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 PROGRAM 

FOR IDAHO NATIONAL LABORATORY (INL): 

ADDITION OF TWELVE CONTAINERS TO WASTE STREAM ID-ANLE-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 2010
i 

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 Waste 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 Knowledge 
ii 

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 reactor 
iii 

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 Facility 

INL Idaho National Laboratory 

INEEL Idaho National Engineering and Environmental Laboratory 

INEL Idaho National Engineering Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

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 Computer Code Collection, 

Oak Ridge National Laboratory 

MFC Materials and Fuel Complex 
iv 

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 Payload Control 

TRU transuranic 
v 

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 zirconium 
1 

1.0 EXECUTIVE SUMMARY 

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

of retrievably-stored, remote-handled (RH) transuranic (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-ANLE-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 INL 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 January 2007, as part of the 

baseline approval, however, the addition of containers is a T1 change; 

• New RH Waste Stream ID-HFEF1

-S5400-RH, Lot 1A with 28 casks; and 

• New RH Waste Stream ID-INTEC2

-RH, consisting of two containers 

The baseline approval is specific to a certain number of containers and any addition of new 

containers to the approved waste stream requires CBFO and INL-CCP to submit a T1 change 

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

The Central Characterization Project (CCP) is responsible for characterizing the above wastes 

using the system of controls, which EPA evaluated during the baseline inspection conducted in 

July 2006 and approved in January 2007. A summary of EPA’s approval of the INL RH TRU 

waste characterization program is included as Attachment A. Because there were no new 

equipment or processes on site at INL to examine, EPA conducted the evaluation at EPA 

Headquarters in Washington, DC, on December 8-9, 2009. 

The scope of this T1 evaluation initially included the three waste streams mentioned above. 

However, during the December evaluation in Washington, 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 sampling the two INTEC waste containers and 

performing radiochemical analysis using processes/procedures not previously evaluated or 

approved by EPA. EPA determined that all processes/procedures implemented for sampling and 

analysis must be first evaluated for technical adequacy before EPA can assess the use of scaling 

factors and approve the subject waste stream. Consequently, EPA removed the ID-INTEC-RH 

waste stream from the scope of this T1 evaluation and informed CBFO that the sampling and 

analysis process implemented must be evaluated before considering approval of the INTEC 

waste. EPA committed to perform this evaluation during the month of January 2010. 

Pending completion of EPA’s onsite evaluation of the sample collection and analyses that 

support this waste stream, EPA will issue a separate report addressing this waste stream. This 

 

1

 HFEF is the Hot Fuel Examination Facility at the Materials 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 Engineering Center. 
2 

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

This report presents the results of the T1 evaluation. Section 4.0 discusses EPA’s evaluation of 

the addition of twelve containers to Waste Stream ID-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 satisfactorily resolved subsequent to the Washington, 

DC, meeting and no issues remain open relative to this 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 be provided to EPA for review on a 

quarterly basis. We have revised the INL-CCP RH Tiering 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 adequate. EPA, therefore, approves 

the two waste streams, ID-ANLE-S5000 and ID-HFEF-S5400-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 activities 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 the July 16, 2004 Federal Register notice, 

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

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

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

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

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

TRU wastes destined for disposal at the WIPP. 

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

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

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

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

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

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

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

specific to a change. DOE may choose to characterize and dispose of, at risk of subsequent EPA 

disapproval, any previously approved TRU waste using processes/procedures/equipment 

implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may 

conduct continued compliance inspections to evaluate implemented T2 changes to verify 

adequacy. 
3 
4 

Table 1. Tiering of RH TRU WC Processes Implemented by INL-CCP (Revised January 28, 2010*)

RH WC Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH WC Process - T2 Changes 

Acceptable Knowledge (AK) Addition of containers to approved Waste Streams 

Any new waste streams not approved under this baseline

Substantive modification(s) that have the potential to affect the characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502 Load management for any RH waste stream 

Notification to EPA when AKSRs, Radiological 

Characterization Reports and Certification Confirmation Test Plans (e.g., CCP-INL-AK-500, CCPINL-AK-501, and CCP-INL-AK-502) updates are 

approved by CBFO 

Notification to EPA when changes to AK documentation as 

a result of WCPIP revisions have been made (e.g., CRR) 

Notification to EPA when a Correlation or Surrogate

Summary Form is completed for each of the RH containers in this waste stream identified as CH, based upon measured dose rates that present NDA results for assayed containers

Notification to EPA once waste stream data package for 

debris waste stream and any modifications to the WSPF, including the CRR and AK Summary, are completed 

Notification to EPA that the final Dose-to-Curie (DTC) 

determination is complete for RH containers numbers 728 through 737, as identified in AK Reference P030 AK accuracy reports (prepared annually, at a minimum) 

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

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501 Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedure 

Any new waste stream not approved under this baseline or addition 

of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors

Notification to EPA upon completion of revisions of CCPAK-INL-501 or CCP-TP-504 that require CBFO approval

Visual 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 necessary None 

Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 or 

wastes from an S3000 or S4000 waste stream 

Notification to EPA upon completion of changes to RTR procedure(s) that require CBFO approval. Notification to EPA upon addition of a new RTR unit(s).

WIPP Waste Information System (WWIS) None Changes made to WWIS procedure(s) that require CBFO

approval 
5 

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

or the use of the high-range probe as described in CCP-TP-504. - Additions to the original tiering table from the 2007 baseline inspection appear in bold. 
6 

3.0 SCOPE OF THE TIER 1 EVALUATION 

This T1 evaluation encompassed the following two INL RH waste streams: 

• The addition of twelve containers to RH Waste Stream ID-ANLE-S5000, which had been 

approved previously, is discussed in Section 4.0 

• INL RH Waste Stream ID-HFEF-S5400-RH, Lot 1A, consisting of 28 HFEF-5 cans, is 

discussed in Section 5.0 

The RH wastes that were the subject of this T1 evaluation are retrievably-stored debris that 

INL-CCP plans to characterize for disposal at WIPP. Technical aspects of the waste 

characterization processes implemented to characterize 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 waste characterization areas, AK and 

radiological characterization, each of which is addressed separately in this report. Personnel who 

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

function during the evaluation. 

 

Table 2. T1 Evaluation Participants 

Name Affiliation & Function 

Rajani Joglekar 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 – Radiological Characterization 

Amir Mobasheran SC&A, Technical Evaluator – Radiological Characterization 

Kevin Peters CCP, AK 

Scott Smith CCP, AK 

Jene Vance* CCP, Technical Support, Radiological Characterization 

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 Radiological Characterization 

Joe Harvill WTS/CCP, Observer 

Mike Sensibaugh CCP, Technical Support for Radiological Characterization 

Kira Darlow SC&A, Observer 

Jim Oliver CTAC Observer 

*Jene Vance did not attend the evaluation in Washington, DC, but was involved in several 

discussions with EPA technical personnel by telephone 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 Cell being added to INL RH Waste Stream 

ID-ANLE-S5000. This waste stream consists of debris 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 pins from various reactor programs at ANL-W 

and other DOE and commercial reactors that were transferred 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 information to determine whether the INL-CCP 

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

for the addition of twelve containers of retrievably-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 following with respect to the use of AK for 

characterizing twelve containers of M-4 Cell RH debris 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 (WSPF) and Characterization 

Reconciliation Report (CRR) 

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

• Personnel training 

• Non Conformance Reports (NCRs) and AK Discrepancy Resolutions (DRs) 

• AK accuracy 

• Load management 
8 

Documents, Waste Containers, and Batch Data Reports Provided

EPA evaluated the documentation that INL-CCP had prepared to support including twelve 

containers of M-4 Cell wastes in Waste Stream No. ID-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-Curie3

[DTC]) and non destructive examination analysis, (i.e., Real-Time Radiography [RTR] or Visual 

Examination [VE]) are reviewed as part of EPA’s traceability 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 available for drums as they were packaged, 

shipped to INL for storage, and subsequently subjected 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 IDAERH000

AK was used to characterize Waste Stream ID-ANLE-S5000 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 characterized 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 underwent 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 subjected to AK confirmation using 

nondestructive assay (NDA). Instead, confirmation of the AK-reported radiological contents of 

the RH debris waste containers, TRU waste designation, and activity-related DQOs were 

 

3

 DTC uses the terms “Dose” or “Dose Rate” to describe 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 technique supported by radionuclide scaling 

factors that were derived through modeling. Note that 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-S5000 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 belong in the ID-ANLE-S5000 waste stream, 

based upon process information, as well as the waste’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 following: how these data had been integrated; 

impacts of the information on the waste stream; changes to the radiological and physical 

characteristics of the waste; and other elements that could affect 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 elements typically included in a T1 review are 

presented for completeness, but were not changed from the original baseline determination by 

the addition of the twelve containers. 

(1) The adequacy of the definition of Waste Stream ID-ANLE-S5000 was examined with 

respect to the addition of the M-4 Cell wastes, including drum traceability, and was found 

to be adequate. 

The Remote-Handled TRU Waste Characterization Program 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 properties.” 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 was 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 determine whether these drums fit within the 

approval of the original waste stream. The discussion provided in CCP-AK-INL-500, Revision 7 

elaborates on waste origin and is similar to the original waste stream. 

To better understand the movement of materials between 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 packaged in 30-gallon drums during three 

campaigns: 
10 

• January 8-10, 1979: Drums 00395, 00396, 00397, 00398 

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

• March 12 and 16, 1981: Drums 001002, 001003, 001004, 001005 

A traceability analysis (the paper “pedigree”), shown below in Table 4, supports the contention 

that the subject drums “fit” in Waste Stream ID-ANLE-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 Big 

Rock/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 processes, inputs, and activities. Data examined 

included several references, including numerous EXXON references discussing the Big Rock 

fuel projects (e.g., C355, C357, C1031). These data indicate that the same procedures (i.e., 

testing) were implemented in the M-4 and AGHCF Cells, and INL-CCP representatives stated 

that the fuel pins managed in M-4 Cells are directly traceable to the same fuel pins/AG Nos. in 

the AGHCF Cells, as evidenced in References C1031 and CCP-AK-501. INL-CCP 

representatives stated their research indicated that while there were some fuels or identifiers 

associated with Building 200 activities that they could not trace, the majority of data they 

obtained showed a clean and substantiated link between Building 200 (and M-4 Cell activities) 

and Building 212, which housed the AGHCF. Therefore, data indicate that common processes 

were implemented for testing and waste generation/management in the AGHCF and other cells 

within the M-Wing, and AGHCF processes and materials 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 prior to shipment back to the AGHCF for further 

analysis. Building 200 also sometimes accepted fuel pins for testing or sectioning prior to 

shipment to the AGHCF. Regardless, INL-CCP representatives stated that all fuel pins within 

the “system” of the AGHCF/M-Wing operated in a closed loop, in that all fuel pins tested in the 

Building 200 M-Wing either originated in or were sent back to the AGHCF following initial 

work. This indicated that the M-4 Cell fuel pin population is a subset of the total population of 

fuel pins managed or tested in the AGHCF. Accordingly, the radionuclide composition of the 

M-4 Cell wastes is a subset of the waste stream’s overall 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 found 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 to the fuel pins tested in the M-4 Cell. This 

reference, as well as new information obtained through VE of the containers (BDRs), indicates 

that the following AGHCF Numbers (AG Numbers) are among 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 

• GB10 
12 

• 175A6 

• 119 

• 135 

• 45B 

EPA found some discrepancies in discussion in relevant 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 cited 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 Table 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 waste stream as part of the baseline 

inspection. At the time, EPA concluded that EDF-6685 showed that 72% of the identified fuel 

pins contain both plutonium and uranium (Pu and U), with 28% containing only 235U. Because 

the M-4 Cell wastes are associated with the same processes and activities and are a part of the 

same fuel pin population, this conclusion should not be modified by inclusion of the M-4 Cell 
13 

drums in the ID-ANLE-S5000 waste stream, although drum-specific characterization will verify 

this assumption. Based on this information, the radionuclide 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 were 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 packaging activities, general information was kept 

pertaining to drum contents and general configuration of the waste. Quick Scan RTR was 

performed by INL-CCP on the drums, because the original 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 holder, glass flasks (roundbottom and Erlenmeyer), ground glass stoppers; small amounts of liquid in the bottom of 

bottles and flasks. 

