DOCKET NO: A

- 98

- 49, II

- A4

- 147

WASTE CHARACTERIZATION INSPECTION REPORT

PROPOSED APPROVAL

EPA BASELINE INSPECTION NO. EPA

- BAPL

- CCP

- RH

- 04.11

- 8 OF THE CENTRAL CHARACTERIZATION PROJECT REMOTE

- HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM FOR BETTIS ATOMIC POWER LABORATORY: August 30, 2010; September 23, 2010; December 8, 2010; April 12

- 13, 2011

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

May 2011i TABLE O F CONTENTS

Section Page
Acronyms and Initializations

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

................................ ................................ ................................ ............ 1 2.0 Purpose of Inspections

................................ ................................ ................................ ........ 3 3.0 Purpose of This Report

................................ ................................ ................................ ....... 4 4.0 Scope o f Inspection

................................ ................................ ................................ ............. 5 5.0 Inspection

- Related Definitions

................................ ................................ ........................... 6 6.0 Personnel

................................ ................................ ................................ ............................. 6 7.0 Performance of the Inspection

................................ ................................ ............................ 6 7.1 Bettis Laboratory Background

................................ ................................ ................ 6 7.2 Inspection Process Overview

................................ ................................ .................. 8 8.0 Technical Evaluation

................................ ................................ ................................ .......... 9 8.1 Acceptable Knowledge

................................ ................................ ........................... 9 8.2 Radiological Characteriza tion

................................ ................................ ............... 20 8.3 Visual Examination

................................ ................................ ............................... 31 9.0 Response to Comments

................................ ................................ ................................ ..... 32 10 .0 Summary of Results

................................ ................................ ................................ .......... 33 10.1 Environmental Protection Agency Findings and Concerns

................................ .. 33 10.2 Conclusions

................................ ................................ ................................ ........... 33 11.0 References

................................ ................................ ................................ ......................... 34ii ATTACHMENTS

Attachment A : Documents Reviewed During the Baseline Inspection Attachment B : Inspection Personnel List Attachment C : EPA Inspection Issue Tracki ng Form, EPA Issue No. BAPL

- CCP

- RH

- AK

- 11

- 001F, Final Attachment D : CBFO Response to EPA Finding No. BAPL

- CCP

- RH

- AK

- 11

- 001F, Final

LIST OF TABLES

Table 1. Batch Data Reports Examined

................................ ................................ ..................... 10 Table 2. Radiological Composition of HIPs in Waste Stream BT

- T001, Results of Final Binning Analyses

................................ ................................ ................................ ......... 13 Table 3. Data Traceability

................................ ................................ ................................ .......... 14 Table 4. Bettis Scaling Factors for Two HIPs

................................ ................................ ............ 26 Table 5. Summary of the Reported Radionuclides in the 27 Smear Samples

............................ 27 Table 6. Overall Uncertainty of Two HIPs at the Nominal Density of 0.7 g/cm 3

..................... 28iii ACRONYMS AND INITIAL IZATIONS

AK acceptable knowledge AKE acceptable knowledge expert AKS R acceptable knowledge summary report Am americium ATR Advanced Test Reactor BAPL Bettis Atomic Power Laboratory BDR batch data report CBFO Carlsbad Area Field Office CCP Central Characterization Project CFR Code of Federal Regulations CH contact

- handled C i curie Cm curium CRR Characterization Reconciliation Report Cs cesium CSSF Correlation and Surrogate Summary Form CTP Confirmatory Test Plan DOE U.S. Department of Energy DQO data quality objective DR discrepancy resolution DTC dose

- to

- curie DU Depleted U ranium EPA U.S. Environmental Protection Agency Eu europium EU Enriched Uranium FR Federal Register
g gram or grams g/cm 3 grams per cubic centimeter HLW high

- level waste HIP high pressure containeriv in inch or inches ICP

- MS Inductively Coupled Plasma

- Mass S pectrometry IDR instrument detection limit ITR Independent Technical Reviewer kg kilogram LANL Los Alamos National Laboratory LCS Laboratory Control Sample LLW low

- level waste LOQI list of qualified individuals LWA WIPP Land Withdrawal Act MCNP5 Monte Carl o N

- Particle Transport Code RSICC Computer Code Collection, Oak Ridge National Laboratory MEL Materials Evaluation Laboratory mR/hr/Ci milli Roentgen per hour per Curie

mr em/hr millir em per hour MT Material Types nCi/g nanocurie per gram NCR non

- conformanc e report NNPP Naval Nuclear Propulsion Program NOFORN Not Releasable to Foreign Nationals/Governments/Non

