the INTEC Facility at INL, consi stent with what EPA had observed during the baseline inspection. These were not assessed d irectly during this T1 evaluation, but EPA did verify that no aspects of these two determinations had changed. The results for all twelve containers that were reviewed as part of this T1 ev aluation are documented in DTC BRD No. INLRHDTC09007. All twelve containers were clearly TRU, i.e., contained more than 100 nano Curies per gram (nCi/g) of transuranic radionuclide s. All containers that were reviewed as part of this T1 evaluation were clearly RH, i.e., had an external contact dose rate greater than 200 mRem/hr. There were no technical or documentation- related concerns regarding the TRU and RH determinations for these twelve containers of M- 4 Cell RH waste.

Summary of Radiological Characterization

Findings or Concerns

The EPA Inspection Team did not identify any findin gs or concerns relative to the radiological characterization of the twelve containers of M-4 Ce ll wastes to Waste Stream No. ID-ANLES5000 during this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations assigned to radiological characterization during th e baseline approval.

5.0 EVALUATION OF NEW RH WASTE STREAM ID-HFEF-S5400-RH

Waste Stream ID-HFEF-S5400-RH consists of 28 HFEF-5 canister inserts of RH TRU heterogeneous debris wastes stored at the INTEC fac ility at INL. The wastes themselves consist of bags, blotter paper, bottles, containers, equipm ent/tools, hardware, hoses, etc. These materials were generated from: hot cell operations at Buildi ng 785, HFEF; fuel fabrication and reprocessing at Building 765, Fuel Conditioning Fac ility (FCF); and analytical chemistry operations at Building 752, Laboratory and Office ( L&O) Building Analytical Laboratory, including destructive examinations. A total of 83 canister liners of RH TRU wastes were generated and these casks are the subject of this T 1 evaluation. INL-CCP expects that upon repackaging, these materials will generate approxim ately 170 55-gallon drums for a total waste volume of approximately 35 m 3 . Much of the documentation prepared by INL-CCP fo r these wastes indicates that it applies to Lots 1A and 1B; however, the scope of this T1 evaluation includes only containers from Lot 1A. Lot 1B conta iners are specifically excluded from this T1 evaluation. A separate T1 change approval request will be needed for the Lot 1B containers.23

5.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion to determine whether INL-CCP demonstrated compliance with 40 CFR 194.8 requireme nts for RH Waste Stream ID-HFEF-S5400-RH.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the followi ng with respect to the use of Acceptable Knowledge for waste characterization:

• Definition and identification of the waste stream

• Radiological characteristics of the waste

• Physical composition of the waste, including the pr esence of liquids

• Identification of HLW, TRU vs. LLW, SNF

• Compiling AK documentation and assembly of required information, including the AKSR and adequacy of WCPIP AK process implementatio n

• AK data traceability

• AK source document sufficiency

• WCPIP interpretation including AK qualification, an d Certification Plan/CTP preparation/adequacy and use of LANL mass spectrome try data

• CRR adequacy

• CSSF and CH-RH correlation

• Personnel training

• WSPF adequacy and compliance with WCPIP requirement s

• NCRs and AK discrepancy resolution

• AK accuracy

• Defense determination

• Load management

• DQOs attained through AK Qualification

Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, required for ms, and other data were provided to EPA, and relevant sources were examined as part of this T1 inspection. The listing of all documentation is in Attachment B, and the list of B DRs examined is presented in Table 6.24 Table 6. Batch Document Reports Examined

Drum Number RTR BDR Number DTC BDR Number IDAWANL820118A INLRHRTR09006 INLRHDTC09006 IDAWANL820118B INLRHRTR09006 INLRHDTC09006 IDAWANL820066A INLRHRTR09008 INLRHDTC09008 IDAWANL820066B INLRHRTR09008 INLRHDTC09008 IDAWANL810091A INLRHRTR09008 INLRHDTC09008 IDAWANL810091B INLRHRTR09008 INLRHDTC09008

CCP-AK-INL-580, Revision 1 (the AKSR) states that W aste Stream ID-HFEF-S5400-RH consists of 86 HFEF-5 cans of RH TRU heterogeneous debris waste that was generated during hot cell and laboratory activities. The waste was generated in hot cells from April 1977 to September 2007 during hot cell and laboratory activ ities to support the Liquid Metal Fast Breeder Reactor (LMFBR), Integral Fast Reactor (IFR ) irradiation studies performed on alloy fuel, and sample materials irradiated in the Experi mental Breeder Reactor (EBR)-II. INL-CCP representatives indicated that the waste stream was generated in three hot cell operational locations: INL MFC Building 785, HFEF (formerly HF EF-North); Building 765, FCF (formerly HFEF-South); and Building 752, the L&O Building Ana lytical Laboratory. The waste is currently stored at INTEC and the Materials and Fue l Complex (MFC) Radioactive Scrap Waste Facility (RSWF), pending transfer to INTEC.

Based on the AKSR, Lot 1A consists of 28 cans. INL -CCP will divide each can into two or more 55-gallon drums. Any cans other than these 28 will be a separate lot (e.g., Lot 1B) requiring a separate T1 evaluation and approval.

CCP-AK-INL-582, Revision 0 states that with the exc eption of “payload container based parameters,” AK will be used to document that each RH TRU waste DQO is met. This document further states, “The CCP intends to use a combination of methods to qualify the AK information defining the isotopic ratios, physical form, and absence of residual liquids associated with this waste stream because it makes the best us e of the information available (such as availability of confirmation sample results).” Spe cifically, INL-CCP proposed to use fuel pin information as input to ORIGEN to develop isotopic ratios. The isotopic ratios were to be verified (qualified) through use of the mass spectr ometry data associated with LANL fuel pins. This approach is the same as that which EPA evaluat ed and approved for the baseline inspections of RH waste streams from INL, ANL-E, and LANL. 8

Technical Evaluation

(1) Waste Stream ID-HFEF-S5400-RH was examined with respect to waste stream definition and was found to be adequate following the successf ul resolution of an EPA concern.

The WCPIP defines a waste stream as consisting of “ waste material generated from a single process or activity, or as waste with similar physi cal, chemical, and radiological properties.” The waste stream examined, ID-HFEF-S5400-RH, is a debri s waste stream generated at three

8 The INL-CCP RH final approval is in EPA Docket No. A-98-49; II-A4-72; the ANL-E RH final approval is in A-98-49; II-A4-72; and the LANL-CCP RH final approv al is in A-98-49; II-A4-88.25

primary locations at INL: INL MFC Building 785, HF EF (formerly HFEF-North); Building 765, FCF (formerly HFEF-South); and Building 752, the L& O Building Analytical Laboratory. EPA examined the information in the AKSR to determine w hether the single process argument and/or commonality of physical, chemical, and radiological properties argument were valid for this waste stream. EPA found the waste stream justifica tion to be lacking, and this issue was discussed with INL-CCP AK personnel. EPA issued EP A Evaluation Issue Concern Form No. INL-RH

- AK-09

- 002CR, which is included as Attachment D to this re port. This concern has four parts, one of which is discussed below. Note that t he numbering of the concern items reflects the order in which these issues were addressed during t he T1 evaluation and the four items are not discussed in numerical order in this report.

EPA Evaluation Issue INL-RH-AK-09-002CR, Item 1: The AKSR requires additional information to justify the waste stream designation . Table(s) and/or text should be added to show commonality of processes and test material(s) in and among the three areas sufficient to show that the same processes and materials were man aged throughout the HFEF, FCF, and Analytical Laboratory to support the use of a singl e scaling factor. Note that revision of other sections (e.g., Section 5.4.5, SNF/HLW discussion) may be warranted, depending on the additional information.

Resolution: In response to the above concern, INL-CCP provided additional information pertaining to the waste stream designation through a revised AKSR entitled CCP-AK-INL-580, Central Characterization Project Acceptable Knowled ge Summary Report For Remote-Handled Transuranic Debris Waste From Materials and Fuels C omplex Hot Fuel Examination Facility at the Idaho National Laboratory Waste Stream ID-HFEF- S5400-RH Revision 2, Tier 1MARKUPSS Month XX, 2010 as a freeze file, hereafter referred to as the AKS R Markup. The following was included in the AKSR Markup in respon se to this concern. Note that information presented to support Items 2, 3, and 4 of this conc ern also supports the waste stream determination.

4.2.2 Types and Quantities of TRU Waste Generated

... Waste Stream ID-HFEF-S5400-RH meets the WIPP-WAP a nd the WCPIP waste stream definitions of “waste materials genera ted from a single process or from an activity that are similar in material, phys ical form, and radiological constituents.” The container specific records have been reviewed for each container to verify the composition and origin of t he waste stream inventory. Every container in waste stream ID-HFEF-S5400-RH was generated from HFEF and FCF operations (References U483, U484, U541, U5 52). Waste generating operations in the HFEF and FCF are the same or simi lar and irradiated materials were transferred to these facilities for examination based on available facilities (References C465, U551). The operations in the facilities remained relatively unchanged, examining the same type of ma terials in approximately the same relative percentages. Most of the HFEF-5 cans were generated in HFEF because FCF facilities were refurbished from the mi d 1970s to early 1980s. The majority of materials examined (approximately 90 pe rcent) consisted of EBR-II irradiated fuels, of which approximately 51 percent was uranium-zirconium-26

plutonium (U-Zr-Pu) or U-Zr alloy fuels, 30 percent was uranium-fissium 9 (UFs), and approximately 7 percent was depleted urani um (DU). Approximately 10 percent of the materials examined consisted of mate rials irradiated in other reactors, of which approximately 41 percent was lig ht water reactor (LWR) or LWBR, approximately 29 percent was RERTR, approxima tely 24 percent was UZr or U-Zr-Pu alloy from FFTF, and approximately 6 percent was Sodium Loop Safety Facility (SLSF) materials from the ETR (Refe rences C465, C503, P263, U483, U484, U541, U551, U552). Samples transferred to the Analytical Laboratory were prepared in the HFEF or FCF. High a ctivity waste from the Analytical Laboratory generated from analysis of th ese samples was transferred back to the HFEF or FCF for disposal (References C2 14, U483, U484, U541, U552). These wastes were packaged in individual HF EF-5 cans with wastes generated in the HFEF or FCF (References U483, U484 , U541, U552). Due to these material management practices, in conjunction with the destructive nature of the examinations further delineation of this was te stream, based on radiological contamination, is not possible. The w aste stream also contains waste materials generated during maintenance and wa ste management activities that could contain any radiological materials conta minating the cell surfaces and equipment. In addition, the waste will be repackag ed into WIPP-approved containers at INTEC in the NWCF Cell 308 or the FDP Cell (References C464, C465, C698, P083, P089, P092, P102, P105, P115, P18 2, U483, U484, U541, U551, U552).

Status of Concern: The above response to EPA’s concern is adequate and the concern is closed. EPA expects the AKSR Markups to be include d in the next formal revision of the AKSR. Providing revisions to the AKSR is a Tier 2 change. The Tiering Table for INL-CCP RH has been modified to reflect the need for all wa ste streams to have similar reporting requirements.

(2) The radiological characteristics of the waste s tream were evaluated, and were found to be adequate following the successful resolution of an EPA concern

The AKSR includes only a generalized table that app ears to summarize radiological data for the 86 cans, and shows that a wide range of radionuclid es may be present from both a weight and activity perspective. INL-CCP states: “Based on g enerator reported radionuclides, the two predominant isotopes for the waste stream are U-235 and U-238, while over 95 percent of the total activity in the waste stream is from Ce-144, Co-58, Co-60, Cr-51, Cs-137, Mn-54, Sr-90, and Y-90.” INL-CCP also states that the “radionucl ide weight percent of individual radionuclides varies greatly on a container-by-cont ainer basis. Because of this variability, some containers will not include the waste stream predom inant radionuclides, but may include other radionuclides expected in this waste stream.” EPA examined Table 5 in the AKSR that verified the assertion that the radionuclide content of each container may be quite variable.

9 Fissium is an equilibrium mixture of fission produ cts in reactor fuel that improves the stability of uranium and uranium-plutonium fuel alloys under fast neutron ir radiation.27

However, CCP-AK-INL-581, Revision 0 appears to incl ude additional AK information that has been evaluated in-depth to obtain a more detailed d epiction of the Lot 1A radionuclide distributions. Data examined under the CCP-AK-INL- 581 document preparation/analysis included, but was not limited to, the following was te record types that were used to identify the fuel elements associated with this waste stream:

• 6-ft (183 cm) waste can logs

• Curie contribution calculated from fuel masses tabl es

• Curie content data tables

• Contents in waste can tables

• RH TRU waste can loading logs

• Analytical lab results records

• FCF waste container logs

• ANL-HFEF complex inventory container listing record s

• SS material transfers records

• Breakdown for waste can records

• HFEF fuel inventory accounting system records

• Metallography sample records

All the above information is AK, which INL-CCP comb ined with fuel pin data, modeling, and other activities to develop scaling factors that in cluded the 10 EPA WIPP-tracked radionuclides.

Examination of the AKSR, AK source documents, and C CP-AK-INL-581 poses questions regarding completeness of the AKSR with respect to the presentation and analysis of radiological data, as well as whether the AKSR adequately suppor ted the single waste stream designation. This issue was discussed with INL-CCP AK personnel and EPA issued EPA Evaluation Issue Concern Form No. INL-RH

- AK-09

- 002CR, which is included as Attachment D to this re port. This concern has four parts and the part that is re levant to this issue is discussed below.

EPA Evaluation Issue INL-RH-AK-09-002CR, Item 4: Section 5.4.3, Radiological Characterization, does not adequately address histo rical information or data pertaining to the WIPP-tracked radionuclides, including the anticipat ed isotopic distributions by general programs (or other suitable designation) in support of the w aste stream designation.

Resolution: INL-CCP responded to this concern by providing an AKSR Markup that included extensive text revisions (e.g., Section 5.4.3) desc ribing the fuel elements, their fuel types, isotopic distributions and other pertinent informat ion, including many references.

Status of Concern: The response to EPA’s concern is adequate and the c oncern is closed. EPA expects the AKSR Markups to be included in the next formal revision of the AKSR. Providing revisions to the AKSR is a Tier 2 change. The INL- CCP RH tiering table (See Tables 1 and 9) has been modified to reflect the need for all waste streams to have similar reporting requirements.28

(3) Physical characteristics of the waste stream w ere examined, including the presence of prohibited items (liquids) and were found to be ade quately addressed following the successful resolution of an EPA concern.

The AKSR states that Waste Stream ID-HFEF-S5400-RH contains the spectrum of debris material including, but not limited to:

• Cellulosic materials (e.g., including blotter paper, cardboard , cotton balls and swabs, HEPA filters, Kim wipes, mop heads, paint brushes, paper (e.g., cups, polishing discs/sandpaper, and smear wipes), rags, rope, spon ges, and terri-towels)

• Plastic materials, including bags, bottles, caps, extension cords, funnels, hoses, paint brushes, nylon rope, personal protective equipment (PPE), Plexiglass, sample vials, sheeting, sleeves, sponges, syringes, tape, trays, and tubing (e.g., Tygon) and other PVC/plastic material

• Rubber items, including bands, extension cords, gaskets, g loves, hoses, pads, slave manipulator boots, and tubing; rubber debris materi als may be composed of neoprene

• Glass items, including beakers, broken glass, ceramics, f iberglass insulation, filter media (e.g., fiberglass), glass wool, labware, lenses, li ght bulbs, magnifying glass, mirrors, and sample vials

• Metal (ferrous) items, including caps, cladding pieces, c ontainers (e.g., beakers, cans, tubes, and vials), equipment/tools, fuel pin cuttin gs/filings and samples, hardware (e.g., bolts, brackets), manipulator parts, piping, plates , scrap, subassembly hardware, tubing, and wire

• Metal (nonferrous) items, including cladding pieces, cont ainers (e.g., cans, liners, tubes, and vials), equipment/tools (e.g., balance, fitting s, gears, etc), fuel pin cuttings/filings and samples, piping, rods, scrap, sources, subassembly hardware, tubing, and wire composed of, or contaminated with, various metals

The AKSR states that Waste Stream ID-HFEF-S5400-RH “may contain lesser amounts (less than 50 percent volume in any container) of homogen eous solids,” as well as small quantities of absorbent, sweepings, and epoxy resins. It also st ates, “However, any payload container consisting of more than 50% by volume of homogeneou s solids will be excluded from this waste stream.” The AKSR included a tabulation of waste m aterial parameters by weight indicating that the waste stream is anticipated to be approximately 71% inorganic and 29% organic material, with metals making up the vast majority of the wast e stream by weight (54%).