• Drums 393, 394, 399, 400: Metal pipe nipples (4” diameter) containing plastic bottles 

(750-1000 ml.) containing immobilized material or “dense solidified material;” one bottle 

contains liquid (100-200 ml); absorbent or other homogenous material visible at the 

bottom of the can between the lead sheeting and inside; metal caps (dishes) placed on top 

of lead liner. 

• Drums 01002-01005: Metal paint cans (with lids), plastic bottles, metal 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 plastic, 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; documentation also suggested the presence of floor 

sweepings, plastic bags, glass bottles (beakers) containing metal rings, (cladding?), 

plastic disc with screws. 

These data suggest that the three drum-generation periods may have different physical 

compositions. To explore this observation, INL-CCP representatives were interviewed and 

current VET data were examined. INL-CCP representatives 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 samples for burn-up and fission gas analysis of 

Big Rock Point Reactor specimens. The resultant waste required shielding in the containers and 

the presence of solidified material in internal containers. Later waste (1981) resulted from 

general clean-out of the M-4 cell. 

INL-CCP representatives have not yet examined whether 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 AKSR, EPA expects to be notified under the T2 
14 

change notification, as required in the baseline approval. EPA notes that while slight revisions to 

weight percentages and other values in Table 6 of the 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 that the physical form of the waste fits into 

the general waste descriptions of Waste Stream ID-ANLE-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 AKSR to add the twelve drums to the waste 

stream. Much of the characterization data associated with these drums had yet to be examined 

by the INL-CCP Acceptable Knowledge Expert (AKE) (most notably the VET data), so it is 

possible that the AKSR will be revised to incorporate 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 Cell waste. 

The AKSR states that the EBR-II reactor supported ongoing defense-related activities under 

various projects. M-4 Cell wastes contain radionuclides that originated in EBR-II. Therefore, 

the AKSR concludes “...the receipt, transfer, and storage 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 conducted 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-defense waste from defense-related waste is 

not feasible”. While a formal evaluation of the waste’s defense determination is not within 

EPA’s purview, EPA did determine that the discussion provided supports the defense status of 

the M-4 Cell wastes. 

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

addition of M-4 Cell references was evaluated and was found to be adequate. 

INL-CCP prepared an AK Source Document Reference List using unique identifiers for the 

different document types, a format typically used for documents supporting CH waste. The 

listing is based on CCP-TP-005 Revision 18, Attachment 4 and was found to be relatively 

complete and was easy to understand. This is a living document and does not always contain 

every reference that is cited in other AK-related documents (e.g., CCP-AK-INL-501). As shown 

in the bulleted list in Attachment B, INL-CCP provided 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 provided references and obtain the same 
15 

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

stream4

. 

(7) Modifications of the WSPF and related CRR were assessed and were found to be 

adequate. 

INL-CCP representatives indicated that neither a revision to the WSPF nor the CRR had been 

prepared. EPA’s baseline approval requires notification when changes to the WSPF and CRR 

are made. EPA expects to be notified if and when changes are made to these documents that 

relate to the M-4 Cell waste. 

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

The Certification Plan/CTP (CCP-AK-INL-502, Revision 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 adequate. 

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 as CH upon application of the DTC 

procedure. Should this occur and the assay data for the containers are available and are used for 

characterization, EPA’s prior approval of INL-CCP describes 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 with improper paperwork associated 

with drum packaging. There were no NCRs associated with the presence of prohibited items, 

inappropriate Summary Category Group (SCG), or other characterization-related elements 

included in the information provided to EPA. Additionally, 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 the 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 for these containers. The remaining 

containers will be quick scanned by RTR and additional information will be collected from 

ANL-E to characterize these containers.” The conclusion to exclude the twelve M-4 Cell 

“unknown” containers presented in the DR has been addressed by activities performed by INLCCP since the DR was generated in 2007. 

 

4

EPA’s review and evaluation process would be facilitated if INL-CCP specifically identified the references 

which are most pertinent to the Tiering request among those provided. It must be pointed out that EPA only 

examines the documentation specific to the technical element in the AKSR that identifies a reference as relevant to 

be selected for examination.
16 

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

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 included 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 report. 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 typographical 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 management is not intended for Waste Stream No. 

ID-ANLE-S5000. EPA’s baseline inspection report indicated that the implementation of load 

management is a T1 change requiring EPA prior approval. 

(13) The presence of Spent Nuclear Fuel (SNF) and High Level Waste (HLW) as a result of 

addition of M-4 Cell waste was examined. 

CCP-AK-INL-500, Revision 7 presents a statement that is consistent with language in other CCP 

AKSRs with respect to SNF and HLW, and INL-CCP personnel stated this applied to the M-4 

Cell wastes. The statement is excerpted below: 

The WIPP LWA (Reference 6) prohibits the disposal of 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 elements of which have not been 

separated by reprocessing.” DOE M 435.1-1, Radioactive Waste Management 

Manual (Reference 22), expands on this definition to clarify that “Test specimens 

of fissionable material irradiated for research and development only, and not 

production of power or plutonium, may be classified as waste, and managed in 

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

cost prohibitive, or would increase worker exposure to separate the remaining 

test specimens from other contaminated material.” High-level waste is defined by 

the NWPA as “the highly radioactive material resulting from the reprocessing of 

spent nuclear fuel, including liquid waste produced directly in reprocessing and 

any solid material derived from such liquid waste that contains fission products in 

sufficient concentrations, and other highly radioactive material that the 

Commission, consistent with existing law, determines by rule requires permanent 

isolation.” 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 elements 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 from 
17 

a reactor. Therefore, the waste is not a spent nuclear fuel or high-level waste and 

is eligible for disposal at WIPP as RH TRU waste. 

EPA accepts the INL-CCP statement as adequately addressing 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 findings or concerns relative to the inclusion of 

the twelve containers of M-4 Cell wastes to Waste Stream No. ID-ANLE-S5000 during this T1 

evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there are 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 debris wastes that were generated at ANL-E 

in the AGHFC during the examination of irradiated and un-irradiated fuel pins from various 

reactor programs at ANL-W and other DOE and commercial reactors that were transferred to 

INL between 1976 and 1995. The fuel examinations consisted 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 characterization protocol that was suited for 

characterizing the population of all RH TRU waste containers within this waste stream. EPA 

evaluated and approved this approach during the baseline inspection, and it applied to Lots 1 

through 20 from Waste Stream ID-ANLE-S5000. This conceptual approach is the equivalent of 

what EPA has evaluated and approved via a baseline inspection at CCP TRU generator sites 

previously5

. The twelve 55-gallon containers that were the subject of this T1 evaluation differed 

from the other containers in this waste stream in that a combination of RTR and VE revealed that 

nine of the drums had internal lead shielding. These 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 137Cs correlation for these nine containers. The additional three 

containers without internal shielding required additional 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 of these sites used the approach of DTC with radionuclidespecific scaling factors and the baseline inspection reports that document them provide considerable details 

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 represents the process with one exception—the 

presence of internal lead shielding in nine of these twelve 55-gallon containers that were the 

subject of this T1 evaluation required a separate 137Cs correlation expressed in units of 

R/hr/Curie 137Cs, which was developed using Microshield®. For the remaining three containers 

without shielding, a 137Cs correlation was modeled for 30-gallon and 55-gallon configurations 

using MCNP56

. 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 characterization 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 radiological characterization program: 

• Development of a DTC correlation as a function of waste density using MCNP5 in a 

30-gallon and 55-gallon geometry based on each container’s measured dose rate, 

assuming the main contributor to the external exposure was 137Cs 

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

radionuclides, as supported by calculation packages that documented the use of 

ORIGEN2.2 runs for 506 equivalent fuel pins; the scaling factors represented the average 

composition of the RH TRU wastes 

Documents Reviewed

The list provided in Attachment B includes all documents related to the INL-CCP RH TRU 

radiological characterization program that were examined to support this T1 evaluation. 

Technical Evaluation

The EPA inspection team evaluated the technical adequacy and documentation of the correlation 

of the radionuclide inventory values to the 137Cs concentrations in INL-CCP RH wastes and the 

technical development and documentation of radionuclide scaling factors. Specifically, the EPA 

inspection team evaluated the following aspects: 

 

6

 MCNP5 is Monte Carlo N-Particle Transport Code RSICC Computer Code Collection, Oak Ridge National 

Laboratory. 
19 

(1) The technical adequacy and documentation of radionuclide 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-S5000: 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 

• Correlation of isotopic activity values to the radionuclides whose physical half-lives are 

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

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

• Appropriate decay correction according to INL-CCP procedure (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 scaling factors and convert the measured 

external dose rates obtained via DTC to radionuclide activity levels 

• Activity and uncertainty values determined for the ten WIPP-tracked radionuclides (233U,

234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs and 90Sr) 

• The determination of the contribution of all radionuclides to the radiological hazard7

• Shielding and other calculations supporting the scaling factors performed using MCNP5

to derive the appropriate DTC relationships as a function of waste density for the 

geometry appropriate to the waste following repackaging (55-gallon drum) 

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

factors for the twelve containers of INL RH Waste Stream 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 137Cs DTC correlation as a function of waste density for 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 derivation 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 Drums. 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 aspects of a container’s radiological characterization. 
20 

waste cans in the 30-gallon drums and a figure of 78% was chosen, as described in CCP-AKINL-501. For actual waste drums, the fill-height percentages will be provided by RTR. 