- US Citizens (Document Handling Instruction) NWPA Nuclear Waste Policy Act ORIA Office of Radiation and Indoor Air Pu plutonium QA quality assurance QA O quality assurance objectives QC quality control RH remote

- handled RTR real

- time radiography SCG summary category group SNF spent nuclear fuel SPM Site Project Manager Sr strontiumv T1 Tier 1 T2 Tier 2 Th thorium TMU Total Measurement Uncertainty TRU trans uranic U uranium VE visual examination WCPIP Waste Characterization Program Implementation Plan WIPP Waste Isolation Pilot Plant WMP waste material parameter WSPF Waste Stream Profile Form1 1.0 EXECUTIVE SUMMARY This report discusses the U.S. Environmental Pr otection Agency’s (EPA or the Agency) proposed approval of a single remote

- handled (RH) transuranic (TRU) debris waste stream [initially packaged in 15 high

- pressure containers (HIPs) and then emplaced in 55

- gallon drums] characterized using the waste char acterization program implemented by the Central Characterization Project (CCP) at the Bettis Atomic Power Laboratory (Bettis Laboratory). In accordance with 40 CFR 194.8(b), the EPA conducted Baseline Inspection No. EPA

- BAPL

CCP

- RH

- 04. 11

- 8 of the CCP ’s wa ste characterization program for RH TRU waste at the U.S. Department of Energy’s (DOE) Bettis Laboratory located in West Mifflin, Pennsylvania

. Upon EPA’s final approval, DOE can emplace BAPL

- CCP RH TRU debris waste in the Waste Isolation Pilot Plant (WIPP )

. The inspection took place in four steps : observ ation of the Visual Examination (VE) process on August 30, 2010, sample collection on September 23, 2010 , and dose

- to

- curie (DTC)
me asurements on December 8, 2010 at Bettis Laboratory and the baseline insp ection at the EPA Office of Radiation and Indoor Air (ORIA) in Washington, D.C. on April 12 and 13, 2011. The inspection scope included a single waste stream, Bettis Laboratory Waste Stream BT

- T001. Because additional RH TRU waste is not expected to be ge nerated for the foreseeable future from decontamination and decommissioning of hot cells, any additional RH TRU waste stream beyond the subject of this inspection generated at Bettis Laboratory will require a new baseline inspection and approval.

Waste Str eam BT

- T001 consists of research and experimental debris generated at Bettis Laboratory from 1973 through 1992. This inspection evaluated: acceptable knowledge (AK) records; DTC in conjunction with radionuclide

- specific scaling factors supported by radioch emical analyses of smear samples from the hot cells; and VE to confirm the physical and radiological contents of waste containers. The scope of the inspection was limited to the 15 55

- gallon drums containing the HIPs. The EPA inspection team identified o ne finding related to both the AK and radiological characterization processes that BAPL

- CCP implemented to characterize RH Waste Stream BT

T001 (see Attachment C ). In response to this finding, BAPL

- CCP revised several key documents associated with both AK and radiological characterization and prepared new documents following the inspection (see Attachment D). EPA reviewed the revised and new documents and determined that they adequately addressed the finding and that the BAPL

- CCP RH waste characterization p rogram was technically adequate and appropriately documented. In several cases, EPA reviewed the modifications to specific documents in the form of freeze

files 1

1 As a result of an inspection

- related EPA issue, CCP may have to revise a document. CCP makes the change(s) and provides the revised document to EPA as a freeze file to serve as objective evidence for the inspection. CCP’s document cont rol process then generates an official version of the revised document. serving as objective evidence to address EPA’s finding

. These will be finalized as revised d ocuments and must be provided to EPA before the end of the public comment period:2 **•** CCP

- AK

- BAPL

- 501 , Central Characterization Project Remote

- Handled Transuranic Radiological Characterization Technical Report for Bettis Atomic Power Laboratory Remote

- Handled Transuranic Fuel Debris Waste, Waste Stream: BT

- T001, Revision 1

**•** CCP

- AK

- BAPL

- 502, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for Bettis Laboratory Waste Stream: BT

- T001, Revis ion 1 (For the end date of the public comment period refer to the Federal Register Notice proposing to approve the baseline RH waste characterization program at the Bettis Laboratory.) Some of the revised documents that BAPL

- CCP generated are subject to B ettis Laboratory’s Public Utterance process (see Section 7.2), which could affect EPA’s planned approval schedule. Given that the Bettis Laboratory debris waste is scheduled for disposal in early July and that the EPA must complete its approval process (in cluding a 45

- day public comment period) on time, EPA is accepting the BAPL

- CCP freeze files as objective evidence to support its proposed approval

. EPA expects and the Bettis Laboratory has agreed that the revised formal documents will (a) be identical to the freeze files , (b) undergo the Public Utterance Process during EPA’s 45