The presence of prohibited items (liquids) was eval uated. INL-CCP representatives indicated that cans containing liquids have been identified. For example, can IDAWANL820118 was found to contain liquid when it was opened for sepa ration into two drums. Remediation of the waste took place prior to placement in the drums. The Drum Repackaging Data Sheet (Reference IDAWANL820118) documents this discovery and the subsequent remediation. This is consistent with the AKSR, which states, “absorbe d liquids are present and residual liquids due to dewatering or incomplete absorption are possible .”29

EPA examined this information and associated refere nces and questioned whether the waste stream had been adequately defined. EPA noted that the waste stream included two hot cells and one laboratory, which can generate vastly different types of debris waste. INL-CCP representatives stated that while the South and Nort h cell wastes were distinct and not physically commingled, laboratory waste was transferred throug h a pneumatic transfer system to either of the laboratories. However, the waste commingling w as not clearly defined in the AKSR. This issue was discussed with INL-CCP AK personnel and E PA issued EPA Evaluation Issue Concern Form No. INL-RH

- AK-09

- 002CR, which is included as Attachment D to this re port. This concern has four parts, and the part that is r elevant to this issue is discussed below.

EPA Evaluation Issue INL-RH-AK-09-002CR, Item 3: The waste generation and management stream must be better presented to show how/if wastes are physically commingled (e.g., Analytical Lab to HFEF and FCF).

Resolution: INL-CCP responded to this concern by providing an A KSR Markup that provided more detailed descriptions of the RH TRU waste mana gement practices, including specifics regarding the sizes of internal waste containers an d the collection, transfer and staging practices for materials within the facilities of interest (Se ction 4.2 RH TRU Waste Management).

Status of Concern: The response to EPA’s concern is adequate and the concern is closed. EPA expects the AKSR Markups to be included in the next formal revision of the AKSR. Providing revisions to the AKSR is a Tier 2 change. The INL-C CP RH tiering table (Tables 1 and 9) has been modified to reflect the need for all waste str eams to have similar reporting requirements.

(4) The identification of HLW, TRU versus LLW, an d SNF was examined and was found to be adequate.

INL-CCP stated the following with respect to the oc currence of SNF and HLW in Waste Stream ID-HFEF-S5400-RH: “The WIPP LWA...prohibits the disp osal of spent nuclear fuel and highlevel waste as defined by the NWPA...[and DOE clarifi es that]... Test specimens of fissionable material irradiated for research and development on ly, and not production of power or plutonium, may be classified as waste, and managed in accordance with [the DOE Order M 435.1-1] when it is technically infeasible, cost pr ohibitive, or would increase worker exposure to separate the remaining test specimens from other co ntaminated material.” INL-CCP contends that material within Waste Stream ID-HFEF-S5400-RH Lot 1A is properly considered to be test specimens and thus falls under this exclusion. INL -CCP has stated that since SNF is not present, HLW could not have been produced as a result of phy sical or chemical processing of these materials. INL-CCP concludes:

Waste Stream ID-HFEF-S5400-RH consists of heterogen eous debris [that]... inherently contains test residues, test materials, and the resultant test fragments from the fuel pin test specimens, including irradia ted pin fragments and dispersed particulate (fines and dust). The analysis and exa mination of irradiated fuels did not involve reprocessing of constituent elements fr om reactor fuel. In addition, waste from fuel reprocessing and the analysis of re processed fuel performed in these facilities was not identified in this waste s tream. Therefore, the waste is not30

a spent nuclear fuel, not high-level waste, nor a w aste historically managed as high-level waste, and is eligible for disposal at t he WIPP as RH TRU waste.

INL-CCP representatives indicated that they do not anticipate any of the resulting analysis will identify LLW. EPA examined the SNF, HLW, and LLW a rguments and found them to be consistent with those presented in other approved R H waste stream AKSRs.

(5) Sufficiency of the AKSR and implementation of the AK process were evaluated and were found to be adequate.

Attachment A of the WCPIP mandates a process that s hould be followed to collect and analyze AK data, similar to the process used for CH waste. Both the content of the AKSR and sufficiency of AK implementation were assessed.

EPA examined the AKSR and found that information wi th respect to waste stream generation, commingling of radiological constituents, and radio logical characterization was lacking [see Items (1) and (2) above, and Item (15), below]. Ho wever, INL-CCP subsequently addressed these concerns in the AKSR Markup and provided exte nsive revisions to the AKSR through freeze file changes. EPA found these changes to be adequate evidence of INL-CCP’s commitment to modify the various documents. EPA ex pects to be notified when the AKSR is updated to include the submitted modifications; thi s update will be provided to EPA as a T2 change.

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

EPA selected six 55-gallon drum containers for trac eability analysis: IDAWANL820118A and IDAWANL820118B; IDAWANL820066A and IDAWANL820066B; and IDAWANL810091A and IDAWANL810091B. INL-CCP indicated that these d rums originated from three common original containers, referred to hereafter as conta iner Nos. 118, 91, and 66. Using CCP-AK-INL581, Revision 0 and other references, the correspon ding Liner ID Nos. and canister numbers can be derived as shown in Table 7 below.

Table 7. Drum Traceability Information, Waste Stre am ID-HFEF-S5400-RH

Drum Number Original Container ID Number Liner ID Number Canister/Container/

Can Number IDAWANL820118A IDAWANL820118B IDAWANL820118 IDAW82-118 N-96

IDAWANL820066A IDAWANL820066B IDAWANL820066 IDAW80-66 N-94

IDAWANL810091A IDAWANL810091B IDAWANL810091 IDAW81-91 N-79

The IWTS (Reference P298) is a site-specific system used by INL to track waste movement and to document general radiological information about the container. The original container Identification Number was obtained from this refere nce, and was used to identify the corresponding Liner ID Number and Canister/Can numb ers presented in Table 1-1 of31

CCP-AK-INL-581. These numbers were then used to id entify references that contained original paperwork traced back to original waste cans that w ere subsequently emplaced in other containers/liners, renamed, and transported to stor age areas.

EPA used the above information, together with sprea dsheets and references provided by INL-CCP (e.g., P084 and U484), to evaluate the type of data available for each drum, and the traceability of that information. EPA’s review ind icated that paperwork is available from the final INL-CCP drum at the can/container level and i s often traceable to individual fuel pins. This conclusion is echoed in INL-CCP-AK-581, which state s: “The review of the AK source documents associated with ID-HFEF-S5400-RH identifi ed the subassemblies and fuel elements associated with each HFEF canister liners.” EPA co ncluded that the information examined suggests detailed information is available for each container/can, and can be traced from the point of generation through INL-CCP drum management

. (7) Sufficiency of AK support documents and relat ed document tracking was evaluated and was found to be adequate.

INL-CCP provided numerous supporting documents and Attachment 4 (i.e. the full reference list), which listed all of the available support do cuments. Subsequent to the inspection and as a result of EPA’s concerns, INL-CCP increased the num ber of source documents used to generate the AKSR, updated Attachment 4 to include all perti nent references and provided an updated AK reference list. It was noted that the reference li st associated with the AKSR did not include several of the relevant documents in Attachment 4 t hat were given to EPA as supporting documents for the waste stream during the T1 evalua tion. EPA recognizes that reference lists are dynamic, and expects the next revision of the AKSR to be as complete as possible.

(8) Interpretation of WCPIP, with respect to contents o f the Certification Plan and CTP, was evaluated, including mandatory content of the CTP a nd the use of LANL mass spectrometry data for DTC AK Qualification, and wer e found to be adequate.

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’s intent was that the sites specify and document exactly how characterization i s to take place on a waste stream basis, followed by a detailed plan explaining implementati on of confirmatory testing when this is to take place.

INL-CCP-AK-582, Revision 0 states that INL-CCP woul d use a combination of methods to qualify AK based on isotopic ratios derived from Oa k Ridge Isotope Generation (ORIGEN) modeling and confirmed by LANL measurement data. T he same process has been used at other RH sites and EPA had previously examined and approv ed the use of the LANL mass spectrometry data used by INL-CCP to qualify the fu el pin data at other RH sites, so it was not necessary to revisit the actual data. However, EPA did examine the arguments posed regarding the use and applicability of this information to th e ID-HFEF-S5400-RH waste stream.

INL-CCP-AK-582 also states that the HFEF waste is s imilar to waste at the other RH sites and the ORIGEN model applies here as well. B ecause the AK is similar between32

LANL and INL-HFEF, the requirement to qualify radio logical parameters can be met using the LANL sampling results. To verify this as sertion, EPA examined the original mass spectroscopy documentation presented in CCP-AK -INL-581, as well as in EPA’s RH baseline approval reports for ANLE-CCP, INL-CCP and LANL-CCP. The purpose of this analysis was to verify that mass spectromet ry data are representative of the Lot 1A cans, and that INL-CCP is therefore justified in us ing these results in waste characterization activities. CCP-AK-INL-581, Revis ion 0 states:

Approximately 90 percent of the irradiated fuel pin s included in the HFEF examination program were from the fast breeder prog ram and, as such, had similar fuel types, common sponsors or experimenter s, and an identical reactor (EBR-II) as did LANL... The remaining 10 percent of t he fuel pins were irradiated in the various reactors, such as, Shippingport LWBR , Belgium Reactor 3 (BR-3), and FFTF and share common sponsors and experimenter s as the LANL work...

INL-CCP has proposed the use of mass spectrometry d ata obtained from LANL to verify the output of the ORIGEN2.2 for INL data. INL-CCP stat es that the LANL fuel pins have similar origins, overlapping experimenters, similar if not the same reactor irradiation or sources, and therefore have sufficiently similar radionuclide co ntent, so the use of LANL data for this purpose is appropriate. INL-CCP revised the AKSR to includ e information detailing the 90% EBR II, 10% other reactor breakdown (see Item 2, above).

In the INL-CCP RH baseline determination, EPA accep ted the approach that INL-CCP implemented regarding use and commonality of the LA NL mass spectrometry data to verify the modeling results. EPA requested information from I NL-CCP regarding the correlation of Lot 1A fuel pins to specific experiment sponsors and other waste-related information, and there was considerable dialogue between EPA AK personnel and INL-CCP personnel. EPA AK personnel sought to identify the objective evidence that clea rly supported the INL-CCP’s positions; however, such information is not available. INL-CC P’s approach is based on three related aspects:

• The link between the ORIGEN2.2 results and the mass spectrometry results is quite good, leading INL-CCP personnel to conclude that the inpu t information was reliable.

• The sponsors in both the LANL and INL programs were the same, and since the information on fuel characteristics was appropriate at LANL, there was no reason to assume the same type of information would be less r eliable for INL.

• There was a direct comparison of nine fuel pins tha t had been examined at both LANL and INL to demonstrate that the information sources used at LANL to extract input information were identical to those used at INL to extract the same information.

Based on this information, EPA concluded that INL-C CP demonstrated applicability of the LANL mass spectroscopy data to the INL program by s howing commonality of experiments, sponsors, and other data. Revision of CCP-AK-INL-5 81, Revision 0 is a T2 change.33

EPA evaluated the CTP to determine whether it inclu ded the specific elements that the CTP must have as defined in the WCPIP and found the CTP to b e complete in this regard. Revision to CCP-AK-582, Revision 0 is a T2 change.

(9) Content and technical adequacy of the CRR wer e evaluated and both were found to be adequate.

The content of the CRR was examined to ensure that this report reflected requirements of CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic W aste Acceptable Knowledge Characterization Reconciliation Report . Specifically, the CRR was evaluated to determine the completeness and adequacy of its cont ents as required in the WCPIP.

INL-CCP representatives provided an Excel version o f the CRR. This form included the necessary information, but did not include the sign ature of the SPM. Following the inspection, INL-CCP provided a full copy of applicable portions of the CRR that met the requirements of the WCPIP in pdf format. Notification of availability of a revised CRR is a Tier 2 change.

(10) Use of a CSSF was evaluated and was found to be adequate.

Completion of a CSSF is required when AK informatio n from a related CH waste stream is used in the RH waste characterization process. The INL- CCP representative indicated that CH data were not used in this manner, so a CSSF was not pre pared for this stream. However, a CSSF was completed to support the correlation of LANL ma ss spectrometry data and INL-CCP data for subsequent use in AK qualification as part of t he INL-CCP baseline inspection, and EPA questioned whether this form was also completed for the same use of LANL mass spectrometry data for the ID-HFEF-S5400-RH waste stream. The us e of a CSSF for this purpose is acceptable, noting that it should reference detaile d reports, memoranda, or other supporting data sources, and should clearly state why the form is b eing used (e.g., in this case, to allow use of destructive assay data performed on LANL fuel pins as being representative or correlative to similar fuel pins at INL). INL-CCP representatives indicated that a new CSSF was not prepared. See Item (8), above, for EPA concerns regarding use of the mass spectrometry data.

(11) Personnel training was evaluated and was fou nd to be adequate.

Scott Smith was the AKE who prepared the AKSR, and Mark Doherty is the SPM who prepared the Certification Plan/CTP. The AKE Qualification Cards were examined to determine whether both individuals’ training was up to date. Neither document indicated that the AKEs had read required materials pertinent to INL-CCP. Apparentl y, the process has changed so that the Qualification Cards are not kept up to date; instea d an e-mail verification method is used to ensure each individual receives and completes site- specific reading. Documentation that both individuals have read the required AK Source Docume nts was sent to EPA via e-mail following this evaluation. It should be noted that the docum entation examined did not indicate that INL-CCP individuals are trained to EPA requirements , nor are they trained with respect to radiological characterization aspects, both of whic h are required in the WCPIP. Since the WCPIP is currently under revision, EPA will examine future training against the modified WCPIP.34

(12) The WSPF was examined and was found to be ade quate.

INL-CCP representatives provided a draft WSPF, with out required signatures or attachments. Notification of availability of the final WSPF is a T2 change. The INL-CCP RH tiering table (Tables 1 and 9) has been modified to reflect the n eed for all waste streams to have similar reporting requirements.

(13) NCRs and DR Forms were examined and were foun d to be adequate.

INL-CCP provided a single DR associated with this w aste stream that dealt with the assignment of hazardous waste numbers to a previously non-haza rdous waste stream. INL-CCP representatives did not indicate that there were an y other DRs available for review and they provided NCR-RHINL-0508-09 that concerned container IDAWANL8100091A, which concerned the omission of a page from the BDR Attac hment 2 and failure of the ITR to identify this deficiency during BDR review. The provided DR s and NCRs verified continued preparation of these key documents as part of the AK process.

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

AK accuracy was assessed with respect to the requir ed contents as presented in the WCPIP. The WCPIP requires AK accuracy be assessed in three are as: reassignment of the waste to a different SCG; reassignment of the waste to a different waste stream; and waste stream-specific assessment of radiological parameter accuracy. INL -CCP provided a draft AK accuracy report that indicated no discrepancies were noted, and whi ch listed verification of AK-based DQOs. Although not explicitly stated, presentation of the DQOs in this manner shows that the SCG assignment was not modified, the drums were not pla ced in a different waste stream, and some of the general radiological parameters (i.e., TRU and RH determination) were met through implementation of the WCPIP and comparison to the A K Record. Notification of availability of a final AK accuracy report for this stream is a T2 change. The Tiering Table for INL-CCP RH (Tables 1 and 9) has been modified to reflect the n eed for all waste streams to have similar reporting requirements.

(15) The discussion provided to resolve EPA conce rn below supports defense status of the
waste.

The AKSR discussed several defense-related activiti es, but did not adequately correlate these to activities that generated Waste Stream ID-HFEF-S540 0-RH. This issue was discussed with INL-CCP AK personnel and EPA issued EPA Evaluation Issue Concern Form No. INL-RH

- AK-09

- 002CR, which is included as Attachment D to this re port. This concern has four parts, and the part that is relevant to this elemen t is discussed below:

EPA Evaluation Issue INL-RH-AK-09-002CR, Item 2: The defense determination in Section 4.1.4 includes numerous activities that are defense -related, but must be better correlated to specific process areas to show association with was tes generated from the HFEF, FCF, and Analytical Laboratory.35

Resolution: INL-CCP provided an AKSR Markup that provided addit ional details in Section 4.1.4, Defense Determination, regarding the correla tion of specific process areas to wastes from HFEF, FCE, and the Analytical Laboratory. The revi sed text provided a stronger link of these materials to defense-related activities, as well as an adequate explanation of waste commingling and cited numerous references.

Status of Concern: The response to EPA’s concern is adequate and the concern is closed. EPA expects the AKSR Markups to be included in the next formal revision of the AKSR. Providing revisions to the AKSR is a Tier 2 change. The INL- CCP RH tiering table (Tables 1 and 9) has been modified to reflect the need for all waste str eams to have similar reporting requirements.

(16) Load Management was assessed and was determi ned to not apply to this waste stream.

INL-CCP representatives indicated that load managem ent will not be performed for this waste stream. Implementation of load management is a T1 change.

(17) Attainment of DQOs through AK qualification was eva luated and was found to be adequate.

As a result of the analysis presented in Items 1-16 , 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 cani ster, including quantification and identification of the 10 EPA WIPP-tracked radionucl ides)

• Residual liquids

• Physical form, including metals and CPR

When evaluated as a whole, CCP-AK-INL-580, Revision 1, CCP-AK-INL-581, Revision 0, CCP-AK-INL-582, Revision 0, and the supporting sour ce documents presented in Attachment A of this report indicate that the DQOs, as specified in the WCPIP, have been met.