The DTC correlation for the nine containers with internal 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 is relatively homogeneous with a 

specific gravity of 1.2 g/cm3

• 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 internal 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, depending 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 radiological 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 document 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 that had been prepared and reviewed initially by 

Jene Vance, Jim Holderness, and Dave Moody to support the initial INL-CCP RH baseline, and 

many of them had been revised to incorporate the twelve drums, as listed above. These packages 

documented a variety of technical aspects, including the following: 

• Application and verification of Microshield®

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

• Decay correction to an assumed reference date 

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

• Potential sources of uncertainty 

• Information input checks 

• Technical development of scaling factors 

• Technical derivation of the DTC approach and documentation 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 aspects related to these twelve containers. As a 

result of reviewing the calculation packages and the conference call, EPA had a question 

regarding the lack of documentation for the contribution of variations in density to Total 

Measurement Uncertainty (TMU). INL-CCP realized that additional details would be necessary 
21 

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 other calculation packages that required 

revisions based on a minor discrepancy with respect to 241Pu, and these were submitted to and 

reviewed by EPA and all were acceptable. Specifically, 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 discussed all technical concerns and 

apparent discrepancies with INL-CCP personnel and questioned 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-ORNL-501 adequately documented the 

radiological characterization process for these wastes, 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 were no issues related to the 

documentation of technical aspects of the INL-CCP radiological characterization approach for 

the addition of twelve containers to Waste Stream ID-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 assumed to be independent, which allows 

them to be added in quadrature. The TMU determination included contributions of the 

following: 

• Drum weight measurement for the 3 drums without internal lead shielding (not applicable 

to the nine drums with internal shielding) 

• Measurement uncertainty attributed to dose rate determination 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: differences in fuel pin compositions; 

individual fuel in contribution due to machining (cuts); 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 calculation 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 internally shielded container, and there were 
22 

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 were found to be adequate. 

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

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

DTC measurement at the INTEC Facility at INL, consistent with what EPA had observed during 

the baseline inspection. These were not assessed directly during this T1 evaluation, but EPA did 

verify that no aspects of these two determinations had changed. The results for all twelve 

containers that were reviewed as part of this T1 evaluation 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 radionuclides. 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 findings or concerns relative to the radiological 

characterization of the twelve containers of M-4 Cell wastes to Waste Stream No. ID-ANLES5000 during this T1 evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the T1 and T2 designations 

assigned to radiological characterization during the 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 facility at INL. The wastes themselves consist 

of bags, blotter paper, bottles, containers, equipment/tools, hardware, hoses, etc. These materials 

were generated from: hot cell operations at Building 785, HFEF; fuel fabrication and 

reprocessing at Building 765, Fuel Conditioning Facility (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 T1 evaluation. INL-CCP expects that upon 

repackaging, these materials will generate approximately 170 55-gallon drums for a total waste 

volume of approximately 35 m3

. Much of the documentation prepared by INL-CCP for 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 containers 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 information to determine whether INL-CCP 

demonstrated compliance with 40 CFR 194.8 requirements for RH Waste Stream 

ID-HFEF-S5400-RH. 

Waste Characterization Element Description 

As part of the inspection, EPA reviewed the following 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 presence 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 implementation 

• AK data traceability 

• AK source document sufficiency 

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

preparation/adequacy and use of LANL mass spectrometry data 

• CRR adequacy 

• CSSF and CH-RH correlation 

• Personnel training 

• WSPF adequacy and compliance with WCPIP requirements 

• 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 forms, 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 BDRs 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 Waste 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 activities 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 Experimental 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 HFEF-North); Building 765, FCF (formerly 

HFEF-South); and Building 752, the L&O Building Analytical Laboratory. The waste is 

currently stored at INTEC and the Materials and Fuel 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 exception 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 use of the information available (such as 

availability of confirmation sample results).” Specifically, 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 spectrometry data associated with LANL fuel pins. 

This approach is the same as that which EPA evaluated 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 successful 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 physical, chemical, and radiological properties.” The 

waste stream examined, ID-HFEF-S5400-RH, is a debris 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 approval is in A-98-49; II-A4-88. 
25 

primary locations at INL: INL MFC Building 785, HFEF (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 whether 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 justification to be lacking, and this issue was 

discussed with INL-CCP AK personnel. EPA issued EPA Evaluation Issue Concern Form No. 

INL-RH-AK-09-002CR, which is included as Attachment D to this report. This concern has four 

parts, one of which is discussed below. Note that the numbering of the concern items reflects the 

order in which these issues were addressed during the 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 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 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 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 Month XX, 2010 as a freeze file, hereafter referred to as the AKSR Markup. The 

following was included in the AKSR Markup in response to this concern. Note that information 

presented to support Items 2, 3, and 4 of this concern 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 and the WCPIP 

waste stream definitions of “waste materials generated from a single process or 

from an activity that are similar in material, physical form, and radiological 

constituents.” The container specific records have been reviewed for each 

container to verify the composition and origin of the waste stream inventory. 

Every container in waste stream ID-HFEF-S5400-RH was generated from HFEF 

and FCF operations (References U483, U484, U541, U552). Waste generating 

operations in the HFEF and FCF are the same or similar 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 materials in approximately the 

same relative percentages. Most of the HFEF-5 cans were generated in HFEF 

because FCF facilities were refurbished from the mid 1970s to early 1980s. The 

majority of materials examined (approximately 90 percent) 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-fissium9 (UFs), and approximately 7 percent was depleted uranium (DU). Approximately 10 

percent of the materials examined consisted of materials irradiated in other 

reactors, of which approximately 41 percent was light water reactor (LWR) or 

LWBR, approximately 29 percent was RERTR, approximately 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 (References C465, C503, P263, 

U483, U484, U541, U551, U552). Samples transferred to the Analytical 

Laboratory were prepared in the HFEF or FCF. High activity waste from the 

Analytical Laboratory generated from analysis of these samples was transferred 

back to the HFEF or FCF for disposal (References C214, U483, U484, U541, 

U552). These wastes were packaged in individual HFEF-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 waste stream, based on 

radiological contamination, is not possible. The waste stream also contains 

waste materials generated during maintenance and waste management activities 

that could contain any radiological materials contaminating the cell surfaces and 

equipment. In addition, the waste will be repackaged 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, P182, 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 included 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 waste streams to have similar reporting 

requirements. 

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

adequate following the successful resolution of an EPA concern 

The AKSR includes only a generalized table that appears to summarize radiological data for the 

86 cans, and shows that a wide range of radionuclides may be present from both a weight and 

activity perspective. INL-CCP states: “Based on generator 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 “radionuclide weight percent of individual 

radionuclides varies greatly on a container-by-container basis. Because of this variability, some 

containers will not include the waste stream predominant 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 products in reactor fuel that improves the stability of uranium and 

uranium-plutonium fuel alloys under fast neutron irradiation. 
27 

However, CCP-AK-INL-581, Revision 0 appears to include additional AK information that has 

been evaluated in-depth to obtain a more detailed depiction 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 waste 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 tables 

• 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 records 

• 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 combined with fuel pin data, modeling, and 

other activities to develop scaling factors that included the 10 EPA WIPP-tracked radionuclides. 

Examination of the AKSR, AK source documents, and CCP-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 supported 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 report. 

This concern has four parts and the part that is relevant 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 historical information or data pertaining to the 

WIPP-tracked radionuclides, including the anticipated isotopic distributions by general programs 

(or other suitable designation) in support of the waste 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) describing the fuel elements, their fuel types, 

isotopic distributions and other pertinent information, including many 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 (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 were examined, including the presence of 

prohibited items (liquids) and were found to be adequately 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, sponges, 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, gloves, hoses, pads, slave 

manipulator boots, and tubing; rubber debris materials may be composed of neoprene 

• Glass items, including beakers, broken glass, ceramics, fiberglass insulation, filter media 

(e.g., fiberglass), glass wool, labware, lenses, light bulbs, magnifying glass, mirrors, and 

sample vials 

• Metal (ferrous) items, including caps, cladding pieces, containers (e.g., beakers, cans, 

tubes, and vials), equipment/tools, fuel pin cuttings/filings and samples, hardware (e.g., 

bolts, brackets), manipulator parts, piping, plates, scrap, subassembly hardware, tubing, 

and wire 

• Metal (nonferrous) items, including cladding pieces, containers (e.g., cans, liners, tubes, 

and vials), equipment/tools (e.g., balance, fittings, 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 homogeneous solids,” as well as small quantities of 

absorbent, sweepings, and epoxy resins. It also states, “However, any payload container 

consisting of more than 50% by volume of homogeneous solids will be excluded from this waste 

stream.” The AKSR included a tabulation of waste material 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 waste stream by weight (54%). 

The presence of prohibited items (liquids) was evaluated. 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 separation 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, “absorbed liquids are present and residual liquids due 

to dewatering or incomplete absorption are possible.” 
29 

EPA examined this information and associated references 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 North cell wastes were distinct and not physically 

commingled, laboratory waste was transferred through a pneumatic transfer system to either of 

the laboratories. However, the waste commingling was not clearly defined in the AKSR. 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 report. 

This concern has four parts, and the part that is relevant 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 AKSR Markup that provided 

more detailed descriptions of the RH TRU waste management practices, including specifics 

regarding the sizes of internal waste containers and the collection, transfer and staging practices 

for materials within the facilities of interest (Section 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-CCP RH tiering table (Tables 1 and 9) has 

been modified to reflect the need for all waste streams to have similar reporting requirements. 

(4) The identification of HLW, TRU versus LLW, and SNF was examined and was found to 

be adequate. 

INL-CCP stated the following with respect to the occurrence of SNF and HLW in Waste Stream 

ID-HFEF-S5400-RH: “The WIPP LWA...prohibits the disposal of spent nuclear fuel and highlevel waste as defined by the NWPA...[and DOE clarifies 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 DOE Order M 

435.1-1] when it is technically infeasible, cost prohibitive, or would increase worker exposure to 

separate the remaining test specimens from other contaminated 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 physical or chemical processing of these 

materials. INL-CCP concludes: 

 Waste Stream ID-HFEF-S5400-RH consists of heterogeneous debris [that]... 

inherently contains test residues, test materials, and the resultant test fragments 

from the fuel pin test specimens, including irradiated pin fragments and dispersed 

particulate (fines and dust). The analysis and examination of irradiated fuels did 

not involve reprocessing of constituent elements from reactor fuel. In addition, 

waste from fuel reprocessing and the analysis of reprocessed fuel performed in 

these facilities was not identified in this waste stream. Therefore, the waste is not 
30 

a spent nuclear fuel, not high-level waste, nor a waste historically managed as 

high-level waste, and is eligible for disposal at the 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 arguments and found them to be 

consistent with those presented in other approved RH 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 should 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 with respect to waste stream generation, 

commingling of radiological constituents, and radiological characterization was lacking [see 

Items (1) and (2) above, and Item (15), below]. However, INL-CCP subsequently addressed 

these concerns in the AKSR Markup and provided extensive 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 expects to be notified when the AKSR is 

updated to include the submitted modifications; this 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 traceability analysis: IDAWANL820118A and 

IDAWANL820118B; IDAWANL820066A and IDAWANL820066B; and IDAWANL810091A 

and IDAWANL810091B. INL-CCP indicated that these drums originated from three common 

original containers, referred to hereafter as container Nos. 118, 91, and 66. Using CCP-AK-INL581, Revision 0 and other references, the corresponding Liner ID Nos. and canister numbers can 

be derived as shown in Table 7 below. 