- day public comment period window, and (c) be provided to EPA before the end of the comment period for review so EPA can issue its final approval of the BAPL

- CCP RH TRU waste charact erization program. EPA is proposing to approve the BAPL

- CCP waste characterization program implemented to characterize RH debris waste belonging to Waste Stream BT

- T001 evaluated during this baseline inspection that is described and documented in this rep ort. The proposed approval includes the following:
(1) The AK process for 15 HIPs of RH retrievably

- stored TRU debris designated as BAPL Waste Stream BT

- T001 (2) The radiological characterization process using DTC and scaling factors for assigning radionuclide va lues to Waste Stream BT

- T001 that is documented in CCP

- AK

- BAPL

501, Revision 1, and supported by the calculation packages referenced in this report (3) The VE process to identify waste material parameters (WMPs) and the physical form of the waste Generally, EP A’s RH and contact

- handled (CH) baseline inspections evaluate a site’s waste characterization program for technical adequacy and, when approved, the TRU site continues to use the approved program components to characterize additional wastes on an ongoing b asis. However, the subject Bettis Laboratory waste stream has been fully characterized and no further waste characterization activities relative to this waste stream will take place. Therefore, this proposed approval is limited to the discrete set of 15 HI Ps in BAPL Waste Stream BT

- T001. BAPL

- CCP may not characterize any additional RH waste in the future based on this baseline approval. Because no additional waste characterization activities will occur relative to the 15 HIPs of RH debris waste subject to t his proposed approval, changes to the waste characterization activities evaluated during the baseline inspection are not expected. Accordingly, this report does not list any Tier 1 (T1) or Tier 2 (T2) designations relative to this waste and the waste chara cterization components covered by this approval. Approval of any future or other past RH3 waste characterization activities at the Bettis Laboratory would require a new EPA baseline inspection. EPA must verify compliance with 40 CFR 194.24 before waste may be emplaced in the WIPP, as specified in Condition 3 of EPA’s certification of the WIPP’s compliance with disposal regulations for TRU radioactive waste [63 Federal Register (FR) 27354 and 27405, May 18, 1998]. EPA Baseline Inspection No. EPA

- BAPL

- CCP

- RH

- 04.11

- 8 was performed in accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571

– 42583).

2.0 PURPOSE OF INSPECTIO NS On May 18, 1998, EPA certified that the WIPP will comply with the radioactive waste disposal regulations in 40 CFR Part 191. In that certification, EPA also included Condition 3, which states that “the Secretary shall not allow shipment of any waste from...any waste generator site other than [Los Alamos National Laboratory (LANL)] fo r disposal at the WIPP until the Agency has approved the processes for characterizing those waste streams for shipment using the process set forth in § 194.8.” The approval process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information on acceptable knowledge (AK) 2

The rule applying to this baseline inspection can be found in the FR (Vol. 69, No. 136, pp. 42571

– 42583, July 16, 2004). Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must perform a baseline inspection of a TRU waste generator site’s waste characterization program. The purpose of the baseline inspection is to approve the site’s waste characterization program based on the demonstration that the program’s components, with appl icable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an on

- site inspection to verify that the site’s s ystem of controls is technically adequate and properly implemented. Specifically, EPA’s inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the following: for waste streams proposed for disposal at the WIPP, and (2) implement a system of controls used to confirm that the total amount of each waste component that will be emplaced in the WIPP will not exceed limits identified in t he WIPP Compliance Certification Application.

Any compliance application shall: . . . Provide information which demonstrate s that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value d escribed in the introductory text of paragraph of this section. 3

2 As of the FR notice of July 16, 2004, EPA has replaced the term process knowledge with acceptable knowledge

. Acceptable knowledge refers to any information about the process used to generate waste, material inputs to the process, and the time period during which the wastes were generated, as well as data resulting from the analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA certif ication decision to show compliance with Condition 3 of the certification decision. The

3 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant to [40 CFR 194.24(b)], the Department shall specify the limit ing value (expressed as an upper or lower limit of mass,4 system of controls shall include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste loading schemes used; and other documentation

. In other words, the purpose of the baseline inspection is to implement the requirements of 40 CFR 194 by assessing whether DOE sites that characterize TRU waste prior to disposal at the WIPP are capable of characterizing and tracking the waste. EPA ma y also conduct follow

- up inspections to address issues remaining from the baseline inspection or to seek further clarification/discussion related to waste characterization processes evaluated during a baseline inspection. By approving the CCP

- implemented w aste characterization systems and processes for RH debris waste at Bettis Laboratory, EPA confirms that the Agency has evaluated the capabilities of systems and processes implemented by the site to accomplish two tasks: (1) the identification and measureme nt of waste components, such as plutonium (Pu), that must be tracked for compliance, 4 and (2) the confirmation that the waste in any given container has been properly identified as belonging to the group of approved waste streams.