Summary of Acceptable Knowledge

Findings or Concerns

The EPA Inspection Team did not identify any findin gs relative to the addition of the containers from Lot 1A of Waste Stream ID-HFEF-S54000-RH, whic h were the subject of this T1 change evaluation. One concern related to AK was identifi ed and this is discussed above. All four aspects of this concern were adequately addressed s ubsequent to the T1 evaluation and there are no open issues relative to the T1 evaluation of the addition of INL RH Waste Stream ID-HFEF-S54000-RH.36

Tiering Changes

Based on the results of this T1 evaluation, there a re no substantive changes to the T1 and T2 designations that were assigned to AK for INL-CCP d uring the baseline approval. However, the INL-CCP RH tiering table (Tables 1 and 9) has been modified to reflect the need for all waste streams to have similar reporting requirements.

5.2 Radiological Characterization

RH Waste Overview

CCP-AK-INL-580 presents a comprehensive description of these wastes, as does Section 4.2.1 of this report. A total of 83 canister liners of R H TRU wastes were generated and these casks are the subject of this T1 evaluation. INL-CCP expects that upon repackaging, these materials will generate approximately 170 55-gallon drums for a to tal waste volume of approximately 35 m 3

. Much of the documentation prepared by INL-CCP for t hese wastes indicates that it applies to Lots 1A and 1B; however, the scope of this T1 evalu ation includes only containers from Lot 1A. Lot 1B containers are specifically excluded from th is T1 evaluation. CBFO will submit a T1 change approval request for Lot 1B containers, when appropriate.

Radiological Characterization Overview

The overall approach to characterizing these waste drums is DTC in conjunction with radionuclide-specific scaling factors, a technique that EPA has observed and approved at several sites previously, as discussed in Section 4.1.2. T he radionuclide-specific scaling factors were developed based on information describing the attri butes of the fuel pins and fuel materials that generated these wastes, i.e., detailed radionuclide composition and burnup. The modeling that was performed incorporated 129 of the 159 total fue l pins (81%) and resulted in a single set of scaling factors to be applied to the entire waste s tream. An overview of the radiological characterization process used for the ID-HFEF-S5400 -RH Lot 1A wastes is provided in Figure 1, below.

As was the case when the twelve containers of M-4 C ell RH waste were added to Waste Stream ID-ANLE-S5000 (see Section 4.2.1), the DTC measurem ent aspect of this HFEF waste stream was not directly assessed during this T1 evaluation in Washington, D.C. The DTC operation at INL had been evaluated during the INL-CCP baseline inspection and EPA had approved it at that time. EPA did evaluate the characterization method s used for the INL-CCP HFEF RH wastes in terms of the technical adequacy of the approach, as supported by the program’s documents, procedures, and controls, and the knowledge and und erstanding of the personnel involved in the RH waste characterization program.37

Documents Reviewed

The list provided in Attachment B includes all docu ments related to the INL-CCP RH TRU radiological characterization program that were exa mined to support this T1 evaluation. This listing is comprehensive and includes documents tha t supported AK, as well as the addition of twelve containers of M-4 Cell RH waste that were ad ded to Waste Stream ID-ANLE-S5000, discussed in Section 4.1.2. Figure 1. Flow Diagram of the Characterization Process: ID-H FEF-S5400-RH, Lot 1A

Use the radiation transport code MCNP5 to model the gamma dose rate at one meter from the drum surface as a f unction of waste density to develop a 137 Cs and a 60 Co DTC correlation based on a 1-Ci source of 137 Cs and a 1-Ci source of 60 Co

Develop DTC correlation factors (mR/hr/Ci)-density relationships

for both 137 Cs and 60 Co

Execute DTC to Determine Drum’s 137 Cs Activity:

Find mean gamma dose rate at 1 m from the surface o f the drum based on four measurements; and determine the waste density based on the actual weight of drum contents and fil l factor

Using the correlation factors and the activity rati o of 60 Co to 137 Cs determine the combined DTC conversion factor

Divide the mean measured dose rate by the DTC conve rsion factor and apply 60 Co/ 137 Cs ratio to find the 137 Cs activity in Curies

Multiply the 137 Cs activity by the scaling factors to determine the activities of the radionuclides of interest Determine Scaling Factors: Determine DTC Conversion Factor:

Locate and retrieve relevant records

Use ORIGEN2.2 to determine the scaling factors, i.e., the total activity of each radionuclide divided by the total 137 Cs activity, based on the representative pre-irradiation composition for the fuel pins modeled, information, post-irradiation fuel information, and out-of-reactor decay time

Validate the modeling results by comparing the computer model outputs to measurement data38

Technical Evaluation

(1) The EPA inspection team evaluated the correlati on of the waste records for the 83 canister liners with the 137 Cs and 60 Co concentrations.

The information that formed the basis of the radiol ogical characterization process identified the radionuclides’ pre-irradiation composition of fuel, burn-up information and 129 fuel pins out of a total population of 159. Specifically, records for the 83 canister liners were reviewed to identify the fuel elements in this waste stream, including t he record types listed in CCP-AK-INL-581, Section 3.1. Pre-irradiation fuel composition and post-irradiation burn-up information was collected from these records, and this was used as input to ORIGEN2.2 for the 129 fuel pins. This exercise resulted in the development of values for 137 Cs and other radionuclides, and the derivation of scaling factors, i.e., the relationsh ip of easily measurable 137 Cs and 60 Co to other radionuclides, as discussed below. These activitie s are documented in INL-RH-61, INL-RH-62 and INL-RH-64 and incorporated information from ANL -E, ANL-W, INL, and LANL, including the following:

• Fuel pin type and characteristics from fuel supplie rs and reactor operators

• 235 U enrichment

• 240 Pu enrichment (for mixed oxide fuels) and burnup

• U/Pu ratios (for mixed oxide fuels)

• Examination of 603 fuel pins examined at ANL-E

• Mass spectrometry results for destructive assay of 400 fuel pins

• Other records related to AGHCF activities, names of experimenters, etc.

Calculation of the 137 Cs activity for a container allows the further calc ulation of the following quantities for each RH container measured:

• 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 bullet

• Fissile Gram Equivalent (FGE)

• Pu Equivalent Curies (PE Ci)

• Decay heat in Watts

The constants and other values required for these c alculations were taken from the appropriate sources (CH WAC and TRAMPAC) and were spot-checked for accuracy.

For these wastes, it was necessary to derive the co ntribution of 60 Co to the measured external dose rate. This was done by running twelve MCNP5 c ases with the source term uniformly distributed throughout a waste container for a rang e of waste densities from 1.0E-4 to 2.0 g/cm 3 for a 1-Curie source of both 60 Co and 137 Cs. The results of these were then used to derive a DTC correlation as a function of density for 137 Cs and 60 Co, as shown in CCP-AK-INL-581, Figures39

6-2 and 6-3, respectively. The actual DTC calculat ions are performed using an Excel spreadsheet where the input includes [see Section ( 3), below]:

• Drum identification number

• Container gross weight

• Fill height in percent

• Fill height material type (concrete, organic, or st eel)

• Four external dose rate measurements

There were no concerns regarding the correlation of waste records for the 83 canister liners with
137 Cs and 60 Co concentrations for this HFEF RH waste stream.

(2) The development of radionuclide scaling factors was evaluated and was found to be technically adequate and appropriately documented.

EPA evaluated the following aspects:

• Activity values were derived from modeling and stat istical metrics using the mean and standard deviation values for each radionuclide

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

• Isotopic activity values 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 and
60 Co for these HFEF RH TRU wastes

• Adjustment of the source distribution inside the dr ums for 137 Cs and 60 Co using MCNP5 calculated as a function of bulk waste density

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

• Appropriate decay correction according to INL-CCP p rocedure (CCP-TP-504, Revision 8) of all radionuclide values for purposes of model development and routine assays performed via DTC

• The ORIGEN2.2 results are used to develop radionucl ide-specific scaling factors and convert the measured external dose rates obtained v ia DTC to radionuclide activity levels

• Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs, and 90 Sr)

• The determination of the contribution of all radion uclides to the radiological hazard 10

10 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.40

• Shielding and other calculations supporting the sca ling factors performed using MCNP5 to derive the appropriate DTC relationships as a fu nction of waste density for the appropriate geometry following repackaging (55-gall on drum)

• Adjustment of scaling factors based on the benchmar k analysis of 400 fast reactor fuel pins at LANL, as documented in LANL-RH-04

The radionuclide-specific scaling factors for these HFEF RH TRU wastes that were developed, as shown in Table 8, below, are taken from INL-RH-6 4:

Table 8. Radionuclide-Specific Scaling Factors

Radionuclide DTC Scaling Factor

233 U 6.83E-05

234 U 8.75E-05

235 U 8.70E-06

238 U 1.13 E-06

238 Pu 1.03E-02

239 Pu 2.72E-02

240 Pu 1.08E-02

241 Pu 2.05E-01

242 Pu 4.33E-06

241 Am 1.08E-02

137 Cs -

137m Ba 9.46E-01

90 Sr 8.45E-01

There are no issues related to the technical adequa cy or documentation of radionuclide scaling factors for HFEF RH TRU Waste Stream ID-HFEF-S5400- RH, Lot 1A.

(3) The technical basis of the DTC correlation and its documentation were evaluated and both aspects were acceptable.

The DTC correlation was evaluated based on DTC BDR No. INLRHDTC09006, which INLCCP provided during the T1 evaluation. The correct version of the DTC Excel spreadsheet was used for the calculations, i.e., it contained the r adionuclide scaling factors that were developed for these HFEF wastes contained in INL-RH-64, and T able 8, above. EPA technical personnel verified that the DTC BDR cited above included the following:

• BDR Cover Sheet, Attachment 4

• BDR Table of Contents, Attachment 5

• BDR Narrative Summary, Attachment 6

• ITR Review Checklist, Attachment 7

• Measurement Control Report, Attachment 1

• Container Data Sheet(s), Attachment 241

• Waste Container DTC Conversion Record(s), Attachmen t 3

• Evidence of signatures by the ITR and a SPM

• Type of waste in each container (steel, concrete, o rganics)

• 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 these HFEF RH TRU wastes.

(4) Technical aspects and documentation of the rad iological characterization process were evaluated and found to be acceptable following succ essful resolution of an EPA concern.

CCP-AKINL-501 is the main document that describes t he radiological characterization process that INL-CCP used for the HFEF wastes. This docume nt is supported by a series of 18 calculation packages, listed in Table 8-1, that wer e reviewed in the process of evaluating the HFET wastes. These packages had been prepared and reviewed initially by Jene Vance, Jim Holderness, Dave Moody, and Jessie Klingensmith to support several CCP RH TRU evaluations. The EPA evaluation team reviewed these packages in conjunction with Revision 0 of CCP-AK-INL-581 in advance of the formal T1 evaluati on meeting at EPA headquarters. Several documents had been revised more recently and these revisions were evaluated during the meeting as they were provided by INL-CCP. During t hese discussions, the EPA evaluation team had the opportunity to discuss all technical concer ns and apparent discrepancies with INL-CCP personnel and to raise a variety of technical and d ocumentation-related questions regarding technical aspects related to the HFEF RH TRU wastes . Based on EPA’s review and technical discussion, numerous changes to the radiological ch aracterization report CCP-AK-INL-581, Revision 0 were required to enable the document to adequately support technical aspects of this waste stream. EPA discussed this with INL-CCP tech nical personnel during the T1 evaluation and captured this issue on an EPA Evaluation Issue Tracking Form, as discussed below (see Attachment C of this report for a copy of this form ).

EPA Concern No. INL-RH-RC-09-003CR : Based on this T1 evaluation, numerous changes to the radiological characterization report CCP-AK-INL -581, Revision 0 were required to enable the documents to adequately support technical aspec ts of this HFEF waste stream.

Resolution: These changes were captured in a freeze-file that w as provided to EPA on January 5, 2010 and the revised document adequately address ed EPA’s concern.

Concern Status : This issue is closed.

The EPA evaluation team found that the freeze-file version of CCP-AK-INL-581 adequately documented the radiological characterization proces s for the HFEF wastes, and the calculation packages cited above adequately supported the activ ities upon which the radiological characterization of the HFEF wastes were based. Th ere were no issues related to the documentation of technical aspects of the INL-CCP r adiological characterization approach for the HFEF RH wastes.42

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

The development of TMU for Waste Stream ID-HFEF-S54 00-RH is based on the propagation of uncertainties present in all aspects of the determi nation of the radiological constituents of RH TRU waste. These aspects are assumed to be indepen dent, which allows them to be added in quadrature. The TMU determination included contrib utions of the following:

• DTC correlation – including drum weight measurement , MCNP5 code, and modeling uncertainties

• Measurement uncertainty – including dose rate uncer tainty from 137 Cs and 60 Co

• Scaling factor uncertainty – including ORIGEN2.2 unc ertainty and aspects related to fuel pin composition and contribution

• Contributions of other gamma emitters

• Drum-to-drum variation

A general treatment of TMU for this HFEF waste stre am is presented in CCP-AK-INL-501 and Calculation Package LANL-RH-25, Revision 0, Uncertainty Analysis of Canisters w/ 364 Cans ; and INL-RH-66, HFEF Lots 1A and 1B Uncertainty Calculation at Idah o National Laboratory (INL) RH Radiological Characterization . The principal sources of uncertainty are the 137 Cs dose rate determination and the relative contribution of each fuel pin to the total. There were no concerns regarding the technical derivation and doc umentation of TMU for INL-CCP Waste Stream ID-HFEF-S5400-RH.

(6) RH and TRU determinations were assessed and wer e found to be adequate.

The determinations that these containers meet the d efinitions of TRU waste and RH waste were examined during the baseline inspection based on DT C BDR No. INLRHDTC09006. Both the RH and TRU determination are parts of the actual DT C measurements that are performed at the INTEC Facility at INL, which was not assessed direc tly during this T1 evaluation. EPA did verify that no aspects of the DTC process had chang ed significantly from what EPA had observed during the baseline inspection. The resul ts for the containers that were reviewed as part of this T1 evaluation as documented in the DTC BDR indicated the following:

• All containers were clearly TRU, i.e., contained mo re than 100 nano Curies per gram (nCi/g) of transuranic radionuclides.

• All containers were clearly RH, i.e., had an extern al contact dose rate greater than 200 mRem/hr.

There were no technical or documentation-related co ncerns regarding the TRU and RH determinations for the containers in Waste Stream I D-HFEF-S5400, Lot 1A.43

Summary of Radiological Characterization

Findings or Concerns

The EPA inspection team did not identify any findin gs related to radiological characterization. EPA identified one concern during this evaluation r elated to radiological characterization that is discussed above, and a copy of the EPA Inspection I ssue Tracking Form recording it is provided in Attachment C. This concern required a response, which was provided in the form of freezefile modification to a document that INL-CCP provid ed. Upon receipt of INL-CCP’s response, there are no open concerns related to radiological characterization resulting from this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations that were assigned to radiological characterization for INL-CCP during the baseline approval. However, the Tiering Table for INL-CCP RH has been modified to reflect the need for all waste streams to have similar reporting requirements.

6.0 FINDINGS AND CONCERNS

S ummary of Findings and Concerns

The EPA inspection team did not identify any findin gs related to AK or radiological characterization. EPA identified two concerns duri ng the inspection, one related to radiological characterization and one related to AK, both of whi ch required a response. Both concerns are discussed above, and a copy of both EPA Inspection Issue Tracking Forms recording these issues is provided in Attachments C and D, respectively. Both concerns were adequately addressed and there are no open concerns related to AK or radiolo gical characterization resulting from this T1 evaluation.

7.0 CONCLUSIONS

EPA concluded that the waste characterization proce sses of AK and radiological characterization proposed for use to characterize RH TRU wastes from INL-CCP are adequate. There are no open issues relative to this T1 evaluation.

Approval

The T1 change that was evaluated consisted of the w aste characterization techniques of AK and radiological characterization as applied to two sep arate areas:

• The addition of twelve drums of RH TRU waste to INL -CCP Waste Stream ID-ANLE-S4000

• Waste Stream ID-HFEF-S5400-RH, Lot 1A consisting of 28 casks44

Based on the results of this evaluation, EPA approv es these components of the T1 change. INL-CCP is approved to characterize these RH TRU wa stes, consistent with the limitations specified in this report. At this time, EPA is notapproving ID-INTEC-RH, and ID-HFEFS5400-RH, Lot 1B.