Table 7. Drum Traceability Information, Waste Stream 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 reference, and was used to identify the 

corresponding Liner ID Number and Canister/Can numbers presented in Table 1-1 of 
31 

CCP-AK-INL-581. These numbers were then used to identify references that contained original 

paperwork traced back to original waste cans that were subsequently emplaced in other 

containers/liners, renamed, and transported to storage areas. 

EPA used the above information, together with spreadsheets 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 indicated that paperwork is available from the 

final INL-CCP drum at the can/container level and is often traceable to individual fuel pins. This 

conclusion is echoed in INL-CCP-AK-581, which states: “The review of the AK source 

documents associated with ID-HFEF-S5400-RH identified the subassemblies and fuel elements 

associated with each HFEF canister liners.” EPA concluded 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 related 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 documents. Subsequent to the inspection and as a 

result of EPA’s concerns, INL-CCP increased the number of source documents used to generate 

the AKSR, updated Attachment 4 to include all pertinent references and provided an updated AK 

reference list. It was noted that the reference list associated with the AKSR did not include 

several of the relevant documents in Attachment 4 that were given to EPA as supporting 

documents for the waste stream during the T1 evaluation. 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 of the Certification Plan and CTP, was 

evaluated, including mandatory content of the CTP and the use of LANL mass 

spectrometry data for DTC AK Qualification, and were found to be adequate. 

EPA’s March 26, 2004, RH WCPIP letter indicated that sites must generate a Certification Plan 

that explains how RH waste characterization will take place at each site, as well as a CTP when 

this plan is required as part of the AK qualification process. EPA’s intent was that the sites 

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

followed by a detailed plan explaining implementation of confirmatory testing when this is to 

take place. 

INL-CCP-AK-582, Revision 0 states that INL-CCP would use a combination of methods to 

qualify AK based on isotopic ratios derived from Oak Ridge Isotope Generation (ORIGEN) 

modeling and confirmed by LANL measurement data. The same process has been used at other 

RH sites and EPA had previously examined and approved the use of the LANL mass 

spectrometry data used by INL-CCP to qualify the fuel 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 the ID-HFEF-S5400-RH waste stream. 

INL-CCP-AK-582 also states that the HFEF waste is similar to waste at the other RH 

sites and the ORIGEN model applies here as well. Because the AK is similar between 
32 

LANL and INL-HFEF, the requirement to qualify radiological parameters can be met 

using the LANL sampling results. To verify this assertion, 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 spectrometry data are representative of the Lot 1A 

cans, and that INL-CCP is therefore justified in using these results in waste 

characterization activities. CCP-AK-INL-581, Revision 0 states: 

 

Approximately 90 percent of the irradiated fuel pins included in the HFEF 

examination program were from the fast breeder program and, as such, had 

similar fuel types, common sponsors or experimenters, and an identical reactor 

(EBR-II) as did LANL... The remaining 10 percent of the fuel pins were irradiated 

in the various reactors, such as, Shippingport LWBR, Belgium Reactor 3 (BR-3), 

and FFTF and share common sponsors and experimenters as the LANL work... 

INL-CCP has proposed the use of mass spectrometry data obtained from LANL to verify the 

output of the ORIGEN2.2 for INL data. INL-CCP states 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 content, so the use of LANL data for this purpose 

is appropriate. INL-CCP revised the AKSR to include information detailing the 90% EBR II, 

10% other reactor breakdown (see Item 2, above). 

In the INL-CCP RH baseline determination, EPA accepted the approach that INL-CCP 

implemented regarding use and commonality of the LANL mass spectrometry data to verify the 

modeling results. EPA requested information from INL-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 clearly supported the INL-CCP’s positions; 

however, such information is not available. INL-CCP’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 input 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 reliable for INL. 

• There was a direct comparison of nine fuel pins that 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-CCP demonstrated applicability of the 

LANL mass spectroscopy data to the INL program by showing commonality of experiments, 

sponsors, and other data. Revision of CCP-AK-INL-581, Revision 0 is a T2 change. 
33 

EPA evaluated the CTP to determine whether it included the specific elements that the CTP must 

have as defined in the WCPIP and found the CTP to be complete in this regard. Revision to 

CCP-AK-582, Revision 0 is a T2 change. 

(9) Content and technical adequacy of the CRR were 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 Waste Acceptable 

Knowledge Characterization Reconciliation Report. Specifically, the CRR was evaluated to 

determine the completeness and adequacy of its contents as required in the WCPIP. 

INL-CCP representatives provided an Excel version of the CRR. This form included the 

necessary information, but did not include the signature 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 information 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 prepared for this stream. However, a CSSF 

was completed to support the correlation of LANL mass spectrometry data and INL-CCP data 

for subsequent use in AK qualification as part of the 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 use of a CSSF for this purpose is 

acceptable, noting that it should reference detailed reports, memoranda, or other supporting data 

sources, and should clearly state why the form is being 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 found 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. Apparently, the process has changed so that the 

Qualification Cards are not kept up to date; instead 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 Documents was sent to EPA via e-mail following 

this evaluation. It should be noted that the documentation 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 which 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 adequate. 

INL-CCP representatives provided a draft WSPF, without 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 need for all waste streams to have similar 

reporting requirements. 

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

INL-CCP provided a single DR associated with this waste stream that dealt with the assignment 

of hazardous waste numbers to a previously non-hazardous waste stream. INL-CCP 

representatives did not indicate that there were any 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 Attachment 2 and failure of the ITR to identify 

this deficiency during BDR review. The provided DRs 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 adequate. 

AK accuracy was assessed with respect to the required contents as presented in the WCPIP. The 

WCPIP requires AK accuracy be assessed in three areas: 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 which 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 placed 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 AK 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 need for all waste streams to have similar 

reporting requirements. 

(15) The discussion provided to resolve EPA concern below supports defense status of the 

waste. 

The AKSR discussed several defense-related activities, but did not adequately correlate these to 

activities that generated Waste Stream ID-HFEF-S5400-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 report. This concern has four 

parts, and the part that is relevant to this element 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 wastes generated from the HFEF, FCF, and 

Analytical Laboratory. 
35 

Resolution: INL-CCP provided an AKSR Markup that provided additional details in Section 

4.1.4, Defense Determination, regarding the correlation of specific process areas to wastes from 

HFEF, FCE, and the Analytical Laboratory. The revised 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 streams to have similar reporting requirements. 

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

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

stream. Implementation of load management is a T1 change. 

(17) Attainment of DQOs through AK qualification was evaluated 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 canister, including quantification and 

identification of the 10 EPA WIPP-tracked radionuclides) 

• 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 source 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 findings relative to the addition of the containers 

from Lot 1A of Waste Stream ID-HFEF-S54000-RH, which were the subject of this T1 change 

evaluation. One concern related to AK was identified and this is discussed above. All four 

aspects of this concern were adequately addressed subsequent 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 are no substantive changes to the T1 and T2 

designations that were assigned to AK for INL-CCP during 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 RH 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 total waste volume of approximately 35 m3

. 

Much of the documentation prepared by INL-CCP for 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 containers are specifically excluded from this 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. The radionuclide-specific scaling factors were 

developed based on information describing the attributes 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 fuel pins (81%) and resulted in a single set of 

scaling factors to be applied to the entire waste stream. 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 Cell RH waste were added to Waste Stream 

ID-ANLE-S5000 (see Section 4.2.1), the DTC measurement 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 methods 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 understanding of the personnel involved in the 

RH waste characterization program. 
37 

 

Documents Reviewed

The list provided in Attachment B includes all documents related to the INL-CCP RH TRU 

radiological characterization program that were examined to support this T1 evaluation. This 

listing is comprehensive and includes documents that supported AK, as well as the addition of 

twelve containers of M-4 Cell RH waste that were added to Waste Stream ID-ANLE-S5000, 

discussed in Section 4.1.2. 

Figure 1. 

Flow Diagram of the Characterization Process: ID-HFEF-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 function of 

waste density to develop a 137Cs and a 60Co DTC correlation 

based on a 1-Ci source of 137Cs and a 1-Ci source of 60Co 

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

for both 137Cs and 60Co 

Execute DTC to Determine Drum’s 137Cs Activity: 

Find mean gamma dose rate at 1 m from the surface of the drum 

based on four measurements; and determine the waste density 

based on the actual weight of drum contents and fill factor 

Using the correlation factors and the activity ratio of 60Co to 137Cs 

determine the combined DTC conversion factor 

Divide the mean measured dose rate by the DTC conversion factor 

and apply 60Co/137Cs ratio to find the 137Cs activity in Curies 

Multiply the 137Cs 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 137Cs 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 data
38 

Technical Evaluation

(1) The EPA inspection team evaluated the correlation of the waste records for the 83 

canister liners with the 137Cs and 60Co concentrations. 

The information that formed the basis of the radiological 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 the 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 137Cs and other radionuclides, and the 

derivation of scaling factors, i.e., the relationship of easily measurable 137Cs and 60Co to other 

radionuclides, as discussed below. These activities 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 suppliers and reactor operators 

•

235U enrichment 

•

240Pu 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 137Cs activity for a container allows the further calculation of the following 

quantities for each RH container measured: 

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

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

• Associated uncertainty for all values listed in previous bullet 

• Fissile Gram Equivalent (FGE) 

• Pu Equivalent Curies (PE Ci) 

• Decay heat in Watts 

The constants and other values required for these calculations 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 contribution of 60Co to the measured external 

dose rate. This was done by running twelve MCNP5 cases with the source term uniformly 

distributed throughout a waste container for a range of waste densities from 1.0E-4 to 2.0 g/cm3

for a 1-Curie source of both 60Co and 137Cs. The results of these were then used to derive a DTC 

correlation as a function of density for 137Cs and 60Co, as shown in CCP-AK-INL-581, Figures 
39 

6-2 and 6-3, respectively. The actual DTC calculations 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 steel) 

• Four external dose rate measurements 

There were no concerns regarding the correlation of waste records for the 83 canister liners with 

137Cs and 60Co 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 statistical metrics using the mean and 

standard deviation values for each radionuclide 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 

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

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

60Co for these HFEF RH TRU wastes 

• Adjustment of the source distribution inside the drums for 137Cs and 60Co using MCNP5 

calculated as a function of bulk waste density 

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

• Appropriate decay correction according to INL-CCP procedure (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 radionuclide-specific scaling factors and 

convert the measured external dose rates obtained via DTC to radionuclide activity levels 

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

(

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs, and 90Sr) 

• The determination of the contribution of all radionuclides to the radiological hazard10

 

10 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this

information may be useful in understanding other aspects of a container’s radiological characterization. 
40 

• Shielding and other calculations supporting the scaling factors performed using MCNP5

to derive the appropriate DTC relationships as a function of waste density for the 

appropriate geometry following repackaging (55-gallon drum) 

• Adjustment of scaling factors based on the benchmark 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-64: 

Table 8. Radionuclide-Specific Scaling Factors 

Radionuclide DTC Scaling Factor 

233U 6.83E-05 

234U 8.75E-05 

235U 8.70E-06 

238U 1.13 E-06 

238Pu 1.03E-02 

239Pu 2.72E-02 

240Pu 1.08E-02 

241Pu 2.05E-01 

242Pu 4.33E-06 

241Am 1.08E-02 

137Cs - 

137mBa 9.46E-01 

90Sr 8.45E-01 

There are no issues related to the technical adequacy 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 radionuclide scaling factors that were developed 

for these HFEF wastes contained in INL-RH-64, and Table 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 2 
41 

• Waste Container DTC Conversion Record(s), Attachment 3 

• Evidence of signatures by the ITR and a SPM 

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

• 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 radiological characterization process were 

evaluated and found to be acceptable following successful resolution of an EPA concern. 