3.0 PURPOSE OF THIS REPO RT This report documents the basis for EPA’s approval and explains the results of Baseline Inspection No. EPA

- BAPL

- CCP

- RH

- 04.11

- 8 in terms of findings or concerns. Specifically, this report does the following:

**•** Describes the BAPL

- CCP waste characterization s ystems proposed for approval

**•** Delineates a specific set of RH wastes proposed for approval

**•** Provides objective evidence supporting the proposed approval basis for all waste characterization systems

**•** Identifies all relevant system limitations and/or conditions for each waste characterization system and/or waste containers that are subject to this proposed approval

**•** Provides objective evidence of EPA’s one finding, including its resolution and status As stated above, this report does not address T1 and T2 elemen ts. The DOE documents that EPA reviewed for this evaluation are cited throughout the report and are listed in Attachment A

. Any of these documents can be requested from the following address:

volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting value, of the total inventory of such waste proposed for disposal in the disposal system .”

4 The potential contents of a single waste stream or group of waste streams determine which processes can adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous, the site should select the matrix

- appropriate radiological characterization technique to obtain adequate radionuclide measurements. VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the nature of the waste has been confirmed, characterization techniques quantify selected radionuclides in the waste. In some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste streams or only a few. A site’s stated limits on the applicability of proposed waste characteriza tion processes govern the scope of EPA’s inspection.5 Manager, National TRU Program Carlsbad Field Office U.S. Depart ment of Energy P.O. Box 3090 Carlsbad, NM 88221

- 3090 EPA’s final approval decision regarding the BAPL

- CCP RH waste characterization program will be conveyed to DOE separately by letter following EPA’s review of public comments received responding to the p roposed approval discussed in this report. In accordance with 40 CFR 194.8(b)(3), this information is also available on EPA’s Web site at www.epa.gov/radiation/WIPP

. 4.0 SCOPE OF INSPECTION The scope of Base line Inspection No. EPA

- BAPL

- CCP

- RH

- 04.11

- 8 included the technical adequacy of the waste characterization systems used by BAPL

- CCP to characterize RH Waste Stream BT

- T001 contained in 15 HIPs

. The EPA inspection team evaluated these systems with respect to their ability to perform the following:

**•** Provide adequate documentation regarding the origin and classification of the RH TRU wastes proposed for disposal at WIPP using AK

**•** Identify and quantify the activities and associated uncertainties of the 10 WIPP

- tra cked radionuclides [americium

- 241 ( 241 Am), cesium

- 137 ( 137 Cs), plutonium

- 238 ( 238 Pu), 239 Pu, 240 Pu, 242 Pu, strontium

- 90 ( 90 Sr), uranium

- 233 ( 233 U), 234 U, and 238 U] and other TRU radionuclides using a combination of AK and DTC with the application of radion uclide

specific scaling factors

**•** Assign WMPs correctly for RH, retrievably

- stored debris waste that was repackaged using VE During an inspection, EPA does not approve characterization data; that function is the sole responsibility of the entity being evalua ted, in this case, BAPL

- CCP. EPA evaluated the site’s waste characterization processes to characterize RH TRU debris waste. The evaluation consisted of interviewing personnel, observing equipment operations and waste characterization practices at Bettis La boratory controlled by site procedures, and inspecting records related to each of the waste characterization processes within the inspection’s scope. An important aspect of this evaluation is the objective evidence documenting the effectiveness of the wast e characterization processes. Objective evidence typically takes the form of batch data reports (BDRs), AK accuracy reports and VE records . During this inspection, EPA selected samples of each of these items, based on the number and variety of items each w aste characterization process produced, consistent with standard auditing techniques. Because the waste characterization activities at BAPL

- CCP included a limited number of samples, EPA evaluated the one DTC and VE BDR and all three sampling BDRs that had been generated, essentially a 100% sample. Based on evaluating the waste characterization processes in conjunction with the objective evidence, EPA determined the technical adequacy of these processes and associated records within the inspection’s scope.6 DOE’s RH Waste Characterization Program Implementation Plan (WCPIP), DOE WIPP

- 02

- 3124, should be an accurate representation of the processes implemented to characterize RH TRU wastes for WIPP. Based on previous RH baseline inspections and T1 evaluations, E PA concluded that Revision 0D of the WCPIP, which had been in place since 2003, did not adequately reflect the requirements for the processes currently implemented by CCP and approved by EPA. As a result, the DOE Carlsbad Field Office (CBFO) revised the WC PIP to adequately address RH waste characterization activities an d Revision 2 of the WCPIP is effective as of April 21, 2011 . In 2010, CBFO was still revising the WCPIP and therefore, EPA requested that all RH characterization activities at Bettis Laborato ry that would be subject to this proposed approval be performed according to the WCPIP, Revision 0D.