Tiering Changes

Based on the results of this T1 evaluation, there a re no substantive changes to the T1 designations assigned to AK or radiological charact erization during the baseline approval. There are two T2 changes to the AK designations and they are reflected in the revised INL-CCP RH Tiering Table as shown in Table 9, below. This tab le has been modified to reflect the need for all waste streams to have similar reporting require ments.45Table 9. Tiering of RH TRU WC Processes Implementedby INL-CCP (Revised January 28, 2010*)RH WC Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH WC Process - T2 ChangesAcceptable Knowledge (AK)Addition of containers to approved Waste StreamsAny new waste streams not approved under this baselineSubstantive modification(s) that have the potentialto affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL-501, orCCP-AK-INL-502Load management for any RH waste streamNotification to EPA whenAKSRs, RadiologicalCharacterization Reports and CertificationConfirmation Test Plans (e.g.,CCP-INL-AK-500, CCPINL-AK-501, and CCP-INL-AK-502) updatesareapproved by CBFONotification to EPA when changes to AK documentation asa result of WCPIP revisions have been made (e.g., CRR)Notification to EPA when a Correlation or SurrogateSummary Form is completed for each of the RH containersin this waste stream identified as CH, based upon measureddose rates that present NDA results for assayed containersNotification to EPA once waste stream data packagefordebris waste stream and any modifications to the WSPF,including the CRR and AK Summary, are completedNotification to EPA that the final Dose-to-Curie (DTC)determination is complete for RH containers numbers728through 737, as identified in AK Reference P030AK accuracy reports (prepared annually, at a minimum)Radiological Characterization, includingDose-to-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501Use of any alternate radiological characterizationprocedure otherthan DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedureAny new waste stream not approved under this baseline or additionof containers to Waste Stream ID-ANLE-S5000 that requireschanging the established radionuclide scaling factorsNotification to EPA upon completion of revisions ofCCPAK-INL-501 or CCP-TP-504 that require CBFO approvalVisual Examination of audio/video media(VE)Implementation of VE following this baseline approval; if INLCCP decides to use VE in the future, EPA approval is necessaryNoneReal-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 orwastes from an S3000 or S4000 waste streamNotification to EPA upon completion of changes to RTRprocedure(s) that require CBFO approval.Notification to EPA upon addition of a new RTR unit(s).WIPP Waste Information System (WWIS) NoneChanges made to WWIS procedure(s) that require CBFOapproval46Notes:-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 every three months.-Excluding changes that are editorial in nature or are required to address administrative concerns.-Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measurement instrumentor the use of the high-range probe as described inCCP-TP-504.* Changes to the original tiering table from the 2007 baseline inspection appear inbold.

### ATTACHMENT A

APPROVAL SUMMARY FOR INL RH WASTE CHARACTERIZATION PROGRAMA-1 

### ATTACHMENT A

APPROVAL SUMMARY FOR INL RH 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 Real Time Radiography F ebruary 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-A4-72 Tier 1 Change – Approval of Visual Examination Tech nique September 2009 A-98-49; II-A4-118

### ATTACHMENT B

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATIONB-1

Reference List for CCP-AK-INL-500 and CCP-AK-INL-50 1

• CCP-AK-INL-500, Central Characterization Project Ac ceptable Knowledge Summary Report for Remote-Handled Transuranic Debris Waste from Argonne National Laboratory-East Stored at the Idaho National Laborat ory, Waste Stream ID-ANLES5000, Revision 7, June 17, 2009

• CCP-AK-INL-501, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report For Remote-Handled Transuranic Debris Waste From Idaho National Laboratory, Revision 4, L arry Porter, October 20, 2009

• CCP-AK-INL-502, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Tes t Plan for INL RH Waste Stream: ID-ANLE-S5000, Revision 3, Larry Porter, October 7, 2009

• DOE WIPP 02-3214, Remote-Handled TRU Waste Characte rization Program Implementation Plan, Revision 0D, October 30, 2003

• Inter-Office Correspondence from C. M. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report: Idaho National Laborator y, Waste Stream Number IDANLE-S5000, Lots 1-27, February 2, 2009

• Memo from Kevin Peters, CCP AKE, to Irene Quintana, CCP SPM, RE: Addition of 12 Containers to Waste Stream ID-ANLE-S5000 CCP-AK-INL -500, R.7, June 24, 2009

• CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameter, Prohibited Items and Packaging, and related WMP memorandum, May 6, 2 009

• CCP-TP-005 Attachment 4, Acceptable Knowledge Sourc e Document Reference List, November 16, 2009

• CCP-TP-005 Attachment 1, Acceptable Knowledge Docum entation Checklist, IDANLE-S5000, November 16, 2009

• C138, Intra-Laboratory Memo to Distribution re: Hot -cell Survey, ANL-26 (11-68), L. A. Neimark, August 20, 1973

• C357, Letter to N.D. Dudey and C.E. Crouthamel (EXX ON); Management Summary and Milestone Report for October 1978, C.E. Johnson, Nov ember 30, 1978

• C359, Inter-Laboratory Memo to A.J. Goldman; Feasib ility of Operating K-2 Facility in D200, L.A. Neimark, April 3, 1978

• C379, Intra-Laboratory Memo; Addendum to Criticalit y Hazards Control Statement (Revision 7) Alpha-Gamma Hot Cell Facility (Special Facility FF-1), W.D. Jackson, July 8, 1975

• C380, Interview with William Kettman; Extension of AGHCF Operations in Building 200 K-1 and K-2 Cells and 10-gallon Waste Cans, K. Peters, July 21, 2007

• C381, Results of Document Review Relating to the AK Available for RH TRU Waste Containers Generated in the Building 200 K Cells at ANL-E, K. Peters, October 23, 2007B-2

• C1001, E-Mail Correspondence re: Work Performed in the Bldg. 200 M-Wing during the 1978-1982 Time Period, C.M. Rock to K. Peters and T . Clements, April 11, 2008

• C1002, E-Mail Correspondence re: Work Performed in the M Cells of the Bldg. 200 MWing, J. Beitz to C.M. Rock, March 18, 2008

• C1003, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for July 1978, C.E. Johnson, A ugust 14, 1978

• C1004, Letter to L.A. Neimark; Preparation of Test Specimens from Exxon Fuel Rods JJ40002 and JK-40001 for Use in EPRI Program RP 1027, F.L. Yaggee, November 22, 1977

• C1005, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for June 1978, C.E. Johnson, J uly 17, 1978

• C1006, Letter to N.D. Dudey (EXXON); Transmittal of Gamma Scanning Data for J-2 Rods, C.E. Johnson, June 16, 1978

• C1007, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for April 1978, C.E. Johnson, June 16, 1978

• C1008, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for January 1978, C.E. Johnson , February 13, 1978

• C1009, Possible Contract with Exxon and Attachments , B.R.T Frost, July 13, 1976

• C1010, Letter to C.E. Crouthamel (EXXON); Managemen t Summary and Milestone Report for February 1979, C.E. Johnson, March 13, 1 979

• C1011, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for December 1978, C.E. Johnso n, January 12, 1979

• C1012, Letter to C.E. Johnson; Progress Report for December 1978 on EXXON-EPRI Program RP 306, L.A. Neimark, January 10, 1979

• C1013, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for November 1978, C.E. Johnso n, December 18, 1978

• C1014, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for September 1978, C.E. Johns on, October 18, 1978

• C1015, Letter to C.E. Johnson; Progress Report on E XXON-EPRI Program RP 306, L.A. Neimark, October 6, 1978

• C1016, Letter to N. Dudey (EXXON); Gamma Scan Resul ts for J-2 Rods, L.A. Neimark, August 13, 1978

• C1017, Letter to C.E. Johnson; Monthly Report for J une on EXXON/EPRI Program RP 306, L.A. Neimark, July 13, 1978

• C1018, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for August 1978, C.E. Johnson, October 18, 1978

• C1019, Letter to C.E. Johnson; Monthly Report for M arch on EXXON/EPRI Program RP306, L.A. Neimark, April 11, 1978B-3

• C1020, Letter to N. Dudey (EXXON); Last Gamma Scan Results for J-2 Rods, L.A. Neimark, September 12, 1978

• C1021, Letter to L.A. Neimark; Estimated Costs for Exxon/EPRI Program, C.E. Johnson, April 6, 1977

• C1022, Drawings List for the CEN Shielded Fuel Exam ination Facility in Cell M-4 of MA-Wing in Building 200, Argonne National Laborator y, J. Beitz, March 9, 2007

• C1023, Intra-Laboratory Memo to D.S. Butler, Locati on of Fission-gas Punctures in EXXON J-2 Rods, L.A. Neimark, June 29, 1978

• C1024, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for April 1978, C.E. Johnson, May 17, 1978

• C1025, Letter to C.E. Johnson; Monthly Report for A pril on EXXON/EPRI Program RP306, L.A. Neimark, May 10, 1978

• C1026, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for March 1978, C.E. Johnson, April 17, 1978

• C1027, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for February 1978, C.E. Johnso n, March 16, 1978

• C1028, Letter to C.E. Johnson; Monthly Report for F ebruary on EXXON/EPRI Program RP306, L.A. Neimark, March 7, 1978

• C1029, Letter from C.E. Johnson; Guidelines for Mon thly EPRI/EXXON Report, C.E. Johnson, March 20, 1978

• C1030, Letter to N.D. Dudey and C.E. Crouthamel (EX XON); Management Summary and Milestone Report for January 1979, C.E. Johnson , February 14, 1979

• C1031, Summary of AK Research for 12 Drums Generate d in the Building 200 M Wing to be Included in Waste Stream ID-ANLE-S5000, K. Pe ters, Undated (provided December 7, 2009)

• P614, Identification of Additional Fuel Elements/Ma terials Examined in the AlphaGamma Hot Cell Facility for ANL-E RH TRU Waste, EDF -6946, Kerry Martin, May 19, 2006

• P615, Information on Fuel Elements Examined at the AGHCF at ANL from November 1971 to August 7, 1995, Based on Waste Consolidatio n Records, EDF-6685, P. Kuan, May 19, 2006

• P622, Addendum to Criticality Hazards Control State ment (Revision 7) Alpha-Gamma Hot Cell Facility (Special Facility FF-1), Bldg. 20 0 File H121A, W.D. Jackson, April 28, 1975

• P1001, From Test Tube to Pilot Plant; A 50 Year His tory of the Chemical Technology Division at Argonne National Laboratory, ANL-00/16, ISBN 0-967168-1-X, R.K. Steunenberg and L. Burris, August 2001

• P1002, Design, Operation, and Performance Data for High Burnup PWR Fuel from the H.B. Robinson Plant for Use in the NRC Experimental Program at Argonne National Laboratory, EPRI Report - 1001558, O. Ozer, EPRI Pr oject Manager, May 2002B-4

• P1003, Building 200/205 Pneumatic Transfer Tube D&D Project Final Report, ANL/D&D98-5, ANL, 1998

• P1004, Irradiation and Evaluation of Mixed Oxide Fu el Performance at the Big Rock Point Reactor, Post-Irradiation History: Fuel and F ission Product Behavior, Research Project 306, C.E. Johnson, R.R. Heinrich, L.A. Neim ark, J.E. Sanecki, November 1987

• P1005, Characterization of Low Burnup Rods (J-1) Fr om Big Rock Point Reactor, Final Report, Research Project 306, C.E. Johnson, R.R. He inrich, L.A. Neimark, J.E. Sanecki, June 1980

• P1006, Analytical Shearing of Fuel Rods in a Hot Ce ll, TANSAO 30 1-814, ISSN: 003- 018X, J.E. Parks, I.O. Winsch, C.E. Stevensson, N.M . Levitz, 1978

• P1007, LWBR Proof-of-Breeding Analytical Support Pr oject, TANSAO 34 1-899, ISSN: 003-018X, J.E. Parks, I.O. Winsch, C.E. Stevensson, N.M. Levitz, C. Wach, R. Nelson, et al., 1980

• P1009, Reference Information Concerning Some 1960s and 1970s Use of Building 200 MA-Wing Hot Cells and Surrounding Areas, J. V. Beit z, December 13, 2008

• P1010, Progress in Nuclear Energy, Analytical Chemi stry, A Large-Scale Facility for Chemical Research with Intensely Radioactive Materi als, D.C. Stewart, 1963

• P1011, Verification Survey of Building 200 Hot Cell s, ANL/ESH-HP-96/02, C.M. Sholeen, March, 1996

• P1012, Characterization of Irradiated Zircaloys: Su sceptibility to Stress Corrosion Cracking, EPRI NP-1557 - Project 1027, F.L. Yaggee, R.F. Mattas, L.A. Neimark, October 1980

• P1013, RP1027 - Characterization of Irradiated Zirc aloys, ANL, April 1978

• P1014, Characterization of Irradiated Zircaloys: Su sceptibility to Stress Corrosion Cracking, EPRI NP-1155 - Project 1027, F.L. Yaggee, R.F. Mattas, L.A. Neimark, September 1979

• P1015, Fuel Performance Improvement Program - Semia nnual Progress Report, October 1979 - March 1980

• U042, RH-TRU 1976 to 1982, Book 1, Undated

• U1001, Building 200 Special Survey Reports, Various authors, September 1, 1979 – December 26, 1979

• U1002, RH TRU RTR Prescreen for Repackaging/AK Work sheets and Videos, Various authors, Undated

• U1003, Argonne Special Material Receipt and Transfe r Documentation by A/G Number, Various authors, 1964-1997

• U1004, Miscellaneous Packaging and Shipping Documen tation for Containers 393, 394, 395, 396, 397, 398, 399, 400, 1002, 1003, 1004, 100 5, Various authors, Undated

• U1005, Health Physics Monthly Reports for Activitie s in Building 200, ANL Heath Physics Department, 1975-1980B-5

• U1006, SPM 24 Logbook for the 200 Area 9/23/74 thro ugh 3/1/96, ANL, September 23, 1974 - March 1, 1996

• U1007, Material Control Ledger, ANL, Undated

• U1008, Argonne National Laboratory Core Competency Areas, ANL, Undated

• U1009, Calculation Review Checklist: Cs.137 DTC Cor relation for 55-Gal Drum with Liners, INLRH-20, Revision 0, J. Vance, January 12 , 2009

• U010, INL RH TRU Radiological Characterization Sour ce Document Reference Information (author(s), document and revision numbe r, date, publisher): INLRH-90, Revision 0, J. Vance, A

Reference List for CCP-AK-INL-580 and CCP-AK-INL-58 1

• CCP-AK-INL-580, Central Characterization Project Ac ceptable Knowledge Summary Report for Remote-Handled Transuranic Debris Waste from Materials and Fuels Complex Hot Fuel Examination Facility at the Idaho National Laboratory, Waste Stream ID-HFEF-S5400-RH, Revision 1, September 8, 2009

• CCP-AK-INL-580, Central Characterization Project Ac ceptable Knowledge Summary Report for Remote-Handled Transuranic Debris Waste from Materials and Fuels Complex Hot Fuel Examination Facility at the Idaho National Laboratory, Waste Stream ID-HFEF-S5400-RH, Revision 2, Tier 1MARKUPSS - Free ze file Month XX, 2010

• CCP-AK-INL-581, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report For Remote-Handled Transuranic Debris from the Hot Fuel Examination Facility (HFEF) at th e Idaho National Laboratory, Revision 0, October 8, 2009

• CCP-AK-INL-582, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Tes t Plan for INL RH Waste Stream: ID-HFEF-S5400-RH, Revision 0, August 13, 2009

• CCP-TP-005, Site(s): Idaho National Laboratory, Was te Stream Number: ID-HFEFS5400-RH Waste Stream Description: HFEF Remote-Hand led TRU Debris, Revision 18, November 16, 2009

• CCP-TP-005, Attachment 1, Acceptable Knowledge Docu mentation Checklist, Waste Stream Description: HFEF Remote-Handled TRU Debris, Waste Stream Number(s): IDHFEF-S5400-RH, Revision 18, November 12, 2009

• CCP-TP-005, Attachment 4, Acceptable Knowledge Sour ce Document Reference List, November 12, 2009

• CCP-TP-005, Attachment 6, Waste Form, Waste Materia l Parameters, Prohibited Items and Packaging, Remote Handled TRU Debris CCP AK INL 580, and related Waste Material Parameter Memo, Revision 18, November 12, 2 009

• CCP-TP-005, Attachment 8, Waste Containers List and Add Containers Memo and Spreadsheet, Revision 18, provided December 9, 2009B-6

• CCP Waste Stream Characterization Checklist, Waste Stream ID-HFEF-S5400-RH, provided December 9, 2009

• Characterization Reconciliation Report (excel sprea dsheet version) provided December 9, 2009

• HFEF Canister and Shipment Data Spreadsheet, provid ed December 9, 2009

• HFEF Individual Container Information Spreadsheet, provided December 9, 2009

• Interoffice Correspondence from C.M. Gomez to M. Se nsibaugh re: Acceptable Knowledge Accuracy Report Materials and Fuels Compl ex Hot Fuel Examination Facility at the Idaho National Laboratory Waste Str eam Number ID-HFEF-S5400-RH, Lot 1, October 12, 2009

• NCR-RHINL-0510-09, Packaging Configuration Issues, No vember 10, 2009

• Program Implementation Plan Draft Waste Stream Prof ile form for ID-HFEF-S5400-RH, Undated; Provided December 9, 2009

• Training Qualification Cards and Email Reading List s, Mark Doherty and Scott Smith, Provided December 9, 2009

• C001, Interview of Jim Stuart, Materials Engineer, Casting Lab Group Leader, re: Process and Operations Conducted in the Casting Lab oratory, Scott Smith, August 10, 2005

• C002, Interview of Pam Crane, Analytical Laboratory , re: Analytical Laboratory Mission and Objectives, Scott Smith, August 31, 2005

• C003, Interview of Roger Haga, MFC Safeguards, re: Traceability of Defense Materials to Casting Laboratory and Analytical Laboratory, Sc ott Smith, August 31, 2005