CCP-AKINL-501 is the main document that describes the radiological characterization process 

that INL-CCP used for the HFEF wastes. This document is supported by a series of 18 

calculation packages, listed in Table 8-1, that were 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 evaluation 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 these discussions, the EPA evaluation team 

had the opportunity to discuss all technical concerns and apparent discrepancies with INL-CCP 

personnel and to raise a variety of technical and documentation-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 characterization 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 technical 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 aspects of this HFEF waste stream. 

Resolution: These changes were captured in a freeze-file that was provided to EPA on January 

5, 2010 and the revised document adequately addressed 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 process for the HFEF wastes, and the calculation 

packages cited above adequately supported the activities upon which the radiological 

characterization of the HFEF wastes were based. There were no issues related to the 

documentation of technical aspects of the INL-CCP radiological characterization approach for 

the HFEF RH wastes. 
42 

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

evaluated and were found to be adequate. 

 

The development of TMU for Waste Stream ID-HFEF-S5400-RH is based on the propagation of 

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

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

quadrature. The TMU determination included contributions of the following: 

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

uncertainties 

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

• Scaling factor uncertainty – including ORIGEN2.2 uncertainty 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 stream 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 Idaho National Laboratory 

(INL) RH Radiological Characterization. The principal sources of uncertainty are the 137Cs dose 

rate determination and the relative contribution of each fuel pin to the total. There were no 

concerns regarding the technical derivation and documentation of TMU for INL-CCP Waste 

Stream ID-HFEF-S5400-RH. 

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

The determinations that these containers meet the definitions of TRU waste and RH waste were 

examined during the baseline inspection based on DTC BDR No. INLRHDTC09006. Both the 

RH and TRU determination are parts of the actual DTC measurements that are performed at the 

INTEC Facility at INL, which was not assessed directly during this T1 evaluation. EPA did 

verify that no aspects of the DTC process had changed significantly from what EPA had 

observed during the baseline inspection. The results for 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 more than 100 nano Curies per gram 

(nCi/g) of transuranic radionuclides. 

• All containers 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 the containers in Waste Stream ID-HFEF-S5400, Lot 1A. 
43 

Summary of Radiological Characterization

Findings or Concerns 

The EPA inspection team did not identify any findings related to radiological characterization. 

EPA identified one concern during this evaluation related to radiological characterization that is 

discussed above, and a copy of the EPA Inspection Issue 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 provided. 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 are 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 

Summary of Findings and Concerns

The EPA inspection team did not identify any findings related to AK or radiological 

characterization. EPA identified two concerns during the inspection, one related to radiological 

characterization and one related to AK, both of which 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 radiological characterization resulting from this T1 

evaluation. 

7.0 CONCLUSIONS 

EPA concluded that the waste characterization processes 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 waste characterization techniques of AK and 

radiological characterization as applied to two separate 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 casks 
44 

Based on the results of this evaluation, EPA approves these components of the T1 change. 

INL-CCP is approved to characterize these RH TRU wastes, consistent with the limitations 

specified in this report. At this time, EPA is not approving ID-INTEC-RH, and ID-HFEFS5400-RH, Lot 1B. 

Tiering Changes

Based on the results of this T1 evaluation, there are no substantive changes to the T1 

designations assigned to AK or radiological characterization 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 table has been modified to reflect the need for 

all waste streams to have similar reporting requirements. 
45 

 Table 9. Tiering of RH TRU WC Processes Implemented by INL-CCP (Revised January 28, 2010*)

RH WC Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH WC Process - T2 Changes 

Acceptable Knowledge (AK) Addition of containers to approved Waste Streams 

Any new waste streams not approved under this baseline

Substantive modification(s) that have the potential to affect the characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502 Load management for any RH waste stream 

Notification to EPA when AKSRs, Radiological 

Characterization Reports and Certification Confirmation Test Plans (e.g., CCP-INL-AK-500, CCPINL-AK-501, and CCP-INL-AK-502) updates are 

approved by CBFO 

Notification to EPA when changes to AK documentation as 

a result of WCPIP revisions have been made (e.g., CRR) 

Notification to EPA when a Correlation or Surrogate

Summary Form is completed for each of the RH containers in this waste stream identified as CH, based upon measured dose rates that present NDA results for assayed containers

Notification to EPA once waste stream data package for 

debris waste stream and any modifications to the WSPF, including the CRR and AK Summary, are completed 

Notification to EPA that the final Dose-to-Curie (DTC) 

determination is complete for RH containers numbers 728 through 737, as identified in AK Reference P030 AK accuracy reports (prepared annually, at a minimum) 

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

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501 Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedure 

Any new waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors

Notification to EPA upon completion of revisions of CCPAK-INL-501 or CCP-TP-504 that require CBFO approval

Visual 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 necessary None 

Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 or 

wastes from an S3000 or S4000 waste stream 

Notification to EPA upon completion of changes to RTR procedure(s) that require CBFO approval. Notification to EPA upon addition of a new RTR unit(s).

WIPP Waste Information System (WWIS) None Changes made to WWIS procedure(s) that require CBFO

approval 
46 

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

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

* Changes to the original tiering table from the 2007 baseline inspection appear in bold.
ATTACHMENT A 

APPROVAL SUMMARY FOR INL RH WASTE 

CHARACTERIZATION PROGRAM 
A-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 February 2007 A-98-49; II-A4-80 

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

Tier 1 Change – Approval of High Range Gamma Probe for DTC April 2008 A-98-49; II-A4-72 

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

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION
B-1 

Reference List for CCP-AK-INL-500 and CCP-AK-INL-501

• CCP-AK-INL-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Remote-Handled Transuranic Debris Waste from Argonne National 

Laboratory-East Stored at the Idaho National Laboratory, Waste Stream ID-ANLES5000, Revision 7, June 17, 2009 

• CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report For Remote-Handled Transuranic Debris 

Waste From Idaho National Laboratory, Revision 4, Larry Porter, October 20, 2009 

• CCP-AK-INL-502, Central Characterization Project RH TRU Waste Certification Plan 

for 40 CFR Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: 

ID-ANLE-S5000, Revision 3, Larry Porter, October 7, 2009 

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

Implementation Plan, Revision 0D, October 30, 2003 

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

Knowledge Accuracy Report: Idaho National Laboratory, 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, 2009 

• CCP-TP-005 Attachment 4, Acceptable Knowledge Source Document Reference List, 

November 16, 2009 

• CCP-TP-005 Attachment 1, Acceptable Knowledge Documentation 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 (EXXON); Management Summary and 

Milestone Report for October 1978, C.E. Johnson, November 30, 1978 

• C359, Inter-Laboratory Memo to A.J. Goldman; Feasibility of Operating K-2 Facility in 

D200, L.A. Neimark, April 3, 1978 

• C379, Intra-Laboratory Memo; Addendum to Criticality 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, 2007 
B-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 (EXXON); Management Summary 

and Milestone Report for July 1978, C.E. Johnson, August 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 (EXXON); Management Summary 

and Milestone Report for June 1978, C.E. Johnson, July 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 (EXXON); Management Summary 

and Milestone Report for April 1978, C.E. Johnson, June 16, 1978 

• C1008, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); 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); Management Summary and Milestone 

Report for February 1979, C.E. Johnson, March 13, 1979 

• C1011, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); Management Summary 

and Milestone Report for December 1978, C.E. Johnson, 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 (EXXON); Management Summary 

and Milestone Report for November 1978, C.E. Johnson, December 18, 1978 

• C1014, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); Management Summary 

and Milestone Report for September 1978, C.E. Johnson, October 18, 1978 

• C1015, Letter to C.E. Johnson; Progress Report on EXXON-EPRI Program RP 306, L.A. 

Neimark, October 6, 1978 

• C1016, Letter to N. Dudey (EXXON); Gamma Scan Results for J-2 Rods, L.A. Neimark, 

August 13, 1978 

• C1017, Letter to C.E. Johnson; Monthly Report for June on EXXON/EPRI Program RP 

306, L.A. Neimark, July 13, 1978 

• C1018, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); Management Summary 

and Milestone Report for August 1978, C.E. Johnson, October 18, 1978 

• C1019, Letter to C.E. Johnson; Monthly Report for March on EXXON/EPRI Program 

RP306, L.A. Neimark, April 11, 1978 
B-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 Examination Facility in Cell M-4 of 

MA-Wing in Building 200, Argonne National Laboratory, J. Beitz, March 9, 2007 

• C1023, Intra-Laboratory Memo to D.S. Butler, Location 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 (EXXON); Management Summary 

and Milestone Report for April 1978, C.E. Johnson, May 17, 1978 

• C1025, Letter to C.E. Johnson; Monthly Report for April on EXXON/EPRI Program 

RP306, L.A. Neimark, May 10, 1978 

• C1026, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); Management Summary 

and Milestone Report for March 1978, C.E. Johnson, April 17, 1978 

• C1027, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); Management Summary 

and Milestone Report for February 1978, C.E. Johnson, March 16, 1978 

• C1028, Letter to C.E. Johnson; Monthly Report for February on EXXON/EPRI Program 

RP306, L.A. Neimark, March 7, 1978 

• C1029, Letter from C.E. Johnson; Guidelines for Monthly EPRI/EXXON Report, C.E. 