5.0 INSPECTION

- RELATED DEFINITIONS During the course of an inspection, EPA inspectors may encounter items or activities that require further inquiry into thei r potential to adversely affect waste characterization and/or isolation within the repository. The two main categories relevant to waste characterization inspections are identified below:

**•** Finding : A determination that a specific item or activity does not conform to 40 CFR 194.24(c)(4). A finding requires a response from CBFO prior to site approval.

**•** Concern : A judgment that a specific item or activity may or may not have a negative effect on compliance and, depending on the magnitude of the issue, may or ma y not require a response. A concern requiring a response requires a response from CBFO prior to site approval.

6.0 PERSONNEL EPA and its support personnel conducted interviews with BAPL

- CCP personnel in several disciplines during three site visits at Bettis Laboratory and the meeting at EPA ORIA Offices. The members of the EPA inspection team and personnel contacted are listed in Attachment B.

7.0 PERFORMANCE OF THE I NSPECTION

7.1 Bettis Laboratory Background The Bettis Laboratory is located in West Mifflin, Pen nsylvania, and is operated under the direction of the Naval Nuclear Propulsion Program (NNPP). Since 1949 it has been dedicated to the design, development, testing, and operational support of naval nuclear propulsion plants used in the U.S. Naval Fleet ( Re ferences P100, P102, and U201 ) and its main focus has been the design and development of nuclear power for the United States (U.S.) Navy. Site activities supported government and commer c ial programs including research and testing associated with the U.S. n aval nuclear program (References P102 and U256). The activities that generated Waste Stream BT

- T001 were performed in the Materials Evaluation Laboratory (MEL), which consists of five c ell b anks: the East Bank, West Bank, Met Cell Bank, and Alpha Bank, all of which contributed to Waste Stream BT

- T001 , and the Central Bank, which did not contribute any waste. While the specific activities within each bank were different , all wastes w ere ultimately7 stored in the East Cell Bank and t hese wastes comprise Waste Stream BT

- T001 (References P103, U207, and U256)

. Waste Generation Activities The materials processed in the MEL were principally naval reactor and thorium (Th) fuels that can be classified as four fuel types: enriched uranium (EU), enriched uranium wit h thorium (EU + Th), Th, and depleted uranium with plutonium (DU + Pu ) (References U231, U259, and U398). Pertinent MEL activities used these fuel types as feed materials. Specific activities were: post

- irradiation examination of fuel assemblies and test s pecimens; lathing of irradiated fuel rods; metallographic specimen mounting, polishing, etching and testing; specimen decrudding and descaling; dye and fluorescent penetrant inspections; fission gas extraction; removal and crushing of fuel prior to testing ; and chemical dissolution of samples for subsequent testing and analyses (References P107, P108, P112, P113, P120, U209, and U264) . These processes generated swarf 5 which ultimately became BAPL

- CCP Waste Stream BT

- T001.

Waste Details
The EU, EU + Th, T h, and DU + Pu materials that were processed in the MEL and their radionuclide constituents represent the radionuclide contents of the BAPL

- CCP wastes. These materials were loaded into 15 HIPs, each with a volume of 3.9 liters. Each HIP contains powder and other waste materials der ived from the activities described above, and Bettis Laboratory radiation surveys indicated surface dose rates 6

5 Swarf is material that is produced by a cutting or grinding process. greater than 200 millirem per hour (mrem/hr) for each HIP. Each HIP was inserted in a 55

- gallon drum, which is the fin al configuration and shipping container for all 15 HIPs in Waste Stream BT

- T001 (Reference U269). Waste Stream BT

- T001 is composed of test residues, test materials, and the resultant test fragments from the fuel specimens, including irradiated fragments an d disperse d particulate (fines and dust). The RH TRU wastes in Waste Stream BT

- T001 were generated in the MEL during examination of fuel specimens that came primarily from naval reactors and originated from Navy ships, prototype plants, irradiated test spe cimens [from the Advanced Test Reactor (ATR)], and the Shippingport Atomic Power Station. The ATR and Shippingport Atomic Power Station are commercial facilities not associated with defense activities in general; however, the Naval Reactors Program designe d fuel assemblies to be irradiated in the ATR and Shippingport with the intent that Bettis Laboratory would utilize the fuel examination information to improve nuclear propulsion technology. These technology advancements have been a vital contribution to t he U.S. Naval defenses ( References P104, U201, and U256 ).