• C004, Interview of Steve Hayes, Materials and Fuel Complex Project Manager, Advanced Fuel Cycle Initiative, re: Advanced Fuel C ycle Initiative Program Related to Casting Laboratory Operations, Scott Smith, August 22, 2005

• C005, Interview of Jennifer Tournage, former Waste Specialist, Nancy Stewart, Waste Specialist, and Roy Grant, Waste Specialist, re: MF C Analytical and Casting Laboratories Waste Management and Waste Characteriz ation, Scott Smith, September 1, 2005

• C014, Intra-Laboratory Memorandum to W.P. Keeney, “ Procurement of Uranium Feedstock for FMF Production,” L.C. Walters and D.B . Tracy, ANL, September 14, 1989

• C021, United States Government Memorandum to Distri bution, re: Receipt of ContactHandled (CH) and Remote-Handled (RH) Transuranic (T RU) Waste at the INEL, J.P. Hamric, May 19, 1987

• C028, Argonne National Laboratory Intra-Laboratory Memo to W.N. Beck, re: Technical Feasibility of Lead IFR Experiments in EBR-II, R.G. Pahl, April 27, 1984

• C030, Argonne National Laboratory Intra-Laboratory Memo to D.W. Cissel, re: EBR-II Division Approval to Irradiate Three IFR Subassembl ies, W.N. Beck, May 17, 1984B-7

• C033, Argonne National Laboratory Intra- Laboratory Memo to R.G. Pahl, re: Assignment of Identification Numbers for Three Lead IFR Experimental Subassemblies, J.L. Welker, June 4, 1984

• C034, Argonne National Laboratory Intra-Laboratory memo to Distribution, re: Design Review of Lead IFR Fuel Elements, R.G. Pahl, June 1 4, 1984

• C037, Argonne National Laboratory Intra-Laboratory Memo to J.L. Welker, re: Xenon Tag Gas for X419, X420, and X421, R.G. Pahl, Septem ber 17, 1984

• C047, Argonne National Laboratory Intra-Laboratory Memo to W.N. Beck, re: NDT Review of Sixty-one (61) IFR Fuel Elements from ANL Scheduled for Experimental S/A X421, G.K. Whitham, February 13, 1985

• C050, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Inspection of Subassembly X419, E.K. Hemsley, July 22, 1985

• C061, Argonne National Laboratory Intra-Laboratory Memo to J.L. Welker, re: Goal Burnup for X419, X420, and X421, R.G. Pahl, June 16 , 1986

• C067, Argonne National Laboratory Intra-Laboratory Memo to L.C. Walters, re: Fuel Elements from X421 Needed by TREAT Program, A.E. Wr ight, February 18, 1987

• C069, Argonne National Laboratory Intra-Laboratory Memo to R.G. Pahl, re: Post Examination of IFR Elements form S/A X419 with incl uded document, W.N. Beck, G.L. Hofman, April 8, 1986

• C072, Packet of letters including: Argonne National Laboratory Intra-Laboratory Memo to D.C. Wade, re: Response to MC&A Questions in Sup port of HFEF-S Fuel Reprocessing Operations, R. Villarreal, January 24, 1989

• C073, Argonne National Laboratory Intra-Laboratory Memo to J.E. Cahalan/D.J. Hill, re: Analysis of Fission Gas Release from IFR Subassembl y X421, J.P. Herzog, K.J. Miles, March 6, 1989

• C074, Two letters concerning Metallography of X420B Element T084, Bob Pahl, August 2 and August 18, 1989

• C078, Argonne Nation Laboratory Intra-Laboratory Me mo to E.K. Hemsley and W.N. Beck, re: HFEF Data Transmittal for S/A X421, E .M. Franklin, April 6, 1987

• C079, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Inspection of Subassembly X421, Addendum 2, E.K. He msley, May 18, 1987

• C081, Letter to Bob Pahl, re: Density of Cladding o n X421 Fuel, R. Villarreal, December 11, 1987

• C082, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Destructive Examination of Element T-108 from S/A X 421, B.G. Carlson, July 8, 1987

• C083, Letter to Bob Pahl, re: Sodium Logging Analys is on X421, T108, R. Villarreal, October 1, 1987B-8

• C084, Letter to Bob Pahl, re: Burnup Measurements o n X421/T108, T128, T225, R. Villarreal, November 24, 1987

• C085, Letter to Bob Pahl, re: Retained Fission Gas Analysis on X421@ 9.3 a/o BU, R. Villarreal, December 10, 1987

• C087, Letter to Bob Pahl, re: Sodium Logging Analys is on X421, T108, R. Villarreal, Undated

• C089, Letter to Idaho Division Chemical Group Perso nnel, re: Transfer of Waste from the Junior Cave Facility by the Pneumatic Transfer System, W.R. Sovereign, March 20, 1969

• C092, Argonne National Laboratory Intra-Laboratory Memo to M.E. Vaughn, re: TRU Sample Waste, W.R. Sovereign, June 30, 1987

• C096, Letter to Distribution re: Changes to Interna l Technical Report PR-W-78-014, Revision 2, KPL-86-82, K.P. Lange, October 14, 1982

• C099, Letter to R. Villarreal, re: X-421, T-225 Imm ersion Density Experience, W.K. Schmier, November 30, 1987

• C105, Argonne National Laboratory Intra-Laboratory Memo to G.R. Hocker and E.M. Franklin, re: Removal of Subassembly X423B, J. L. Welker, April 24, 1986

• C106, Letter to E.K. Hemsley, re: Plenum Gas Analys is – X423B Elements, M.T. Laug, November 5, 1986

• C107, Argonne National Laboratory Intra-Laboratory Memo to G.R. Hocker and C.E. Lahm, re: Removal Subassembly X423C, J.L. Welk er, August 11, 1987

• C108, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Destructive Examinations Requested for X423C, C.E. Lahm, December 11, 1987

• C109, Argonne National Laboratory Intra-Laboratory Memo to R. Villarreal, re: Radial Chemistry Analyses Requested for X423C, C.E. Lahm, December 14, 1987

• C110, Argonne National Laboratory Intra-Laboratory Memo to Backup Radial Chemistry Samples Requested for X423C, C.E. Lahm, May 2, 1988

• C115, Letter to Bob Pahl, re: Radial Drilling Resul ts for X421, R. Villarreal, December 18, 1987

• C119, Department of Energy, Idaho Operations Office Order, re: Hazardous and Radioactive Mixed Waste Management, ID 5480.2, Oper ational Safety Division, January 3, 1984

• C126, Letter to M.J. Holzemer, re: Use and Disposal of Halogenated Organic Solvents by the ANL-W Analytical Laboratory, R. Villarreal, Nove mber 5, 1987

• C127, Argonne National Laboratory Intra-Laboratory Memo to W.N. Beck, re: NDT Review of Sixty-one (61) IFR Fuel Elements from ANL Scheduled for Experimental S/A X419, G.K. Whitham, February 11, 1985B-9

• C129, Argonne National Laboratory Intra-Laboratory Memo to Distribution, re: TRU Waste Profile Sheets, ANL-W-SSS-(LCW)-88-118, L.C. Witbeck, January 6, 1988

• C131, Argonne National Laboratory Intra-Laboratory Memo to J. R. Krsul, re: SEM/EDAX Examination of Cadmium Soaked Steels, E.L. Wood, April 4, 1988

• C134, Argonne National Laboratory Intra-Laboratory Memo to R. Villarreal, re: Proposed Waste Handling and Disposal Facility, John R. Krsul, Robert Coleman, Ralph Martell, Pamela Crane, William Vroman, John Young, February 1, 1989

• C135, Argonne National Laboratory Intra-Laboratory Memo to G.C. McClellen, re: Transfer of Analytical Lab Hot Cell Wastes to HFEF, AW-AL-(RV)-89-010, R. Villarreal, July 17, 1989

• C142, Argonne National Laboratory Intra-Laboratory Memo to T. P. Zahn, re: Waste Characterization Report, KPG92-20, K.P.Guay, Septem ber 16, 1992

• C145, Argonne National Laboratory Intra-Laboratory Memo to E. M. Franklin, re: Destructive Examinations Requested for X423B, C.E. Lahm, January 15, 1987

• C147, Letter to Bob Pahl, re: Sodium Logging Analys is on X421, T128 (U-8Pu-Zr), R. Villarreal, October, 1987

• C148, Letter to Bob Pahl, re: Axial Fuel Expansion Measurements, X421, T128, U-8Pu/Zr, R. Villarreal, December 1, 1987

• C150, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Final Loading Diagram for Subassembly X421A, J.L. Welker, March 9, 1987

• C153, Argonne National Laboratory Intra-Laboratory Memo to Distribution, re: Interim Proposed Guidelines for ESRG Regarding High Burnup Subassemblies, G.H. Golden and W.K. Lehto, February 23, 1989

• C154, Letter to R.S. Wisner, re: Destructive Examin ations of X421A Elements, R.G. Pahl, March 27, 1989

• C160, Argonne National Laboratory Intra-Laboratory Memo to G. Hofman, re: Fission Product Iodine Retention in IFR Fuel Experiment, FP -AL-(RV)-90-066, R. Villarreal, November 16, 1990

• C162, Letter to Art Wright, re: Addendum to Isotopi c Analyses of Irradiated IFR Fuels, R. Villarreal, December 23, 1987

• C173, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Inspection of Subassembly X423B, E.K. Hemsley, July 7, 1986

• C176, Argonne National Laboratory Intra-Laboratory Memo to J.L. Welker, re: Changed Loading Diagram for X423C, C.E. Lahm, July 2, 1986

• C178, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Final Loading Diagram for Subassembly X423C, J.L. Welker, August 12, 1986

• C179, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Inspection of Subassembly X423C, T.A. Carlson, Sept ember 19, 1987B-10

• C180, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Characterization of X421 Element T225 by Scanning E lectron Microscopy, R.G. Pahl, December 15, 1987

• C185, Letter to T.A. Carlson, re: Plenum Gas Analys es – X423C Elements, M.T. Laug, December 11, 1987

• C191, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Subassembly X421, Element T108 Samples, R.G. Pahl, February 16, 1988

• C206, Letter to A.E. Wright, re: Isotopic Analyses of Irradiated IFR Fuels, R. Villarreal, M.T. Laug, December 14, 1987

• C212, EDF for the Review of ILTSF Mixed Waste, SMB- 02-91, S.M. Burns, January 17, 1991

• C214, MFC Interview, Scott Smith and Carrie Johnson , April 14, 2008

• C372, Argonne National Laboratory Intra-Laboratory Memo, re: HFEF Data Transmittal for X252, P.R. Betten, B.R. Seidel, W.N. Beck, J. P . Webb, September 9, 1982

• C463, Evaluation of Volume, Period Generation, and Calculation of Individual and Total Radionuclide Masses and Activities for Waste Strea m ID-HFEF-S5400-RH, Jim Schoen, April 20, 2009

• C464, HFEF Repackaging Operations Email, Tom Clemen ts, March 3, 2009

• C465, Evaluation and Summary of the Process Work Sh eets (PWS), Various dates

• C466, E-mail from Bud Lowman to Scott Smith, re: HF EF Waste Item Packaging and Layers of Confinement, Bud Lowman, March 12, 2009

• C501, Email to Scott Smith, re: HFEF Retrieval and Transfer to INTEC (transfer of HFEF-5 cans from ILTSF to INTEC), Various dates

• C502, Email to Scott Smith, re: TEDs, SADs, SAMs, K odak LR 115 Film in Hot Cell, Bud Lowman, April 2, 2009

• C522, Evaluation of Volume, Period Generation, and Calculation of Individual and Total Radionuclide Masses and Activities for Waste Strea m ID-HFEF-S5400-RH – Phase II , Jim Schoen, Undated

• C633, Email to Mike Papp, re: 90-Mil Liner Use, Tom Clements, July 14, 2009

• C698, Email to Tom Clements, re: Operation of CPP-6 66, Gerald Streier, July 28, 2009

• DR003, Waste Stream ID-HFEF-S5400-RH, Historical an d Current RCRA Characterization and Assignment of EPA Hazardous Wa ste Numbers, Undated

• P001, The Defense Programs Origin of Transuranic Wa ste at Argonne National Laboratory - West, ANL-NT-192, H. F. McFarlane, Nove mber, 2001

• P004, Casting Laboratory Operating Procedure, Fabri cation and Characterization of Pu, Np, and Am-Bearing Metallic Alloy Specimens, W0650- 0070-OP, Revision 0, Argonne National Laboratory-West, August 2, 2005B-11

• P006, Packet of Material Safety Data Sheets, Variou s dates

• P008, Nuclear Technology Division, Analytical Labor atory Procedure: Casting Laboratory AAA Cladding Tube Loading/Welding, W0650 -0059-OP, Revision 3, R. Fielding and D. D. Standfield, April 23, 2003

• P009, Fuel Cycle Programs, Nuclear Materials Charac terization Operating Procedure: Glovebox Glove, Bagout Sleeve and Gloveport Blank R eplacement, W0650-0030-OP, Revision 2, J. Stuart and D. Peay, May 5, 2005

• P011, Nuclear Technology Division, Casting Laborato ry Experimental Plan and Hazard Analysis: Accelerator Transmutation of Waste Projec t Diffusion Couple FCCI Studies on ATW, W0660-0076-AP, Revision 0, J.R. Kennedy and D. D. Standfield, July 18, 2002

• P012, Nuclear Technology Division, Casting Laborato ry Experimental Plan and Hazard Analysis: Accelerator Transmutation of Waste Projec t Arc-Melting Activities, W0650-0049-EP, Revision 0, R.J. Kennedy and D.D. St andfield, June 8, 2001

• P013, Nuclear Technology Division, Analytical Labor atory Procedure: Operating Procedure for Decontaminating Glovebox, W0650-0043- OP, Revision 2, P. Hansen and D.D. Standfield, June 24, 2003

• P015, Fuel Cycle Programs, Nuclear Materials Charac terization Department Casting Laboratory Operating Procedure: Fabrication and Cha racterization of Futurix Pu, Np and Am-Bearing Metallic Alloy Fuel Slugs, W0650-0054-OP , Revision 1, D. Porter and D. D. Peay, August 9, 2005

• P017, Nuclear Technology Division, Analytical Labor atory Procedure: Determination of Gallium in Plutonium Oxide by Inductively-Coupled-P lasma Mass Spectrometer, W0650-0064-KP, Revision 0, J. Giglio and D.D. Stand field, March 26, 2003

• P018, Nuclear Technology Division, Analytical Labor atory Procedure: Quality Assurance Plan, W0660-0012-QP, Revision 10, D.D. St andfield, August 19, 2003

• P019, Nuclear Technology Division, Analytical Labor atory Administrative Procedure: Dissolution of Plutonium Metal Samples for Silicon Analysis, W0650-0062-KP, Revision 0, J. Berg and D.D. Standfield, November 5, 2002

• P020, Nuclear Technology Division, Analytical Labor atory Procedure: Dissolution of Plutonium Oxide Samples for Trace Metal Analysis, W 0650-0063-KP, Revision 1, J. Berg and D.D. Peay, March 31, 2004

• P021, Nuclear Technology Division, Analytical Labor atory Procedure: Determination of Boron in Plutonium Oxide by Inductively-Coupled-Pla sma Atomic Emission Spectrometry, W0650-0065-KP, Revision 0, D. Cumming s and D.D. Standfield, March 26, 2003

• P023, Analytical Laboratory Procedure: Dissolution of Pu Metal, W0630-0026-KP, Revision 1, Argonne National Laboratory-West, May 1 7, 2001

• P024, Analytical Laboratory Procedure: Sample Prepa ration for Analysis of Boron and Gallium in Plutonium Oxide, W0630-0128-KP, Argonne National Laboratory-West, March 26, 2003B-12

• P025, Analytical Laboratory Operating Procedure: Gl ovebox Bagout Bag Replacement and Waste/Material Bagout, W0650-0008-OP, Revision 14, Idaho National Laboratory, July 19, 2005

• P026, Analytical Laboratory Operating Procedure: Sp ecial Projects Glovebox Operations, W0650-0025-OP, Revision 3, Idaho National Laboratory , July 11, 2005

• P027, Analytical Laboratory Operating Procedure: Wa ste Form Testing Glovebox, W0650-0016-OP, Revision 3, Idaho National Laboratory , August 12, 2005

• P028, Analytical Laboratory Operating Procedure: Ru snok Milling Machine for Waste Form Testing Glovebox, W0650-0019-OP, Revision 2, A rgonne National LaboratoryWest, September 1, 2005

• P029, Nuclear Technology Division, Analytical Labor atory Operating Procedure: Standard Test Method for Determining Chemical Durab ility of Nuclear Waste Glasses and Ceramics - Product Consistency Test, W0630-0059 -OP, Revision 1, S. Johnson and D.D. Standfield, December 16, 2003

• P030, Engineering Division, Analytical Laboratory P rocedure: Uranium and Plutonium Separation from Electrorefiner Salt for Mass Spectr ometer Analysis, W0630-0057-KP, Revision 2, J. F. Berg and D.D. Standfield, June 18 , 1996