Johnson, March 20, 1978 

• C1030, Letter to N.D. Dudey and C.E. Crouthamel (EXXON); Management Summary 

and Milestone Report for January 1979, C.E. Johnson, February 14, 1979 

• C1031, Summary of AK Research for 12 Drums Generated in the Building 200 M Wing 

to be Included in Waste Stream ID-ANLE-S5000, K. Peters, Undated (provided 

December 7, 2009) 

• P614, Identification of Additional Fuel Elements/Materials 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 Consolidation Records, EDF-6685, P. Kuan, 

May 19, 2006 

• P622, Addendum to Criticality Hazards Control Statement (Revision 7) Alpha-Gamma 

Hot Cell Facility (Special Facility FF-1), Bldg. 200 File H121A, W.D. Jackson, April 28, 

1975 

• P1001, From Test Tube to Pilot Plant; A 50 Year History 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 Project Manager, May 2002 
B-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 Fuel Performance at the Big Rock 

Point Reactor, Post-Irradiation History: Fuel and Fission Product Behavior, Research 

Project 306, C.E. Johnson, R.R. Heinrich, L.A. Neimark, J.E. Sanecki, November 1987 

• P1005, Characterization of Low Burnup Rods (J-1) From Big Rock Point Reactor, Final 

Report, Research Project 306, C.E. Johnson, R.R. Heinrich, L.A. Neimark, J.E. Sanecki, 

June 1980 

• P1006, Analytical Shearing of Fuel Rods in a Hot Cell, 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 Project, 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. Beitz, December 13, 2008 

• P1010, Progress in Nuclear Energy, Analytical Chemistry, A Large-Scale Facility for 

Chemical Research with Intensely Radioactive Materials, D.C. Stewart, 1963 

• P1011, Verification Survey of Building 200 Hot Cells, ANL/ESH-HP-96/02, C.M. 

Sholeen, March, 1996 

• P1012, Characterization of Irradiated Zircaloys: Susceptibility 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 Zircaloys, ANL, April 1978 

• P1014, Characterization of Irradiated Zircaloys: Susceptibility 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 - Semiannual 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 Worksheets and Videos, Various 

authors, Undated 

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

Various authors, 1964-1997 

• U1004, Miscellaneous Packaging and Shipping Documentation for Containers 393, 394, 

395, 396, 397, 398, 399, 400, 1002, 1003, 1004, 1005, Various authors, Undated 

• U1005, Health Physics Monthly Reports for Activities in Building 200, ANL Heath 

Physics Department, 1975-1980 
B-5 

• U1006, SPM 24 Logbook for the 200 Area 9/23/74 through 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 Correlation for 55-Gal Drum with 

Liners, INLRH-20, Revision 0, J. Vance, January 12, 2009 

• U010, INL RH TRU Radiological Characterization Source Document Reference 

Information (author(s), document and revision number, date, publisher): INLRH-90, 

Revision 0, J. Vance, A 

Reference List for CCP-AK-INL-580 and CCP-AK-INL-581

• CCP-AK-INL-580, Central Characterization Project Acceptable 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 Acceptable 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 - Freeze file Month XX, 2010 

• CCP-AK-INL-581, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report For Remote-Handled Transuranic Debris 

from the Hot Fuel Examination Facility (HFEF) at the 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 Test Plan for INL RH Waste Stream: 

ID-HFEF-S5400-RH, Revision 0, August 13, 2009 

• CCP-TP-005, Site(s): Idaho National Laboratory, Waste Stream Number: ID-HFEFS5400-RH Waste Stream Description: HFEF Remote-Handled TRU Debris, Revision 18, 

November 16, 2009 

• CCP-TP-005, Attachment 1, Acceptable Knowledge Documentation 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 Source Document Reference List, 

November 12, 2009 

• CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items 

and Packaging, Remote Handled TRU Debris CCP AK INL 580, and related Waste 

Material Parameter Memo, Revision 18, November 12, 2009 

• CCP-TP-005, Attachment 8, Waste Containers List and Add Containers Memo and 

Spreadsheet, Revision 18, provided December 9, 2009
B-6 

• CCP Waste Stream Characterization Checklist, Waste Stream ID-HFEF-S5400-RH, 

provided December 9, 2009 

• Characterization Reconciliation Report (excel spreadsheet version) provided December 9, 

2009 

• HFEF Canister and Shipment Data Spreadsheet, provided December 9, 2009 

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

• Interoffice Correspondence from C.M. Gomez to M. Sensibaugh re: Acceptable 

Knowledge Accuracy Report Materials and Fuels Complex Hot Fuel Examination 

Facility at the Idaho National Laboratory Waste Stream Number ID-HFEF-S5400-RH, 

Lot 1, October 12, 2009 

• NCR-RHINL-0510-09, Packaging Configuration Issues, November 10, 2009 

• Program Implementation Plan Draft Waste Stream Profile form for ID-HFEF-S5400-RH, 

Undated; Provided December 9, 2009 

• Training Qualification Cards and Email Reading Lists, 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 Laboratory, 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, Scott Smith, August 31, 2005 

• C004, Interview of Steve Hayes, Materials and Fuel Complex Project Manager, 

Advanced Fuel Cycle Initiative, re: Advanced Fuel Cycle 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: MFC Analytical and Casting 

Laboratories Waste Management and Waste Characterization, 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 Distribution, re: Receipt of ContactHandled (CH) and Remote-Handled (RH) Transuranic (TRU) 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 Subassemblies, W.N. Beck, May 17, 1984 
B-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 14, 1984 

• C037, Argonne National Laboratory Intra-Laboratory Memo to J.L. Welker, re: Xenon 

Tag Gas for X419, X420, and X421, R.G. Pahl, September 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. Wright, 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 included 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 Support 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 Subassembly 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 Memo 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. Hemsley, May 18, 1987 

• C081, Letter to Bob Pahl, re: Density of Cladding on 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 X421, B.G. Carlson, July 8, 1987 

• C083, Letter to Bob Pahl, re: Sodium Logging Analysis on X421, T108, R. Villarreal, 

October 1, 1987 
B-8 

• C084, Letter to Bob Pahl, re: Burnup Measurements on 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 Analysis on X421, T108, R. Villarreal, 

Undated 

• C089, Letter to Idaho Division Chemical Group Personnel, 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 Internal 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 Immersion 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 Analysis – 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. Welker, 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 Results 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, Operational 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, November 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, 1985 
B-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, September 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 Analysis 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 Examinations 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 Isotopic 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, September 19, 1987 
B-10 

• C180, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: 

Characterization of X421 Element T225 by Scanning Electron Microscopy, R.G. Pahl, 

December 15, 1987 

• C185, Letter to T.A. Carlson, re: Plenum Gas Analyses – 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 Stream ID-HFEF-S5400-RH, Jim Schoen, 

April 20, 2009 

• C464, HFEF Repackaging Operations Email, Tom Clements, March 3, 2009 

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

• C466, E-mail from Bud Lowman to Scott Smith, re: HFEF 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, Kodak 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 Stream 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-666, Gerald Streier, July 28, 2009 

• DR003, Waste Stream ID-HFEF-S5400-RH, Historical and Current RCRA 

Characterization and Assignment of EPA Hazardous Waste Numbers, Undated 

• P001, The Defense Programs Origin of Transuranic Waste at Argonne National 

Laboratory - West, ANL-NT-192, H. F. McFarlane, November, 2001 

• P004, Casting Laboratory Operating Procedure, Fabrication and Characterization of Pu, 

Np, and Am-Bearing Metallic Alloy Specimens, W0650-0070-OP, Revision 0, Argonne 

National Laboratory-West, August 2, 2005 
B-11 

• P006, Packet of Material Safety Data Sheets, Various dates 

• P008, Nuclear Technology Division, Analytical Laboratory 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 Characterization Operating Procedure: 

Glovebox Glove, Bagout Sleeve and Gloveport Blank Replacement, W0650-0030-OP, 

Revision 2, J. Stuart and D. Peay, May 5, 2005 

• P011, Nuclear Technology Division, Casting Laboratory Experimental Plan and Hazard 

Analysis: Accelerator Transmutation of Waste Project 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 Laboratory Experimental Plan and Hazard 

Analysis: Accelerator Transmutation of Waste Project Arc-Melting Activities, 

W0650-0049-EP, Revision 0, R.J. Kennedy and D.D. Standfield, June 8, 2001 

• P013, Nuclear Technology Division, Analytical Laboratory 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 Characterization Department Casting 

Laboratory Operating Procedure: Fabrication and Characterization 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 Laboratory Procedure: Determination of 

Gallium in Plutonium Oxide by Inductively-Coupled-Plasma Mass Spectrometer, 

W0650-0064-KP, Revision 0, J. Giglio and D.D. Standfield, March 26, 2003 

• P018, Nuclear Technology Division, Analytical Laboratory Procedure: Quality 

Assurance Plan, W0660-0012-QP, Revision 10, D.D. Standfield, August 19, 2003 

• P019, Nuclear Technology Division, Analytical Laboratory 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 Laboratory Procedure: Dissolution of 

Plutonium Oxide Samples for Trace Metal Analysis, W0650-0063-KP, Revision 1, 

J. Berg and D.D. Peay, March 31, 2004 

• P021, Nuclear Technology Division, Analytical Laboratory Procedure: Determination of 

Boron in Plutonium Oxide by Inductively-Coupled-Plasma Atomic Emission 

Spectrometry, W0650-0065-KP, Revision 0, D. Cummings 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 17, 2001 

• P024, Analytical Laboratory Procedure: Sample Preparation for Analysis of Boron and 

Gallium in Plutonium Oxide, W0630-0128-KP, Argonne National Laboratory-West, 

March 26, 2003 
B-12 

• P025, Analytical Laboratory Operating Procedure: Glovebox Bagout Bag Replacement 

and Waste/Material Bagout, W0650-0008-OP, Revision 14, Idaho National Laboratory, 

July 19, 2005 

• P026, Analytical Laboratory Operating Procedure: Special Projects Glovebox Operations, 

W0650-0025-OP, Revision 3, Idaho National Laboratory, July 11, 2005 

• P027, Analytical Laboratory Operating Procedure: Waste Form Testing Glovebox, 

W0650-0016-OP, Revision 3, Idaho National Laboratory, August 12, 2005 

• P028, Analytical Laboratory Operating Procedure: Rusnok Milling Machine for Waste 

Form Testing Glovebox, W0650-0019-OP, Revision 2, Argonne National LaboratoryWest, September 1, 2005 

• P029, Nuclear Technology Division, Analytical Laboratory Operating Procedure: 

Standard Test Method for Determining Chemical Durability 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 Procedure: Uranium and Plutonium 

Separation from Electrorefiner Salt for Mass Spectrometer Analysis, W0630-0057-KP, 

Revision 2, J. F. Berg and D.D. Standfield, June 18, 1996 

• P031, Nuclear Technology Division, Analytical Laboratory 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 Laboratory) 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 Laboratory) Mixed Transuranic 

Waste, ANL142T, MFC, August 17, 2001 

• P047, Argonne National Laboratory Description and Proposed 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 1963 
B-13 

• P049, Estimated Radiological Inventory Sent from Argonne National Laboratory-West to 

the Subsurface Disposal Area from 1952 through 1993, INEEL/EXT-02-01385, 

Revision 0, Michael L. Carboneau, James A. Vail, April 2004 

• P051, A Survey of NRTS Waste Management Practices, Volume II, ICP-1042-II, Allied 

Chemical Corporation, Idaho Chemical Programs, Operations Office, National Reactor 

Testing Station, September 1971 

• P054, Informal Report, A Brief Analysis and Description of Transuranic Wastes in the 