6 Rem is a unit of dose equivalent, which is often commonly called dose or when it is expressed per unit time, a dose rate

. The crit erion for RH determination is expressed in terms of a dose rate in Rem, which, while technically incorrect, is commonly used. In this report, the terms dose and dose rate are used in place of the technically correct term dose equivalent or dose equivalent rate . The actual difference among these values for the purpose of this report is negligible.8 7.2 Inspection Process Overview EPA conducted Baseline Inspection No. EPA

- BAPL

- CCP

- RH

- 04.11

- 8 of BAPL

- CCP’s program to characterize RH TRU wastes at Bettis Laboratory on three occasions from September

– December 2010 and at EPA ORIA offices from April 12 through 13, 2011. This inspection had the scope described in Section 4.0 for the purpose of determining the site’s compliance with 40 CFR 194.24. The inspection was conducted in the following steps:
(1) Ob taining and reviewing site procedures, reports, and other technical information related to RH waste characterization activities used to characterize BAPL

- CCP Waste Stream BT

- T001 (2) Observing BAPL

- CCP personnel perform VE, sample collection , and DTC at Bettis Laboratory on three separate occasions in 2010 in advance of the baseline inspection at EPA ORIA offices in April 2011 (3) Preparing technical questions prior to the inspection based on the activities cited in (1) above (4) Interacting with CBFO and BAPL

- CCP pers onnel to arrange inspection logistics (5) Evaluating BAPL

- CCP’s implementation of waste characterization processes for adequacy and demonstrating compliance with 40 CFR 194.24 requirements (6) Conducting the baseline inspection to verify the technical adequacy and /or qualifications of RH waste characterization personnel, procedures, processes, and equipment, as documented in BAPL

- CCP records (7) Evaluating the radiometric and spectrometric data used to support the development of radionuclide

- specific scaling factors (8) Ev aluating the correlations of HIPs for the purpose of identifying common attributes, i.e., “binning” (9) Recording one finding on an EPA Inspection Issue Tracking Form, which was completed and provided to CBFO and BAPL

- CCP personnel as it was generated (see Att achment C for a copy of this form) (10) Communicating all pertinent information to CBFO and BAPL

- CCP personnel (11) Pursuing resolution of the finding prior to completion of the inspection, when feasible (12) Conducting entrance, exit, and daily briefings for CBFO and B APL

- CCP management personnel for all four segments of the inspection (13) Obtaining and reviewing BAPL

- CCP documents that were revised and/or created in response to the EPA finding after the inspection, and closing the finding (14) Issuing the inspection report and proposed approval Due to the potentially sensitive nature of information concerning site activities at Bettis Laboratory, some of the information supporting the RH TRU program is considered Not Releasable to Foreign Nationals/Governments/Non

- US Citizens ( NOFORN). This information was not available until the April inspection at EPA offices. Additionally, all technical9 information had to undergo the Public Utterance process prior to release to EPA, including key documents that are typically provided to EPA w ell in advance of the inspection. While this is understandable, it added to the complexity of the inspection process particularly when BAPL

CCP documents required revision to address the EPA finding discussed in Sections 8.1 and 8.2. 7

8.0 TECHNICAL EVALUATION Sections 8.1 through 8.3 of this report detail the three technical areas assessed during this inspection:

**•** AK

**•** Radiological Characterization

**•** VE

8.1 Acceptable Knowledge EPA examined the AK process and associated information to determine whether BAPL

- CCP de monstrated compliance with 40 CFR 194.8 requirements for RH W aste S tream BT

- T001

. Waste Characterization Element Description As part of the inspection, EPA reviewed the following with respect to the use of AK for RH waste characterization by BAPL

- CCP:

**•** Waste stream identification including radiological and physical characteristics

**•** V erification that the subject waste is of defense origin and is not high

- level waste (HLW), low

- level waste (LLW), or spent nuclear fuel (SNF)

**•** Role of AK in the characterizatio n methodology, including radiological and physical composition of the waste an d use of AK to support scaling factors derived by BAPL

- CCP

**•** Adequacy of the WCPIP AK process implementation

**•** Adequacy of the AK Summary Report (AKSR)

**•** Data traceability

**•** Sufficiency of source documents

**•** WCPIP interpretation with respect to AK qualification

**•** Confirmatory Test Plan (CTP) preparation and plan adequacy

**•** Preparation and adequacy of Waste Stream Profile Form (WSPF) and Characterization Reconciliation Report (CRR)

**•** Correlatio n of Correlation and Surrogate Summary Form (CSSF) and CH

- RH

7 EPA’S evaluation of a T1 change to add INL

- CCP Waste Stream IN

- ID

- NRF

- 153 in November 2010 involved the same processes with NOFORN and Public Utterance, see EPA Docket No. A