• P031, Nuclear Technology Division, Analytical Labor atory Procedure: Dissolution of SRM-B Eutectic Salt Reference Material, W0630-0102- KP, Revision 1, J. Berg and D.D. Standfield, May 5, 2001

• P035, Idaho National Engineering and Environmental Laboratory Waste Acceptance Criteria, DOE/ID-10381, Revision 19, U.S. DOE Idaho Operations Office, April 2004

• P036, Pollution Prevention/Waste Minimization Plan, Revision 10, A.M. Collins, January 2004

• P037, Nuclear Fuel Cycle Division, Idaho Operations Office: INEL Transuranic Waste Acceptance Criteria, DOE/ID-10074, Revision 5, R.M. Brown and J.D. Wells, July 1993

• P039, Integrated Waste Tracking System Material and Waste Characterization Profile, 3657P: Analytical Laboratory (including Casting Lab oratory) Mixed Transuranic Waste, 3657P, R. Watson, December 3, 2002

• P042, Analytical Laboratory Safety Analysis Report, W0660-0055-KH, Revision 4, Idaho National Laboratory, April 6, 2006

• P043, Integrated Waste Tracking System Material and Waste Characterization Profile, ANL142T: Analytical Laboratory (including Casting L aboratory) Mixed Transuranic Waste, ANL142T, MFC, August 17, 2001

• P047, Argonne National Laboratory Description and P roposed Operation of the Fuel Cycle Facility for the Second Experimental Breeder Reactor (EBR-II), ANL-6605, J.C. Hesson, M.J. Feldman, L. Burris, April 1963B-13

• P049, Estimated Radiological Inventory Sent from Ar gonne National Laboratory-West to the Subsurface Disposal Area from 1952 through 1993 , INEEL/EXT-02-01385, Revision 0, Michael L. Carboneau, James A. Vail, Ap ril 2004

• P051, A Survey of NRTS Waste Management Practices, Volume II, ICP-1042-II, Allied Chemical Corporation, Idaho Chemical Programs, Oper ations Office, National Reactor Testing Station, September 1971

• P054, Informal Report, A Brief Analysis and Descrip tion of Transuranic Wastes in the Subsurface Disposal Area of the Radioactive Waste M anagement Complex at INEL, EGG-WTD-9438, Revision 1, D.A. Arrenholz, J.L. Knig ht, August 1991

• P055, Argonne-West Criticality Hazards Control Stat ement, ID-CHCS-A11, Revision 7, W.P. Keeney, May 7, 1984

• P060, ANL-West Remote-Handled Transuranic Waste Cer tification Plan, W0001-0898- ES-00, Revision 0, R.J. Teunis, July 5, 1988

• P063, ANL-West Remote-Handled Transuranic Waste Cer tification Plan, W0001-0898- ES-01, Revision 1, Michael E. Vaughn, August 2, 199 1

• P066, Analytical Laboratory Glassware Cleaning Proc edure, W0660-0029-OP, Revision 0, C.D. Morgan, March 5, 1991

• P067, Safeguards and Security Plan for IFR - EFL, R . Villarreal, May, 1984

• P070, Waste Preparation Procedure for Analytical La boratory Waste Disposal, W0660-0035-OP, Revision 0, J.R. Krsul, August 19, 1 991

• P071, Plant Description, Administration and General Policy, GET/PD, August 1995

• P073, Performance of Metallic Fuels and Blankets in Liquid-Metal Fast Breeder Reactors, Leon C. Walters and B.R. Seidel, November 2, 1983

• P075, Waste Preparation Procedure for Analytical La boratory Waste Disposal, AW-AL-WM-002, William R. Sovereign, June 1988

• P076, Argonne West Analytical Laboratory Waste Redu ction Plan for Low Level Waste, W.R. Sovereign, November 8, 1988

• P077, ANL-W RCRA Part B Permit Application, General Information, W0001-0920-ES-04, September 1994

• P081, Quality Assurance Plan for ANL-W Analytical L aboratory Materials Control and Accountability Section, Robert Villarreal, April 25 , 1989

• P083, Engineering Design File, Radiological Propert ies of Remote-Handled Transuranic Waste Inventory at the Radioactive Waste Management Complex, EDF-4687, Revision 1, Cecilia R. Hoffman, May 20, 2005

• P084, Characterization and Shipping Records for Rem ote Handled (RH) Transuranic (TRU) Waste Stored at the Radioactive Waste Managem ent Complex (RWMC), 3460-94-084, H.D. Killian and S.K. McDermott, Septe mber 1994B-14

• P085, Test Description for the Integral Fast Reacto r Subassemblies X419, X420, and X421, ANL-IFR-19, R.G. Pahl, C.E. Lahm, G.E. Hudman , July 1985

• P086, ANL-W Division, Nuclear Materials Control Pro cedures, Appendix C, Analytical Chemistry Laboratory, Revised 08/87, William R. Sov ereign, August 26, 1987

• P088, TRU-RH Waste Handling Plan for Waste Manageme nt Operations, AW-AL-WM-001, William R. Sovereign, March 30, 1988

• P089, AK Summary Documentation AK TRU Packaging, RP T-456, DRAFT, Revision 0, Idaho Cleanup Project, October and November 2007

• P091, INEL Transuranic Waste Acceptance Criteria, I DO-10074, Revision 1-4, Fuel Processing and Waste Operations Division, April 198 0; February 1984; March 1986; July 1987

• P092, Engineering Design File, ANL-W Radioactive In serts Stored at ILTSF, EDF-4208, Revision 0, P. Kuan, November 18, 2003

• P093, Design Description and Safety Analysis for X- 447, J.F. Koenig, C.E. Lahm, R.G. Pahl, D.L. Porter, November 1, 1987

• P094, Determination of Temperature and Phase Distri butions in Irradiated U-Pu-Zr Fuel, Charles E. Lahm, May 6, 1988

• P100, Engineering Design File, CPP-1617 Fire Area E valuation, EDF-4684, Nancy Makey, April 26, 2004

• P101, Technical Procedure, CPP-1617 Waste Handling and Operations, TPR-7318, Radioactive Waste Management Complex at INTEC, Febr uary 1, 2007

• P102, Estimated Radiological Inventory Sent from th e Idaho Nuclear Technology and Engineering Center to the Subsurface Disposal Area from 1952 through 1993, ICP/EXT03-00967 (R0), INEEL-EXT-05-00967 (R1), James A. Va il, Michael L. Carboneau, Glen R. Longhurst, March 2004 and December 2005

• P105, Engineering Design File, Baseline Estimate of the Volume of Remote Handled Transuranic Waste Stored at the Radioactive Waste M anagement Complex, EDF-4379, Revision 0, Cecilia R. Hoffman, March 29, 2004

• P106, Collection of ANL-E Documents including: Work Plan for the Evaluation of Fuel Plates from the RERTR-4 Experiment in ATR; Work Pla n for Cutting H.B. Robinson Rod Sections and Loading into Shipping Tubes; Vario us AGHCF Supplemental Instructions; Revised Work Plan for the Examination of Fuel Plates from the RERTR-5 Experiment in ATR, IPS-375-00-00, IPS-376-00-00, IP S-375-01-00 (SIs 153, 182, 236, 259, 279, 292, 315, 317, 320), IPS-335-00-00 (SIs 1 76, 221), R.V. Strain, Hanchung Tsai, Y. Yan, Darold Perry, Mitch Meyer, Various da tes

• P107, Mission Need Statement: RH TRU to WIPP Projec t, DOE/ID11114, Revision 0, INEEL, August 2004

• P109, EPA Hazardous Waste Codes for Transuranic Sto rage Area (TSA) Item Description Codes (IDC), EDF-RWMC-421, Revisions 0- 4, R.D. Falconer, April 1, 1994B-15

• P110, Characterization of Wastes Generated at Argon ne National Laboratory – West with IDCs of 161, 162, and 163, INEEL/INT-99-00081, Revis ion 0, C.B. Ransom, April 7, 1999

• P111, Matrix Parameter Category Groups (MPCGs), RWM C-805/INEL-95-029, Revisions 0-4, R.O. Falconer, February 26, 2002

• P112, Chemical Constituents in Transuranic Waste St orage Area (TSA) Waste, RWMC-803/INEL-95/022, Revisions 0-7, R.O. Falconer, M.S. DeHaan, D.E. Kuder, K. Knudtsen, K.J. Galloway, S.M. Hailey, June 12, 1 995, July 10, 1996, August 12, 1997, April 8, 1998

• P113, Content Code Assessments for INEL Contact-Han dled Stored Transuranic Wastes, WM-F1-82-021, Thomas L. Clements, Jr., October 1982

• P115, Decontamination Cell Operations in CPP-659, T PR-7298, Revision 7 and Revision 11, Idaho Cleanup Project, June 4, 2008 an d June 3, 2009

• P116, Dissolution and Clarification of RERTR Silici de Fuels, DP-MS-82-98, George C. Rodrigues, Savannah River Laboratory, November 8, 19 82

• P141, INEL Waste Management Plan For FY-1978, Idaho National Engineering Laboratory, IDO-10051, Nuclear Fuel Cycle Division, Idaho Operations Office, August 1977

• P145, EBR-II Reactor Review, NE Reactor Review Team, May 23, 1980

• P146, Hot Fuel Examination Facility South Final Saf ety Analysis Report, Argonne National Laboratory-West, January 1982

• P157, System Design Description (SDD), HFEF/N Neutro n Radiography Facility (NRAD), W0170-0004-SA-03, W. E. Stephens, June 1, 19 78

• P158, Waste Management Program, Program Plan for FY -1978, WMP 77-25, Smith, December 1, 1978

• P176, The Element Laser Profilometer System in Hot Fuel Examination Facility/North, R. W. Keyes, Undated

• P178, Overview of Idaho National Laboratory’s Hot F uels Examination Facility - 2007 European Working Group Hot Laboratories and Remote Handling, INL/CON-07-13203, Adam B. Robinson, R. Paul Lind, and Daniel M. Wachs , September 1, 2007

• P180, Integrated Waste Tracking System Material and Waste Characterization Profile 3799P: RH-TRU (Misc. Metal/Plastic/Cellulosic Debri s, SAD & SAMs - sample residue), Profile 3799P, N. Stewart, April 11, 2003

• P181, Postirradiation Handling Examination at HFEF Complex, J. Paul Bacca, May 1980

• P182, Packing Configurations for Repacked TRA and A NL-E RH-TRU Waste, EDF-8860, Greg Hulet, August 18, 2008B-16

• P221, Operation and Maintenance Manual: Metallograp hic Preparations, Containment Box, W0098-0049-SA-02, HFEF OMM 3114, Revision 2, B art G. Carlson, May 26, 1988

• P222, Operation and Maintenance Manual: Cask Tunnel Transfer Penetrations; Facility Operations Division: Cask Tunnel Transfer Penetrati ons, W0147-0138-SA-03, HFEF OMM 3410, Revision 3; HFEF-MI-3410, Revision 0, Mic hael E. Vaughn, October 6, 1982, and November 14, 1994

• P223, Operation and Maintenance Manual: Subassembly Profilometer II - HFEF, W0086-07 50-ES-02, HFEF OMM 4132, Revision 2, P.L. Coomer, April 5, 1991

• P224, Operation and Maintenance Manual: Subassembly Profilometer - HFEF/N, W0086-0205-SA-01, HFEF OMM 4134, Revision 1, P.L. C oomer, July 31, 1980

• P225, Operation and Maintenance Manual: Vertical As sembler-Dismantler (VAD), W0064-0039-SA-04, HFEF/S OMM 4151, Revision 4, P.L. Coomer, January 29, 1985

• P226, Operation and Maintenance Manual: Vertical As sembler-Dismantler (VAD), W0055-0136-SA-03, HFEF/N OMM 4152, Revision 4, P.L. Coomer, August 1, 1988

• P227, Operation and Maintenance Manual: Spent Fuel Dismantling and Canning - North & South, W0058-0001-SA-03, HFEF/N&S OMM 4156, Revis ion 3, P.L. Coomer, January 13, 1988

• P228, Operation and Maintenance Manual: Special ASC Can Spent Fuel Transfer - North, W0041-0001-ES-00, HFEF/N OMM 4157, Revision 0 , P.L. Coomer, August 11, 1978

• P229, Operation and Maintenance Manual: Grid-Type S ubassembly Dismantling and Reassembly - North, W0015-0349-ES-00, HFEF/N OMM 41 71, Revision 0, P.L. Coomer, November 11, 1982

• P230, Operation and Maintenance Manual: Capsule/Ele ment Transfer Station, W0024-0171-SA-02, HFEF/N OMM 4210, Revision 2, Fred L. DiLorenzo, August 13, 1986

• P231, Operation and Maintenance Manual: TREAT Neutr on Radiography Equipment for Capsules and Elements - South, W0060-0337-SA-00, HF EF/S OMM 4311, Revision 0, M.E. Vaughn, December 13, 1977

• P232, Operation and Maintenance Manual: TREAT Neutr on Radiography Equipment for Elements - HFEF/N, W0169-0134-SA-00, HFEF/N OMM 431 3, Revision 0, M.E. Vaughn, November 10, 1976

• P233, Operation and Maintenance Manual: Contact Pro filometer MK-II (Unit 2) - South, W0057-0071-SA-00, HFEF OMM 4322, Revision 0, T.C. C ameron, April 14, 1977

• P234, Operation and Maintenance Manual: Bow and Len gth Measurement HFEF/N, W0171-0159-ES-00, HFEF/N OMM 4325, Revision 0, Thom as C. Cameron, April 11, 1984B-17

• P235, Operation and Maintenance Manual: Element Con tact Profilometer, W0202- 0007-SA-01, HFEF/N OMM 4326, Revision 1, Thomas C. Cameron, August 8, 1984

• P236, Operation and Maintenance Manual: DR-25B With Remote Stage - North, W0171-0046-SA-00, HFEF/N OMM 4327, Revision 0 (DRAF T), T.C. Cameron, August 1, 1977

• P237, Operation and Maintenance Manual: Element Bow and Length Machine W0171-0026-SA-00, HFEF OMM, 4328, Revision 0, T.C. Cameron, June 23, 1976

• P238, Operation and Maintenance Manual: Visual Exam ination Machine - HFEF/South, W0172-0009-SA-00, HFEF/S OMM 4331, Revision 0, T.C. Cameron, January 24, 1977

• P239, HFEF Operations and Maintenance Manual: Visua l Examination Machine, W0053-0014-SA-03, HFEF OMM 4332, Revision 4, Fred L . DiLorenzo, August 13, 1991

• P240, Operation and Maintenance Manual: Precision G amma Scanner II (PGS-II) W0017-0106-SA-01, HFEF/N OMM 4352, Revision 0, T.C. Cameron, June 6, 1984

• P241, Operation and Maintenance Manual: Element Bal ance System, W0173-0007-SA-00, HFEF/N OMM 4362, Revision 2, P.L. Coomer, May 16, 1990

• P242, Operation and Maintenance Manual: Driver Fuel Bond Tester – South, W0084-0004-SA-00, HFEF/S OMM 4371, Revision 0, T.C. Cameron, April 7, 1977

• P243, Operation and Maintenance Manual: Eddy-Curren t Cladding Integrity Tester – North, W0175-0141-ES-00, HFEF/N OMM 4373, Revision 0 , T.C. Cameron, October 14, 1982

• P244, Operation and Maintenance Manual: Spacer Wire Removal Device (Shear); HFEF Operations and Maintenance Manual: Spacer Wire Remo val Devices, W0111-0011-SA00, HFEF/N OMM 4411, Revision 0: WO111-0011-SA-02, 4411, Revision 2, T.C. Cameron; Dale A. Tobios, April 5, 1977, and Ja nuary 21, 1991

• P245, Operation and Maintenance Manual: Summit Mill , Unit 2, W0186-0035-SA-01, HFEF/N OMM 4513, Revision 1, P.L. Coomer, August 3 1, 1978

• P246, Operation and Maintenance Manual: Cutoff Saw - HFEF/North, W0187-0014-SA00, HFEF OMM 4514, Revision 0, B.J. Nelson, July 22, 1976

• P247, Operation and Maintenance Manual: Metallogra phic Sample Sectioning Equipment, E0271-0004-SA-01, HFEF/N OMM 4710, Revis ion 1, Bart G. Carlson, May 24, 1984

• P248, Operation and Maintenance Manual: Low Speed D iamond Saw, E0271-0005-SA00, HFEF/N OMM 4711, Revision 0, B.G. Carlson, Apri l 21, 1978

• P249, Operation and Maintenance Manual: High-Speed Abrasive Saw, E0271-0014-SA, HFEF/N OMM 4712, Revision 0, R.D. Phipps, February 26, 1975

• P250, Hot Fuel Examination Facility Operation and M aintenance Manual: Remote Grinding and Polishing in the Containment Box; Oper ation and Maintenance Manual: Remote Grinding and Polishing in the Containment Bo x, HFEF-OMM-4730,B-18

Revision 0a, E0271-0006-SA, HFEF OMM 4730, Revision 0, C.J. Knight, R.D. Phipps, August 16, 1994, and January 6, 1975