Subsurface Disposal Area of the Radioactive Waste Management Complex at INEL, 

EGG-WTD-9438, Revision 1, D.A. Arrenholz, J.L. Knight, August 1991 

• P055, Argonne-West Criticality Hazards Control Statement, ID-CHCS-A11, Revision 7, 

W.P. Keeney, May 7, 1984 

• P060, ANL-West Remote-Handled Transuranic Waste Certification Plan, W0001-0898-

ES-00, Revision 0, R.J. Teunis, July 5, 1988 

• P063, ANL-West Remote-Handled Transuranic Waste Certification Plan, W0001-0898-

ES-01, Revision 1, Michael E. Vaughn, August 2, 1991 

• P066, Analytical Laboratory Glassware Cleaning Procedure, 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 Laboratory Waste Disposal, 

W0660-0035-OP, Revision 0, J.R. Krsul, August 19, 1991 

• 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 Laboratory Waste Disposal, 

AW-AL-WM-002, William R. Sovereign, June 1988 

• P076, Argonne West Analytical Laboratory Waste Reduction 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 Laboratory Materials Control and 

Accountability Section, Robert Villarreal, April 25, 1989 

• P083, Engineering Design File, Radiological Properties 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 Remote Handled (RH) Transuranic 

(TRU) Waste Stored at the Radioactive Waste Management Complex (RWMC), 

3460-94-084, H.D. Killian and S.K. McDermott, September 1994 
B-14 

• P085, Test Description for the Integral Fast Reactor 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 Procedures, Appendix C, Analytical 

Chemistry Laboratory, Revised 08/87, William R. Sovereign, August 26, 1987 

• P088, TRU-RH Waste Handling Plan for Waste Management Operations, 

AW-AL-WM-001, William R. Sovereign, March 30, 1988 

• P089, AK Summary Documentation AK TRU Packaging, RPT-456, DRAFT, Revision 0, 

Idaho Cleanup Project, October and November 2007 

• P091, INEL Transuranic Waste Acceptance Criteria, IDO-10074, Revision 1-4, Fuel 

Processing and Waste Operations Division, April 1980; February 1984; March 1986; 

July 1987 

• P092, Engineering Design File, ANL-W Radioactive Inserts 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 Distributions in Irradiated U-Pu-Zr Fuel, 

Charles E. Lahm, May 6, 1988 

• P100, Engineering Design File, CPP-1617 Fire Area Evaluation, EDF-4684, Nancy 

Makey, April 26, 2004 

• P101, Technical Procedure, CPP-1617 Waste Handling and Operations, TPR-7318, 

Radioactive Waste Management Complex at INTEC, February 1, 2007 

• P102, Estimated Radiological Inventory Sent from the 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. Vail, 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 Management 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 Plan for Cutting H.B. Robinson 

Rod Sections and Loading into Shipping Tubes; Various 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, IPS-375-01-00 (SIs 153, 182, 236, 

259, 279, 292, 315, 317, 320), IPS-335-00-00 (SIs 176, 221), R.V. Strain, Hanchung 

Tsai, Y. Yan, Darold Perry, Mitch Meyer, Various dates 

• P107, Mission Need Statement: RH TRU to WIPP Project, DOE/ID11114, Revision 0, 

INEEL, August 2004 

• P109, EPA Hazardous Waste Codes for Transuranic Storage Area (TSA) Item 

Description Codes (IDC), EDF-RWMC-421, Revisions 0-4, R.D. Falconer, April 1, 1994 
B-15 

• P110, Characterization of Wastes Generated at Argonne National Laboratory – West with 

IDCs of 161, 162, and 163, INEEL/INT-99-00081, Revision 0, C.B. Ransom, April 7, 

1999 

• P111, Matrix Parameter Category Groups (MPCGs), RWMC-805/INEL-95-029, 

Revisions 0-4, R.O. Falconer, February 26, 2002 

• P112, Chemical Constituents in Transuranic Waste Storage 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, 1995, July 10, 1996, August 12, 

1997, April 8, 1998 

• P113, Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, 

WM-F1-82-021, Thomas L. Clements, Jr., October 1982

• P115, Decontamination Cell Operations in CPP-659, TPR-7298, Revision 7 and 

Revision 11, Idaho Cleanup Project, June 4, 2008 and June 3, 2009 

• P116, Dissolution and Clarification of RERTR Silicide Fuels, DP-MS-82-98, George C. 

Rodrigues, Savannah River Laboratory, November 8, 1982 

• 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 Safety Analysis Report, Argonne 

National Laboratory-West, January 1982 

• P157, System Design Description (SDD), HFEF/N Neutron Radiography Facility 

(NRAD), W0170-0004-SA-03, W. E. Stephens, June 1, 1978 

• 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 Fuels 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 Debris, 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 ANL-E RH-TRU Waste, 

EDF-8860, Greg Hulet, August 18, 2008 
B-16 

• P221, Operation and Maintenance Manual: Metallographic Preparations, Containment 

Box, W0098-0049-SA-02, HFEF OMM 3114, Revision 2, Bart G. Carlson, May 26, 

1988 

• P222, Operation and Maintenance Manual: Cask Tunnel Transfer Penetrations; Facility 

Operations Division: Cask Tunnel Transfer Penetrations, W0147-0138-SA-03, HFEF 

OMM 3410, Revision 3; HFEF-MI-3410, Revision 0, Michael 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. Coomer, July 31, 1980 

• P225, Operation and Maintenance Manual: Vertical Assembler-Dismantler (VAD), 

W0064-0039-SA-04, HFEF/S OMM 4151, Revision 4, P.L. Coomer, January 29, 1985 

• P226, Operation and Maintenance Manual: Vertical Assembler-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, Revision 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 Subassembly Dismantling and 

Reassembly - North, W0015-0349-ES-00, HFEF/N OMM 4171, Revision 0, 

P.L. Coomer, November 11, 1982 

• P230, Operation and Maintenance Manual: Capsule/Element Transfer Station, 

W0024-0171-SA-02, HFEF/N OMM 4210, Revision 2, Fred L. DiLorenzo, August 13, 

1986 

• P231, Operation and Maintenance Manual: TREAT Neutron Radiography Equipment for 

Capsules and Elements - South, W0060-0337-SA-00, HFEF/S OMM 4311, Revision 0, 

M.E. Vaughn, December 13, 1977 

• P232, Operation and Maintenance Manual: TREAT Neutron Radiography Equipment for 

Elements - HFEF/N, W0169-0134-SA-00, HFEF/N OMM 4313, Revision 0, 

M.E. Vaughn, November 10, 1976 

• P233, Operation and Maintenance Manual: Contact Profilometer MK-II (Unit 2) - South, 

W0057-0071-SA-00, HFEF OMM 4322, Revision 0, T.C. Cameron, April 14, 1977 

• P234, Operation and Maintenance Manual: Bow and Length Measurement HFEF/N, 

W0171-0159-ES-00, HFEF/N OMM 4325, Revision 0, Thomas C. Cameron, April 11, 

1984 
B-17 

• P235, Operation and Maintenance Manual: Element Contact 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 (DRAFT), 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 Examination 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: Visual Examination Machine, 

W0053-0014-SA-03, HFEF OMM 4332, Revision 4, Fred L. DiLorenzo, August 13, 

1991 

• P240, Operation and Maintenance Manual: Precision Gamma 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 Balance 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-Current 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 Removal 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 January 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 31, 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: Metallographic Sample Sectioning 

Equipment, E0271-0004-SA-01, HFEF/N OMM 4710, Revision 1, Bart G. Carlson, 

May 24, 1984 

• P248, Operation and Maintenance Manual: Low Speed Diamond Saw, E0271-0005-SA00, HFEF/N OMM 4711, Revision 0, B.G. Carlson, April 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 Maintenance Manual: Remote 

Grinding and Polishing in the Containment Box; Operation and Maintenance Manual: 

Remote Grinding and Polishing in the Containment Box, 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 Cleaning in the Station 2M 

Containment Box, E0271-0008-SA, HFEF/N OMM 4741, Revision 0, R.D. Phipps, 

August 23, 1974 

• P252, Operation and Maintenance Manual: Element Radiography, W0170-0840-ES-01, 

HFEF/N OMM 5810, Review 1, Thomas C. Cameron, April 23, 1984 

• P253, Operation and Maintenance Manual: InterBuilding 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 Transport Cask (HFEF-6), 

W0087-0112-ES-02, HFEF OMM 6105, Revision 2, P.L. Coomer, January 22, 1988 

• P256, Operation and Maintenance Manual: Contact Handled 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 Shipping 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 Tubes 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. Stantliff, 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. Stantliff, 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. Stantliff, 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. Stantliff, September 19, 1988 

• P263, Operation and Maintenance Manual: In-Cell Solid Waste Handling, 

W0351-0005-SA-01, HFEF/S OMM 6620, Revision 1, S. Stantliff, August 31, 1988 

• P264, Operation and Maintenance Manual: In-Cell Remote Handled Solid Waste 

Handling - HFEF/N, W0201-0005-ES-02, HFEF/N OMM 6621, Revision 2, S. Stantliff, 

September 1, 1988 

• P265, Operation and Maintenance Manual: In-Cell Contact Handled Solid Waste 

Handling - HFEF/N, W0201-0006-ES-02, HFEF OMM 6622, Revision 2, S. Stantliff, 

August 10, 1988 
B-19 

• P266, Operation and Maintenance Manual: Remote Handled 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 Out-of-Cell Handling System, 

W0204-0012-SA-05, HFEF OMM 7110, Revision 5, G.M. Teske, April 11, 1984 

• P271, Operation and Maintenance Manual: Transporter System, W0204-0013-SA-02, 

HFEF OMM 7111, Revision 2, G.M. Teske, April 20, 1984 

• P272, Operation and Maintenance Manual: SLSF Loop Insertion System, 

W0003-0154-SA-06, HFEF OMM 7120, Revision 6, G.M. Teske, April 11, 1984 

• P273, Operation and Maintenance Manual: SLSF Loop Insertion Cell, 

W0003-0155-SA-03, HFEF OMM 7121, Revision 3, G.M. Teske, May 18, 1984 

• P274, Operation and Maintenance Manual: Loop Disassembly Systems, 

W0204-0015-SA-04, HFEF/N OMM 7130, Revision 3, Gregory M. Teske, March 29, 

1983 

• P275, Operation and Maintenance Manual: Loop Disassembly Machine, 

W0004-0094-SA-01, HFEF/N OMM 7131, Revision 1, G.M. Teske, August 11, 1971 

• P277, Operation and Maintenance Manual: SLSF Loop Gas 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 Cut-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; Revision 1, G.M. Teske; Gregory 

M. Teske, April 20, 1984, and October 2, 1980 

• P280, Operation and Maintenance Manual: Sodium Removal Equipment, 

W0009-0074-SA-00, HFEF OMM 7141, Revision 0, Kendal, January 5, 1976 

• P281, Operation and Maintenance Manual: Sodium Evaporator, 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 Hardware 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, Revision 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. Teraguchi, April 13, 1982 
B-20 