- 98

- 49, II

- A4

- 135.10 **•** Personnel training and qualifications

**•** Non

- Conformance Reports (NCRs) and AK discrepancy resolution

**•** Accuracy

**•** Plans for load management

**•** Identification of the method for determining data quality ob jectives (DQOs) and which DQOs are attained through AK Qualification Documents and Batch Data Reports Reviewed Source documents, reports, forms, and other data were provided to EPA, and the relevant sources
were reviewed as part of this baseline inspectio n. All documentation examined is listed in Attachment A and the sampling, DTC , and VE BDRs examined are presented in Table 1

. Table 1

. Batch Data Reports Examined
Container No. Sampling BDR No. DTC BDR No. VE BDR No. HIP

- 41

- 23

- 4 N/A BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 20

- 1 BARH1001 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 16

- 8 BARH1001 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 06

- 10 BARH1002 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 33

- 9 BARH1002 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 24

- 7 N/A BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 30

- 3 BARH1001 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 18

- 2 BARH1001 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 32

- 6 BARH1003 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 13

- 5 N/A BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 28

- 11 N/A B APLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 15

- 12 BARH1003 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 05

- 13 BARH1002 BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 27

- 14 N/A BAPLRHDTC11001 RHBAPLVE100001 HIP

- 41

- 21

- 15 N/A BAPLRHDTC11001 RHBAPLVE100001

Technical Evaluation EPA evaluated the adequacy of AK information specific to Bettis Laboratory Waste Stream BT

T001 as described in the AKSR, CCP

- AK

- BAPL

- 500 , Revision 1. Waste stream BT

- T001 consists of TRU debris waste generated from nuclear fuel examination and testing act ivities conducted at the Bettis Laboratory. (1) The waste stream definition was examined for Waste Stream BT

- T001 and was found to be adequate.

The RH WCPIP Revision 0d defines a waste stream as " waste material generated from a single process or activity, o r as waste with similar physical, chemical, and radiological properties." The AKSR for Waste Stream BT

- T001 did not adequately support the waste stream determination based on this definition. As described in Section 7.1, four different process lines and s e veral different activities in the MEL cell banks contributed to the waste stream

. The Radiological11 Characterization Report (CCP

- AK

- BAPL

- 501 ) states that the radiological compositions of individual HIPs are distinct, and can be grouped into at least five ge neral categories. Based on this information, EPA determined during the baseline inspection process that the AKSR did not adequately support the waste stream determination because the radiological composition of the waste is heterogeneous and requires HIP

- s pecific scaling factors. EPA requested that BAPL

- CCP revise the AKSR to appropriately reflect the radiological composition of waste Stream BT

- T001.

BAPL

- CCP revised the AKSR to include additional information about processes performed in the MEL , clarifyin g that all activities were associated with fuel pin or sample testing that generated a total of 15 HIPs (e.g. , References U214 and U 243 ) . The revised AKSR also clarified that wastes were initially collected in Dolly tubes 8 or other containers [see Item (3) ] and were ultimately repack ag ed into 15 HIPs . T he HIPs were not generated by intentionally mixing wastes from specific process lines or Dolly tubes to create defined radiological compositions. Instead, HIPs were loaded primarily to meet site nuclear safet y criteria. This means that wastes were not intentionally packaged by process line and their heterogeneity is the result of packaging activities, not the intentional generation of separate waste streams. For perspective, EPA previously accepted the use o f multiple scaling factors within a single waste stream for Oak Ridge RH Waste Stream OR

- REDC

- RH

- HET (EPA Docket No. A

- 98

- 49; II

- A4

- 111). ORNL

- CCP stated, and EPA agreed, that the use of different scaling factors was analogous to individual radioassays of CH drums, which generate unique radiological signatures for each drum. EPA also accepted the use of multiple scaling factors because the radiological characterization process was well supported by the Waste Stream OR

- REDC

- RH

- HET Radiological Characterizati on Report. Similarly, EPA accepts the use of multiple scaling factors for Waste Stream BT

- T001 because the waste stream is limited to 15 containers, the radiological composition of each HIP has been well established [see Item ( 2 )], and the overall processe s and radiological composition of waste in individual Dolly tubes and other containers are adequately defined.
(2) Physical and radiological compositions of the waste stream presented in the acceptable knowledge summary report were assessed and found to be ad equate. Physical and radiological attributes of waste are important elements of the waste stream determination [see Item (1)]. EPA found that the AKSR did not adequately define the Summary Category Group (SCG) (Reference U267), and did not adequately asso ciate the physical waste composition presented in the AKSR with the process origins. Source document U267 identified the contents of each HIP to be primarily powder with "clumps," which is a solid, SCG S3000. BAPL