• P251, Operation and Maintenance Manual: Sample Cle aning in the Station 2M Containment Box, E0271-0008-SA, HFEF/N OMM 4741, Re vision 0, R.D. Phipps, August 23, 1974

• P252, Operation and Maintenance Manual: Element Rad iography, W0170-0840-ES-01, HFEF/N OMM 5810, Review 1, Thomas C. Cameron, April 23, 1984

• P253, Operation and Maintenance Manual: InterBuildi ng Casks (IBC-1 and IBC-2), W0087-0012-SA-06, HFEF/N-S OMM 6101, Revision 6, P. L. Coomer, November 1, 1985

• P254, Operation and Maintenance Manual: Waste Cask - HFEF-5, W0087-0024-SA-01, HFEF OMM 6104, Revision 3, P.L. Coomer, December 4, 1985

• P255, Operation and Maintenance Manual: Materials T ransport Cask (HFEF-6), W0087-0112-ES-02, HFEF OMM 6105, Revision 2, P.L. C oomer, January 22, 1988

• P256, Operation and Maintenance Manual: Contact Han dled Solid Waste Handling - HFEF/S, W0351-0004-ES-01, HFEF OMM 6123, Revision 1 , S. Stantliff, March 13, 1986

• P257, Operation and Maintenance Manual: Off-Site Sh ipping Casks (T2-1 and T2-2), W0195-0003-SA-03, HFEF/N OMM 6202, Revision 3, P.L. Coomer, October 30, 1985

• P258, Operation and Maintenance Manual: Shipping Tu bes and Containers (Off-Site), W0196-0008-SA-0, HFEF/N OMM 6301, Revision 0, T.C. Cameron, May 12, 1980

• P259, Operation and Maintenance Manual: Solid Waste Handling and Disposal, W0201-0002-SA-02, HFEF OMM 6600, Revision 2, S. Sta ntliff, August 31, 1988

• P260, Operation and Maintenance Manual: Out-of-Cell Solid Waste Handling, W0201-0001-SA-04, HFEF/N OMM 6610, Revision 4, S. S tantliff, August 10, 1988

• P261, Operation and Maintenance Manual: Out-of-Cell Waste Handling - HFEF/N, W0201-0003-ES-02, HFEF/N OMM 6611, Revision 2, S. S tantliff, September 19, 1988

• P262, Operation and Maintenance Manual: Out-of-Cell Waste Handling - HFEF/S, W0351-0002-ES-02, HFEF/S OMM 6612, Revision 2, S. S tantliff, September 19, 1988

• P263, Operation and Maintenance Manual: In-Cell Sol id Waste Handling, W0351-0005-SA-01, HFEF/S OMM 6620, Revision 1, S. S tantliff, August 31, 1988

• P264, Operation and Maintenance Manual: In-Cell Rem ote Handled Solid Waste Handling - HFEF/N, W0201-0005-ES-02, HFEF/N OMM 662 1, Revision 2, S. Stantliff, September 1, 1988

• P265, Operation and Maintenance Manual: In-Cell Con tact Handled Solid Waste Handling - HFEF/N, W0201-0006-ES-02, HFEF OMM 6622, Revision 2, S. Stantliff, August 10, 1988B-19

• P266, Operation and Maintenance Manual: Remote Han dled Solid Waste Handling - HFEF/S, W0351-0003-ES-01, HFEF/S OMM 6623, Revision 1, S. Stantliff, February 20, 1986

• P270, Operation and Maintenance Manual: SLSF Loop O ut-of-Cell Handling System, W0204-0012-SA-05, HFEF OMM 7110, Revision 5, G.M. T eske, April 11, 1984

• P271, Operation and Maintenance Manual: Transporter System, W0204-0013-SA-02, HFEF OMM 7111, Revision 2, G.M. Teske, April 20, 19 84

• P272, Operation and Maintenance Manual: SLSF Loop I nsertion System, W0003-0154-SA-06, HFEF OMM 7120, Revision 6, G.M. T eske, April 11, 1984

• P273, Operation and Maintenance Manual: SLSF Loop Insertion Cell, W0003-0155-SA-03, HFEF OMM 7121, Revision 3, G.M. T eske, May 18, 1984

• P274, Operation and Maintenance Manual: Loop Disass embly Systems, W0204-0015-SA-04, HFEF/N OMM 7130, Revision 3, Greg ory M. Teske, March 29, 1983

• P275, Operation and Maintenance Manual: Loop Disass embly Machine, W0004-0094-SA-01, HFEF/N OMM 7131, Revision 1, G.M. Teske, August 11, 1971

• P277, Operation and Maintenance Manual: SLSF Loop G as Sampling Equipment, W0008-0004-SA-01, HFEF/N OMM 7133, Revision 1, G.M. Teske, January 11, 1982

• P278, Operation and Maintenance Manual: SLSF Loop C ut-Up Tools and Fixtures, W0006-0581-SA-02, HFEF/N OMM 7134, Revision 2, G.M. Teske, April 14, 1980

• P279, Operation and Maintenance Manual: SLSF Sodium Removal System, W0009-0088-SA-02, HFEF OMM 7140, Revision 2; Revisi on 1, G.M. Teske; Gregory M. Teske, April 20, 1984, and October 2, 1980

• P280, Operation and Maintenance Manual: Sodium Remo val Equipment, W0009-0074-SA-00, HFEF OMM 7141, Revision 0, Kendal , January 5, 1976

• P281, Operation and Maintenance Manual: Sodium Evap orator, W0009-00S7-SA-00, HFEF OMM 7142, Revision 0, Fred L. DiLorenzo, March 9, 1976

• P282, Operation and Maintenance Manual: Loop Sodium Disposal System, W0213-0082-SA-02, HFEF/N OMM 7150, Revision 2, K.T. Teraguchi, November 25, 1986

• P283, Operation and Maintenance Manual: SLSF Loop H ardware Disposal - In-Cell System, W0213-0186-ES-02, HFEF OMM 7160, Revision 2 , G.M. Teske, April 20, 1984

• P284, Operation and Maintenance Manual: Test Train Disassembly and Examination Equipment, W0010-0111-SA-01, HFEF OMM 7210, Revisio n 1, Fred L. DiLorenzo, June 22, 1976

• P285, Operation and Maintenance Manual: Decon Cell Equipment (TREAT Experiment), W0093-0246-SA-02, HFEF OMM 7310, Revision 2, K.T. T eraguchi, April 13, 1982B-20

• P286, Operation and Maintenance Manual: IBC Washsta tions Operation and Maintenance, W0350-0067-ES-04, HFEF/S OMM 9171, Rev ision 4, P.L. Coomer, October 25, 1985

• P298, Collection of Integrated Waste Tracking Syste m Container Profiles for 28 HFEF-5 Cans, Jeffery K. Paynter, Sara E. Gibbons, Laura P. Davis, August 16, 1978 – April 21, 1988, not inclusive

• P307, Core Materials Testing, Disassembly Procedure for Thermal Expansion Difference (TED) Monitor Capsules in Subassembly X262E, CMT Tr ansmittal No. 80-212-0033, DRF A00-299, D.R. Walker, June 9, 1980

• P308, Core Materials Testing, Disassembly Procedure for Thermal Expansion Difference (TED) Monitor Capsules in Subassembly X262F, CMT Tr ansmittal No. 81-212-0003, DRF A00-299, D.R. Walker, January 8, 1981

• P309, Core Materials Testing, Disassembly Procedure for Barrier Tube Capsules, Thermal Spacers and Thermal Expansion Difference (T ED) Monitor Capsules in Subassembly X334B, CMT Transmittal No. 81-212-0001, DRF A00-635, D.R. Walker, January 7, 1981

• P310, Core Materials Testing, Disassembly Procedure for Barrier Tube Capsules, Thermal Spacers and Thermal Expansion Difference (T ED) Monitor Capsules in Subassembly X334C, CMT Transmittal No. 81-212-0057, DRF A00-635, D.R. Walker, October 29, 1981

• P311, Core Materials Testing, Quality Assurance Pac kage for EBR-II Temperature Monitor Capsules (TED) (Subassembly X262G), CMT Tra nsmittal No. 81-212-0011, DRF A00-299, R.P. Tucker, D.R. Walker, March 10, 19 81

• P312, Core Materials Testing, Quality Assurance Pac kage for Barrier Tube Capsules for Irradiation in the EBR-II-5 Experiment (X262H), CMT Transmittal No. 81-212-0059, DRF AOO-635, R.P. Tucker, D.R. Walker, December 8, 1981

• P313, Core Materials Testing, Quality Assurance Pac kage for EBR-II Temperature Monitor Capsules (TED) (Subassembly X262H), CMT Tra nsmittal No. 81-212-0058, DRF AOO-299, R.P. Tucker, D.R. Walker, December 10, 1981

• P314, Core Materials Testing, Disposition and Disas sembly Procedure for Barrier Tube Capsules, Thermal Spacer and Thermal Expansion Diff erence (TED) Monitor Capsules in Subassembly X262H, CMT Transmittal No. 82-212-004 4, DRF AOO-299 and AOO635, R.E. Blood, September 28, 1982

• P315, Core Materials Testing, Quality Assurance Pac kage for EBR-II Temperature Monitor Capsules (TED) (Subassembly X262J), CMT Tra nsmittal No. 82-212-0047, DRF AOO-299, R.P. Tucker, R.E. Blood, October 29, 1 982

• P316, Core Materials Testing, Disposition and Disas sembly Procedure for Barrier Tube Capsules, Thermal Spacer and Thermal Expansion Diff erence (TED) Monitor Capsules in Subassembly X262J, CMT Transmittal No. 83-212-005 9, DRF AOO-299 and AOO-635, R.P. Tucker, September 16, 1983B-21

• P317, TED Manufacturing Procedures, OM-TED, Douglas L. Porter, November 6, 1990 – February 22, 1992

• P325, Operations and Maintenance Manual: Liquid Dis posal System - Containment Box, W0191-0010-SA-00, HFEF/N OMM 4752, Revision 0, B.G. Carlson, February 1, 1978

• P361, Operation and Maintenance Manual, Structural Design of HFEF/North, W012S-0038-SA-00, HFEF OMM 2110, Revision 0, B.J. Ne lson, December 7, 1976

• P362, Operation and Maintenance Manual, Truck Lock, Fred L. DiLorenzo, W0125-0006-SA-02, HFEF OMM 2131, Revision 2, Februa ry 13, 1984

• P363, Operation and Maintenance Manual, High Bay Ar ea, B.J. Nelson, W0125- 0004-SA-01, HFEFIN OMM 2132, Revision 1, May 16, 19 78

• P364, Operation and Maintenance Manual, High Bay Cr ane, Paul Wayne, W0133-0003-SA-09, HFEF/N OMM 2510, Revision 9, Octo ber 3, 1988

• P365, Operation and Maintenance Manual, Freight Ele vator, B.J. Nelson, W0133- 0043-SA-00, HFEF OMM 2520, Revision 0, January 7, 1 976

• P366, Operation and Maintenance Manual, Truck Lock Crane, Paul Wayne, W0133-0079-ES-05, HFEF/N OMM 2590, Revision 5, Dece mber 1, 1987

• P367, Operation and Maintenance Manual, In-Cell Con tamination Monitoring System, W0135-0023-SA-04, HFEF/N OMM 2680, Revision 4, Kenn eth T. Teraguchi, April 20, 1988

• P368, Operation and Maintenance Manual, Main Cell S tructure, W0137-00S1-SA-00, HFEF OMM 3111, Revision 0, B.J. Nelson, October 13, 1976

• P369, Operation and Maintenance Manual, Decon Cell Structure, W0138-0011-SA-00, HFEF OMM 3121, Revision 0, B.J. Nelson, January 20, 1977

• P370, Operation and Maintenance Manual, Decon Cell Spray Chamber, W0101-0014-SA-01, HFEF/N OMM 3124, Revision 1, Fred L. DiLorenzo, January 26, 1984

• P371, Operation and Maintenance Manual, Hot Repair Area, W0092-0003-SA-04, HFEF/N OMM 3150, Revision 4, Clarence A. Frickey, No vember 4, 1988

• P374, Operation and Maintenance Manual, Bagout Port , W0092-0159-ES-04, HFEF/N OMM 3156, Revision 4, Clarence A. Frickey, November 4, 1988

• P376, Operation and Maintenance Manual, Secondary F ilters, W0159-0027-00-SA, HFEF/N OMM 3662, Revision 0, B.J. Nelson, February 1 2, 1975

• P377, Operation and Maintenance Manual, Hex Tube Sl itter, W0168-0001-SA-01, HFEF/N OMM 4154, Revision 1, P.L. Coomer, January 1 2, 1982

• P378, Operation and Maintenance Manual, Dipper Tran sfer and Storage, W0164-0002-SA, HFEF/N OMM 4161, Revision 0, D.M. Mc Kenzie, September 27, 1974B-22

• P379, Operation and Maintenance Manual, Dipper Heat ing Chamber - North, W0164-0025-SA-01, HFEF/N OMM 4162, Revision 1, P.L. Coomer, October 22, 1979

• P380, Operation and Maintenance Manual, Bench Mill - South, W0105-0036-SA-00, HFEF/S OMM 4511, Revision 0, P.L. Coomer, November 15, 1977

• P381, Operation and Maintenance Manual, CNC Milling Station - HFEF/N, W0106-0001-ES-02, HFEF/N OMM 4512, Revision 2, P.L. Coomer, June 28, 1988

• P382, Operation and Maintenance Manual, Bench Power Hacksaw - South, W0045-0045-ES-00, HFEF/S OMM 4515, Revision 0, P.L. Coomer, June 8, 1984

• P383, Operation and Maintenance Manual, Diamond Cut -Off Saw - South, W0045-0030-ES-00, HFEF/S OMM 4517, Revision 0, P.L. Coomer, October 21, 1980

• P384, Operation and Maintenance Manual, Sample Moun ting Equipment, E0271-0016-SA, HFEF/N OMM 4720, Revision 0, R.D. Ph ipps, February 24, 1975

• P385, Operation and Maintenance Manual, SLSF Waste Cask - HFEF-14, W0087-0147-ES-01, HFEF/N OMM 6110, Revision 1, P.L. Coomer, November 19, 1985

• P386, HFEF Operations and Maintenance Manual, Analy tical Laboratory Pneumatic Cask (ALP-7) Operation and Maintenance, W0087-0191- ES-00, OMM 6113, Revision 0, M.E. Vaughn, September 11, 1991

• P395, Operation and Maintenance Manual, In-Cell Cle aning and Etching Equipment, E0271-0007-SA, HFEF/N OMM 4740, Revision 0, R.D. Ph ipps, August 19, 1974

• P396, Hot Fuel Examination Facility Operations and Maintenance Manual, Etching of Remotely-Prepared Metallographic Samples, HFEF-OMM- 4742, Revision 1a, D.L. Davidson, April 13, 1995

• P397, Hot Fuel Examination Facility Operations and Maintenance Manual, ContainmentBox Liquid Supply, HFEF-OMM-4751, Revision 0a, R. L ee, July 28, 1995

• P398, Operation and Maintenance Manual, In-Cell Rad iography Equipment – North W0170-0838-ES-01, HFEF/N OMM 5800, Revision 1, Thom as C. Cameron, February 10, 1984

• P400, Operation and Maintenance Manual, Main Cell E quipment (TREAT Experiment), W0093-0347-SA-02, HFEF/N OMM 7320, Revision 2, K.T. Teraguchi, February 10, 1983

• P401, Operation and Maintenance Manual, TREAT Exper iments, W021S-0001-SA-00, HFEF OMM 7400, Revision 0, Revision 1, K.T. Teraguc hi, March 17, 1976 and September 9, 1981

• P402, Operation and Maintenance Manual, RAS Sodium Loops, W0215-0002-SA-02, HFEF/N OMM 7410, Revision 2, K.T. Teraguchi, Februa ry 18, 1983

• P403, Operation and Maintenance Manual, HEDL Sodium Loop, W0215-0004-SA-01, HFEF OMM 7430, Revision 1, K.T. Teraguchi, November 11, 1980B-23

• P404, Operation and Maintenance Manual, HEDL Static Capsule, K.T. Teraguchi, W0215-000S-SA-00, HFEF OMM 7440, Revision 0, Revisi on 1, October 19, 1976 and July 10, 1979

• P405, Operation and Maintenance Manual, HEDL US/UK Static Capsule Experiment, W0215-0006-ES-OO, HFEF/N OMM 7450, Revision 0, K.T. Teraguchi, November 7, 1979

• P406, HFEF Operations and Maintenance Manual, Mark III Sodium Loops, W0215-0007-ES-04, OMM 7460, Revision 4, Kenneth T. Teraguchi, January 21, 1991

• U001, Various Sections of the ANL-W Waste Handling Manual, Waste Management Information Bulletins, WMIB-8 through WMIB- Various

• U016, EBR II Project Work Authorization Form, IFR F at Slug Experiment, WAF-1212, C.W. Wilkes, G.R. Seidel, April 24, 1985

• U025, DRAFT Facility Waste Descriptions Argonne-Wes t, December 14, 1973

• U038, Restricted Loading Instruction No. 600-E, Log No. 1-K, Revision 3, D.R. Ellis, T.J. Kehne, February 14, 1985