• P286, Operation and Maintenance Manual: IBC Washstations Operation and 

Maintenance, W0350-0067-ES-04, HFEF/S OMM 9171, Revision 4, P.L. Coomer, 

October 25, 1985 

• P298, Collection of Integrated Waste Tracking System 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 Transmittal 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 Transmittal 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 (TED) 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 (TED) 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 Package for EBR-II Temperature 

Monitor Capsules (TED) (Subassembly X262G), CMT Transmittal No. 81-212-0011, 

DRF A00-299, R.P. Tucker, D.R. Walker, March 10, 1981 

• P312, Core Materials Testing, Quality Assurance Package 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 Package for EBR-II Temperature 

Monitor Capsules (TED) (Subassembly X262H), CMT Transmittal No. 81-212-0058, 

DRF AOO-299, R.P. Tucker, D.R. Walker, December 10, 1981 

• P314, Core Materials Testing, Disposition and Disassembly Procedure for Barrier Tube 

Capsules, Thermal Spacer and Thermal Expansion Difference (TED) Monitor Capsules 

in Subassembly X262H, CMT Transmittal No. 82-212-0044, DRF AOO-299 and AOO635, R.E. Blood, September 28, 1982 

• P315, Core Materials Testing, Quality Assurance Package for EBR-II Temperature 

Monitor Capsules (TED) (Subassembly X262J), CMT Transmittal No. 82-212-0047, 

DRF AOO-299, R.P. Tucker, R.E. Blood, October 29, 1982 

• P316, Core Materials Testing, Disposition and Disassembly Procedure for Barrier Tube 

Capsules, Thermal Spacer and Thermal Expansion Difference (TED) Monitor Capsules 

in Subassembly X262J, CMT Transmittal No. 83-212-0059, DRF AOO-299 and 

AOO-635, R.P. Tucker, September 16, 1983 
B-21 

• P317, TED Manufacturing Procedures, OM-TED, Douglas L. Porter, November 6, 1990 

– February 22, 1992 

• P325, Operations and Maintenance Manual: Liquid Disposal 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. Nelson, December 7, 1976 

• P362, Operation and Maintenance Manual, Truck Lock, Fred L. DiLorenzo, 

W0125-0006-SA-02, HFEF OMM 2131, Revision 2, February 13, 1984 

• P363, Operation and Maintenance Manual, High Bay Area, B.J. Nelson, W0125-

0004-SA-01, HFEFIN OMM 2132, Revision 1, May 16, 1978 

• P364, Operation and Maintenance Manual, High Bay Crane, Paul Wayne, 

W0133-0003-SA-09, HFEF/N OMM 2510, Revision 9, October 3, 1988 

• P365, Operation and Maintenance Manual, Freight Elevator, B.J. Nelson, W0133-

0043-SA-00, HFEF OMM 2520, Revision 0, January 7, 1976 

• P366, Operation and Maintenance Manual, Truck Lock Crane, Paul Wayne, 

W0133-0079-ES-05, HFEF/N OMM 2590, Revision 5, December 1, 1987 

• P367, Operation and Maintenance Manual, In-Cell Contamination Monitoring System, 

W0135-0023-SA-04, HFEF/N OMM 2680, Revision 4, Kenneth T. Teraguchi, April 20, 

1988 

• P368, Operation and Maintenance Manual, Main Cell Structure, 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, November 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 Filters, W0159-0027-00-SA, 

HFEF/N OMM 3662, Revision 0, B.J. Nelson, February 12, 1975 

• P377, Operation and Maintenance Manual, Hex Tube Slitter, W0168-0001-SA-01, 

HFEF/N OMM 4154, Revision 1, P.L. Coomer, January 12, 1982 

• P378, Operation and Maintenance Manual, Dipper Transfer and Storage, 

W0164-0002-SA, HFEF/N OMM 4161, Revision 0, D.M. McKenzie, September 27, 

1974 
B-22 

• P379, Operation and Maintenance Manual, Dipper Heating 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 Mounting Equipment, 

E0271-0016-SA, HFEF/N OMM 4720, Revision 0, R.D. Phipps, 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, Analytical 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 Cleaning and Etching Equipment, 

E0271-0007-SA, HFEF/N OMM 4740, Revision 0, R.D. Phipps, 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. Lee, July 28, 1995 

• P398, Operation and Maintenance Manual, In-Cell Radiography Equipment – North 

W0170-0838-ES-01, HFEF/N OMM 5800, Revision 1, Thomas C. Cameron, 

February 10, 1984 

• P400, Operation and Maintenance Manual, Main Cell Equipment (TREAT Experiment), 

W0093-0347-SA-02, HFEF/N OMM 7320, Revision 2, K.T. Teraguchi, February 10, 

1983 

• P401, Operation and Maintenance Manual, TREAT Experiments, W021S-0001-SA-00, 

HFEF OMM 7400, Revision 0, Revision 1, K.T. Teraguchi, 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, February 18, 1983 

• P403, Operation and Maintenance Manual, HEDL Sodium Loop, W0215-0004-SA-01, 

HFEF OMM 7430, Revision 1, K.T. Teraguchi, November 11, 1980 
B-23 

• P404, Operation and Maintenance Manual, HEDL Static Capsule, K.T. Teraguchi, 

W0215-000S-SA-00, HFEF OMM 7440, Revision 0, Revision 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 Fat Slug Experiment, WAF-1212, 

C.W. Wilkes, G.R. Seidel, April 24, 1985 

• U025, DRAFT Facility Waste Descriptions Argonne-West, 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. Wilkes, February 12, 1985 

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

• U041, Miscellaneous pages including: Logsheet showing before and after radioisotope 

weights for different batches, Experimental Subassembly 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 X423A, 2-1869, E.M. Franklin, 

December 11, 1985 

• U043, Hot Cell Contamination Control Plan and Procedures, 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-330, #61176, May 16, 1988 

• U081, Dipping Experiment for Density, Sample B X423C T-330 #61176, May 16, 1988 

• U085, Accuracy of Immersion Density Measurement, May 5, 1988 

• U086, Transfer of SS Materials - Between Areas, 0864, November 5, 1986 

• U104, Argonne National Laboratory Analytical Sample Record for X-421 T128, 60754, 

60755, 60756, Robert Villarreal, November 19, 1987 
B-24 

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

• U108, Inspection/Disposition Report for .290 Jackets 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; January 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, 0873, 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, Ralph 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 Burnup Determination by Isotopic 

Dilution Mass Spectroscopy (IDMS) Analysis, Cal Morgan, 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, 1988 
B-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 Activities, R. Villarreal and 

J.R. Krsul, October 1, 1987 

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

• U190, Argonne National Laboratory, Argonne-West Analytical 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 X423B, 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 Paper, re: Determination of 

Burnup on Nuclear Fuels, ANL-6900, R.P. Larsen, Undated 

• U219, AL Sample Logbook No. 20 re: July 1984 - February 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 - September 1988, May 1, 1987 

• U222, Index of Material of Analytical Methods for Laboratory Use, Undated 

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

July 24, 1959 

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

• U225, Radiochemical Determination of Cerium by Liquid-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 EDTA, February 26, 1959 
B-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 Extraction 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, Undated 

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

1963 

• U234, Water Soluble Uranium Determination, W.S.U, July 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 EDTA, Zr-Vol, ANL-CEN, May 20, 

1959 

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

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

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

• U260, HFEF Process Work Sheet, Radiography of T5 Test Train, PWS No. 2-817, 

Revision 0, G.C. McClellan, December 10, 1979 

• U285, Experiment Designation and Identification, July 1991 

• U483, HFEF Transuranic Waste Can Log Cards, Undated

• U484, Radioactive Scrap & Waste Storage/Disposal Request and Authorization Forms 

and related documents, Undated 

• U541, Shipping Papers Gathered from MFC for ILTSF HFEF-5 Inserts, February 10, 

1983 

• U551, Compilation of HFEF Process Work Sheets and HFEF Procedure Change Notices; 

includes HFEF PWS Log, Subassemblies, PWS Nos., and PCN Nos., Various Dates 

• U552, Compilation of MFC Liner Documents, Various dates 

• U607, Excel Spreadsheet: Information for 108 MFC RH-TRU Liners, Reese Gannon, 

February 11, 2009 

• U645, Collection of Documents Pertaining to the Manufacture of Thermal Expansion 

Difference (TED) Temperature Monitor Jackets, Various dates 
B-27 

• U646, Fuel Manufacturing Process Data Sheets, TED Manufacturing, OM-TED-1B, 

Revision 0, Douglas L. Porter, December 9, 1991 

• U647, Thermal Expansion Difference Temperature Monitor 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 from 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 Idaho 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 Measurements 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, September 23, 2009 

• U651, Hot Fuel Examination Facility (HFEF) at Idaho National Laboratory (INL) RH 

TRU Radiological Characterization - ORIGEN2.2 Output Masses and Activities 

Converted to Curie Scaling Factors, INL-RH-64, Revision 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 Calculations 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 Idaho National Laboratory (INL) RH 

TRU Radiological Characterization - Estimation of the 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 TRU Radiological Characterization 

- Isotopes in Addition to the 10 WIPP-Required Reportable 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, September 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 24, 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, 2006 
B-28 

• U846, INL Cs-137 Dose-to-Curie Correlation Uncertainty, INL-RH-05, WS11, S9, S13, 

Revision 0, J. Holderness, May 8, 2006 

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

2006 

• U852, RERTR Adjustment Factor Development, INL-RH-11, Revision 0, J. Vance, May 

8, 2006 

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

2006 

• U856, Derivation of Burnup and Composition for Thorium Pins, INL-RH-15, Revision 0, 

J. Vance, May 8, 2006 

• U857, Scaling Factors Sensitivity Studies, INL-RH-016, 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-6000G (B-3411G), B-3411G, 

C.W. Wilkes, May 4, 1983 

• U885, Collection of Documents Pertaining to Subassembly 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 Subassembly X027, Various dates 

• U895, Photograph of HFEF Canisters in IBC, including N-94, P4280009, April 28, 2009 

• U896, Photograph of HFEF Canisters in IBC, including N-147 and N-136 with hazardous 

waste labels, P4280017, April 29, 2009 

• U898, Fuel Composition Calculations, LANL-RH-04, Revision 0, Jene Vance, 

February 22, 2006 

• U899, Uncertainty Analysis of Canisters with 364 Cans, LANL-RH-25, Revision 0, 

James H. Holderness, May 8, 2006 
ATTACHMENT C 

EPA EVALUATION ISSUE TRACKING FORM – 

RADIOLOGICAL CHARACTERIZATION 
C-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 the two radiological characterization 

reports CCP-AK-INL-551 and CCP-AK-INL-581 are required. These changes are required to enable the 

documents to adequately support technical aspects of both waste streams. These changes will be captured in a 

freeze file that will be provided to EPA by December 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. Harvill 

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 KNOWLEDGE 
D-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 justify 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 processes 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 discussion) 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 data 

pertaining to the 10 WIPP-tracked radionuclides, including 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