• U039, Experimental Subassembly Transfer, C.W. Wilke s, February 12, 1985

• U040, Xenon Tag Dummy Record, Anal. Lab. No. 56410, M.T. Laug, January 2, 1985

• U041, Miscellaneous pages including: Logsheet showi ng before and after radioisotope weights for different batches, Experimental Subasse mbly Transfer for X-421, and Subassembly Transfer from Reactor Plant for X-421, C.W. Wilkes, not legible, Not dated, February 12, 1985 and March 24, 1987

• U042, HFEF Procedure Change Notice, Examination of X 423A, 2-1869, E.M. Franklin, December 11, 1985

• U043, Hot Cell Contamination Control Plan and Proce dures, Rough Draft, John Krsul, November 1989

• U047, Sample Accountability Log, September 2, 1987

• U048, Samples to L&O, November 2, 1987

• U064, Sample Accountability Log for X-421, Element # T-225, S.K., September 2, 1987

• U070, HFEF Procedure Change Notice, Examination of X423, PCN No. 1, PWS 2-1847, E.M. Franklin, October 14, 1985

• U080, Density on Porous Samples, Sample – X423C T-3 30, #61176, May 16, 1988

• U081, Dipping Experiment for Density, Sample B X423 C T-330 #61176, May 16, 1988

• U085, Accuracy of Immersion Density Measurement, Ma y 5, 1988

• U086, Transfer of SS Materials - Between Areas, 086 4, November 5, 1986

• U104, Argonne National Laboratory Analytical Sample Record for X-421 T128, 60754, 60755, 60756, Robert Villarreal, November 19, 1987B-24

• U105, Axial Fuel Expansion for X-421 T-128, November 16, 1987

• U108, Inspection/Disposition Report for .290 Jacket s for Fat Slug (X423 S/A), 21073, Mark H. Williamson, April 24, 1985

• U115, Sample Accountability Log for X423B, PWS No. 2-1951, Work Order No. 11-U, Franklin, January 9, 1987; January 27, 1987; Januar y 29, 1987; February 10, 1987; December 1, 1987

• U116, HFEF Procedure Change Notice, Examination of X423B, PCN No. 3, PWS No. 2-1951, Webb, January 28, 1987

• U122, Argonne National Laboratory Analytical Sample Record, S/A X423C T-344, 61313-B, Robert Villarreal, August 2, 1988

• U130, Sodium Logging Analyses on X421, T225 (U-10Zr ), R. Villarreal, January 1988

• U132, Immersion Density Procedures for U-10Zr and U -Pu-10Zr Fuel and Cladding in Hot Cell, Wendy Schmier, Undated

• U133, Transfer of SS Materials - Between Areas, 087 3, October 15, 1986

• U138, Argonne National Laboratory Analytical Sample Record for X421 (T128) Pu, 60486, Robert Villarreal, September 8, 1987

• U139, Argonne National Laboratory Analytical Sample Record for X421 (T225) Pu, 60487, Robert Villarreal, September 8, 1987

• U140, X421 Radiochemistry, January 12, 1988

• U145, Argonne National Laboratory Analytical Sample Record for X423C T302, 61104, Robert Villarreal, February 18, 1988

• U146, Argonne National Laboratory Analytical Sample Record for X423C T325, 61173, Robert Villarreal, March 3, 1988

• U151, Radial Drilling Notes X421 T108 U-10-Pu-Zr, R alph Martell, June 24, 1987

• U153, ANL Analytical Sample Record, S/A X421 (T108) , 60485, Carlson, September 8, 1987

• U154, ANL Analytical Sample Record, S/A X421 (T108) , 60652A, Carlson, October 22, 1987

• U155, ANL Analytical Sample Record, S/A X421 (T108) , U-19Pu-10Zr, 61137, Carlson, February 24, 1988

• U161, Procedure for Preparation of Samples for Burn up Determination by Isotopic Dilution Mass Spectroscopy (IDMS) Analysis, Cal Mor gan, John Krul, Undated

• U162, X421 Surveillance Analyses at ~10 a / o BU Hot Cell Analyses, Undated

• U170, Total Characterization of Hot Cell Waste ANL- W Analytical Laboratory, Undated

• U176, Argonne National Laboratory Analytical Sample Record for X423C T302, 61105, W. Schmier, February 18, 1988B-25

• U177, Argonne National Laboratory Analytical Sample Record for X423C T325, 61174, W. Schmier, March 3, 1988

• U178, Argonne National Laboratory Analytical Sample Record for X423C T330, 61175, W. Schmier, March 3, 1988

• U183, Radial Analyses of IFR Fuel, June 24, 1987

• U184, ANL-W Analytical Laboratory IFCF Support Acti vities, R. Villarreal and J.R. Krsul, October 1, 1987

• U189, HFEF Terminal Examination of IFR S/A X423C, P WS 2-2142, October 30, 1987

• U190, Argonne National Laboratory, Argonne-West Ana lytical Chemistry Laboratory, Criticality Hazards Control Statement, ID-CHCS-A11( 8), W. R. Sovereign and R. Villarreal, October 20, 1987

• U191, Na Logging Expt. 60487 X421 T-225, Undated

• U194, Sample Accountability Log for X423C, PWS No. 2-142, PCN, No. 4, February 11, 1988

• U196, Design Description and Safety Analysis for X- 419, X-420, and X-421, C.E. Lahm and R.G. Pahl, December 1984

• U205, Procedure Change - Examination of IFR S/A X42 3B, PWS No. 2-1951, E.M. Franklin, January 30, 1987

• U213, Argonne National Laboratory Analytical Sample Record for X423B, 60819, Robert Villarreal, December 7, 1987

• U218, Analytical Research and Development Program P aper, re: Determination of Burnup on Nuclear Fuels, ANL-6900, R.P. Larsen, Und ated

• U219, AL Sample Logbook No. 20 re: July 1984 - Febr uary 1986, July 1, 1984

• U220, AL Sample Logbook No. 21 re: February 1986 - May 1987, February 1, 1986

• U221, AL Sample Logbook No. 22 re: May 1987 - Septe mber 1988, May 1, 1987

• U222, Index of Material of Analytical Methods for L aboratory Use, Undated

• U223, The Radiochemical Determination of Americium, Am-LaF3-α, ANL-CEN, July 24, 1959

• U224, The Spectrophotometric Determination of Ceriu m in Ammonium Tartrate, ANLCEN, January 13, 1961

• U225, Radiochemical Determination of Cerium by Liqu id-Liquid Extraction, Ce-FP, ANL-CEN, July 1960

• U226, Volumetric Determination of Cerium with EDTA, Ce-Vol, ANL-CEN, July 2, 1959

• U227, Volumetric Determination of Lanthanum with ED TA, February 26, 1959B-26

• U228, Separation of Neptunium from Fission Products , NP-γ, ANL-CEN, February 26, 1963

• U229, Fission Product Cesium, Cs, January 1959

• U230, Determination of Plutonium by Hexone Extracti on and Alpha Counting, February 25, 1963

• U231, Separation of Plutonium by Ferric Hydroxide – Lanthanum Fluoride Precipitation, Pu-Fe(OH)3-LaF3-α, January 1958

• U232, Plutonium by Lanthanum Fluoride, Pu-A, Undate d

• U233, Procedure Manual: A Summary of Uranium Analys es, U-Sum, ANL-CEN, March 1963

• U234, Water Soluble Uranium Determination, W.S.U, J uly 16, 1956

• U235, Spectrophotometric Determination of Thorium, Th-C, ANL-CEN, October 1959

• U236, Colorimetric Determination of Zirconium with Alizarin-Red-S, Zr-C, Revision 1, ANL-CEN, (Revision 0) October 1958, Revision 1 July 6, 1960

• U237, Volumetric Determination of Thorium with EDTA , Th-V, ANL-CEN, July 1960

• U238, Volumetric Determination of Zirconium with ED TA, Zr-Vol, ANL-CEN, May 20, 1959

• U239, Fission Product Zirconium, Zr-F.P, ANL-CEN, F ebruary 23, 1959

• U240, Fission Product Strontium (and Barium), Sr-Ba -FP, January 1959

• U241, Counting Methods: Radioactive Decay Chains fo r Various Elements, Undated

• U260, HFEF Process Work Sheet, Radiography of T5 Te st Train, PWS No. 2-817, Revision 0, G.C. McClellan, December 10, 1979

• U285, Experiment Designation and Identification, Ju ly 1991

• U483, HFEF Transuranic Waste Can Log Cards, Undated

• U484, Radioactive Scrap & Waste Storage/Disposal Re quest and Authorization Forms and related documents, Undated

• U541, Shipping Papers Gathered from MFC for ILTSF H FEF-5 Inserts, February 10, 1983

• U551, Compilation of HFEF Process Work Sheets and H FEF Procedure Change Notices; includes HFEF PWS Log, Subassemblies, PWS Nos., and PCN Nos., Various Dates

• U552, Compilation of MFC Liner Documents, Various d ates

• U607, Excel Spreadsheet: Information for 108 MFC R H-TRU Liners, Reese Gannon, February 11, 2009

• U645, Collection of Documents Pertaining to the Man ufacture of Thermal Expansion Difference (TED) Temperature Monitor Jackets, Vario us datesB-27

• U646, Fuel Manufacturing Process Data Sheets, TED M anufacturing, OM-TED-1B, Revision 0, Douglas L. Porter, December 9, 1991

• U647, Thermal Expansion Difference Temperature Moni tor Assembly Drawings, E0289-0005-0C-01, C.W. Wilkes, August 29, 1989

• U648, Hot Fuel Examination Facility (HFEF) at Idaho National Laboratory (INL) RH TRU Radiological Characterization - Data Culled fro m Available AK and Used as Input for ORIGEN2.2 Calculations, INL-RH-61, Revision 0, J.J. Klingensmith, September 23, 2009

• U649, Hot Fuel Examination Facility (HFEF) at Idah o National Laboratory (INL) RH TRU Radiological Characterization - ORIGEN2.2 Input and Output for the HFEF Fuel Pins and the Processing Codes and Batch Files Used to Obtain the Results, INL-RH-62, Revision 0, J.J. Klingensmith, September 23, 2009

• U650, Hot Fuel Examination Facility (HFEF) at Idaho National Laboratory (INL) RH TRU Radiological Characterization - ISOCS Measureme nts Taken at INL to Determine the Fraction of Gamma-Emission Activity in the HFEF Lot 1A Liners Due to Cs-137 and Co-60, INL-RH-63, Revision 0, J.J. Klingensmith, Se ptember 23, 2009

• U651, Hot Fuel Examination Facility (HFEF) at Idah o National Laboratory (INL) RH TRU Radiological Characterization - ORIGEN2.2 Output Masses and Activities Converted to Curie Scaling Factors, INL-RH-64, Revi sion 0, J.J. Klingensmith, September 23, 2009

• U652, Hot Fuel Examination Facility (HFEF) at Idaho National Laboratory (INL) RH TRU Radiological Characterization - Dose-to-Curie C alculations for Co-60 and Cs-17 for HFEF Drum Characterization, INL-RH-65, Revision 0, J.J. Klingensmith, September 23, 2009

• U653, Hot Fuel Examination Facility (HFEF) at Idah o National Laboratory (INL) RH TRU Radiological Characterization - Estimation of t he Uncertainty in the Calculated Radionuclide Content in Lots 1A and 1B of the HFEF Waste Streams, INL-RH-66, Revision 0, J.J. Klingensmith, September 23, 2009

• U654, HFEF at Idaho National Laboratory (INL) RH TR U Radiological Characterization - Isotopes in Addition to the 10 WIPP-Required Repo rtable Isotopes and in Aggregate that Provide 95% of the Radiological Hazard in the HFEF Lot 1A and 1B Liners Waste Stream, INL-RH-67, Revision 0, J.J. Klingensmith, S eptember 23, 2009

• U655, Hot Fuel Examination Facility (HFEF) at Idaho National Laboratory (INL) RH TRU Radiological Characterization - HFEF Lot 1A DTC Spreadsheet, INL-RH-68, Revision 0, Revision 1, David W. Moody, September 2 4, 2009 and November 9, 2009

• U660, EBR-II Power Run Information, August 1, 1964 through September 30, 1994

• U843, Scaling Factors Development, INL-RH-02, WS11, S9, S13, Revision 0, J. Holderness, June 5, 2006

• U845, MCNP Sensitivity Studies, INL-RH-04, Revision 0, J. Holderness, May 8, 2006B-28

• U846, INL Cs-137 Dose-to-Curie Correlation Uncertai nty, INL-RH-05, WS11, S9, S13, Revision 0, J. Holderness, May 8, 2006

• U848, Uncertainty Analysis for Drums, INL-RH-07 Rev ision 0, J. Holderness, June 5, 2006

• U852, RERTR Adjustment Factor Development, INL-RH-1 1, Revision 0, J. Vance, May 8, 2006

• U855, Co-60 Dose Rate Contribution, INL-RH-14, Revi sion 0, J. Holderness, May 8, 2006

• U856, Derivation of Burnup and Composition for Thor ium Pins, INL-RH-15, Revision 0, J. Vance, May 8, 2006

• U857, Scaling Factors Sensitivity Studies, INL-RH-0 16, Revision 0, J. Holderness, June 5, 2006

• U858, Demonstration of Commonality of INL and LANL Experimenters, Calculation No. INLRH-17, Revision 0, J. Vance, July 11, 2006

• U883, Fuel Manufacturing Subassembly Transfer, F-60 00G (B-3411G), B-3411G, C.W. Wilkes, May 4, 1983

• U885, Collection of Documents Pertaining to Subasse mbly H6, Various dates

• U886, Interface Agreements by HFEF and HEDL for the HEDL Safety Test Programs at HFEF and Scope of HFEF Work for FY-1978, J.H. Cook, J.D. Berger, I.L. Metcalf, Undated

• U892, Collection of Documents Pertaining to Subasse mbly X027, Various dates

• U895, Photograph of HFEF Canisters in IBC, includin g N-94, P4280009, April 28, 2009

• U896, Photograph of HFEF Canisters in IBC, includin g N-147 and N-136 with hazardous waste labels, P4280017, April 29, 2009

• U898, Fuel Composition Calculations, LANL-RH-04, Re vision 0, Jene Vance, February 22, 2006

• U899, Uncertainty Analysis of Canisters with 364 Ca ns, LANL-RH-25, Revision 0, James H. Holderness, May 8, 2006

### ATTACHMENT C

EPA EVALUATION ISSUE TRACKING FORM – RADIOLOGICAL CHARACTERIZATIONC-1 Inspection No. EPA-INL-CCP-RH-12.09-8 Issue Number: INL-RH

- RC-09

- 003CR Date: December 9, 2009 Inspector: P. Kelly & A. Mobasheran Attachments? YES NO Sample Size: Two Radiological Characterization Reports Population size (if known): Not Applicable
Description of Issue: Based on this T1 evaluation, numerous changes to t he two radiological characterization reports CCP-AK-INL-551 and CCP-AK-INL-581 are requi red. These changes are required to enable the documents to adequately support technical aspects o f both waste streams. These changes will be capture d in a freeze file that will be provided to EPA by Decembe r 18, 2009.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s):

D. Discussed with: D. Moody, J. Klingensmith, M. Sensibaugh, and J. Ha rvill

E. Additional Comments:

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: December 18, 2009

### ATTACHMENT D

EPA EVALUATION ISSUE TRACKING FORM –

ACCEPTABLE KNOWLEDGED-1 Inspection No. EPA-INL-CCP-RH-12.09-8 Issue Number: INL-RH

- AK-09

- 002CR Date: December 9, 2009 Inspector: C. Walker Attachments? YES NO Sample Size: Waste Stream ID-HFEF-5400-RH Drums Population size (if known): Lot 1A (28 HFEF-5 cans)
Description of Issue: Four related issues: 1.0 The AK Summary requires additional information to j ustify the waste stream designation. Table(s) and/or text should be added to show commonality of processes and test material in and between the three areas sufficient to show that the same proces ses and materials were managed throughout the HFEF, FCF, and Analytical Laboratory to support the use of a single scaling factor. Note that revision of other sections (e.g., Section 5.4.5, SNF/HLW dis cussion) may be warranted, depending on the additional information. 2.0 The defense determination in Section 4.1.4 includes numerous activities that are defense related, but must be better correlated to specific process areas to show association with wastes generated from the HFEF, FCF, and Analytical Laboratory. 3.0 The waste generation and management stream must be better presented to show how/if wastes are physically commingled (e.g., Analytical Laboratory to HFEF and FCF). 4.0 Section 5.4.3, Radiological Characterization, does not adequately address historical information or da ta pertaining to the 10 WIPP-tracked radionuclides, in cluding the anticipated isotopic distributions by general programs (or other suitable designation) in support of the waste stream designation.

Revise the AK Summary as appropriate to address the above; freeze file modification is acceptable. B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s):

D. Discussed with: K. Peters, S. Smith, M. Sensibaugh, I. Quintana, M. Doherty

E. Additional Comments:

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: TBD