- CCP provided the WMP calculation memorandu m (CCP

- TP

- 005, Attachment 6) and explained that the metal HIPs and their contents are considered debris waste ; cribbing and shielding are not included as debris waste components in the SCG and WMP calculations. The calculation memorandum adequately verifie d the appropriate assignment of the S5000 SCG by demonstrating that the waste material is approximately 33% solids and 67% debris by volume

. BAPL

- CCP representatives also provided the original WMP calculations showing that the

8 Dolly tubes are straight

- right cylinders with threaded ends that were used for interim storage of the RH debris prior to transferring them to the HIPs. They could be combined to form longer tubes and their specific dimensi ons are not available in the Bettis Laboratory documents reviewed for this baseline inspection.12 majority of the waste stream mass is attributable to metals. Based on the available information, EPA determines that t he physical composition of the waste stream is adequately described. EPA also found that the AKSR presented only a broad radiological composition that appeared to
con tradict the need to develop HIP

- specific scaling factors (References C213 and P127). However, in practice, BAPL

- CCP "binned" the HIPs into groups with similar radiological composition, as described in CCP

- AK

- BAPL

- 501, and developed the sampling and analysi s plan (CCP

- AK

- BAPL

- 505A, Revision 0) based on these AK groupings, see Item (7) below. EPA evaluated the original binning based on radiological composition information provided in source documents (References U259 and U212) and in conjunction with EPA’s tr aceability analysis. EPA determined that the original HIP binning performed by BAPL

- CCP did not include all wastes present in individual HIPs and could therefore compromise the radiological characterization process. This issue was discussed with BAPL

- CCP p ersonnel and EPA formalized it as a finding on an EPA Inspection Issue Tracking Form as No. BAPL

- CCP

- RH

AK

- 11

- 01F, as discussed below (see Attachment C for a copy of this form ). 9 BAPL

- CCP responded to the EPA finding by modifying the AKSR to include inform ation from additional radiological source documents (References U259, U220, U231, and U241). The AKSR was revised to show the correlation between waste within each HIP and specific radiological Material Types (MT). MTs in Waste Stream BP

- T001 are DU (MT 11 and 12), EU (MT 33, 34, 36, 37, 38, and 39), Pu (MT 56 and 57), U enriched in 233 U (MT 72), and Th (MT 88). The MTs occur within the HIPs in various combinations. BAPL

- CCP determined that each HIP is associated with one of the following radiological group ings:

**•** 233 U + Th

**•** EU + Th

**•** Th only

**•** EU only

**•** DU + Pu In response to EPA's finding, BAPL

- CCP re

- evaluated the binning process and found that the radiological contents of the following HIPs were not adeqately represented in the original binning process due to the presence of additional cans or Dolly tubes:

HIP Number Additional Container (s) 41

- 20 AF

- 1, AF

- 2, AF

- 3 and AF

- 4 (all Dolly tubes) 41

- 23 Can M042 41

- 33 Dolly tube DC11

BAPL

- CCP re

- examined the AK record to determine the MTs associated wit h each of the omitted containers. BAPL

- CCP determined that HIP 41

- 20 contains Th, which was not originally considered in the binning process (Reference U231). Bettis Laboratory representatives determined that the fuel specimens in M042 and DC11 consist of only EU, and that neither Th
nor 233 U type fuel specimens are present in these containers (Reference U398). As a result,

9 Because this finding had a bearing on both AK and radiological characterization it is discussed multiple times in Sections 8.1 and 8.2 of this report. Accordi ngly, it may be described slightly differently in a specific report section to emphasize aspects pertinent to the characterization technique discussed in the section.13 accounting for M042 in HIP 41

- 23 d oes not alter the original fuel type contribution in HIP 41

- 23, which was already 100% EU fuel specim ens (Reference U259). Similarly, waste in HIP 41

- 33 is composed predominantly of EU (Reference U398), so accounting for DC11 d oes not significantly alter the radiological composition of HIP 41

- 33. However, BAPL

- CCP determined that due to inclusion of the o mitted Th fuel type, HIP 41

- 20 no longer accurately represents HIP 41

- 23. Therefore, HIP 41

- 20 is not associated with any other HIP, i.e., it became unbinned, and HIP 41

- 23 will be binned with HIP 41

- 05, as discussed below.

B APL

- CCP also identified an app arent omission in the record of fuel specimens contributing to HIP 41

- 32. Upon further review, it was determined that all fuel specimens were accounted for during the original binning effort (Reference U398). EPA evaluated the information presented in Refe rence U398 and concluded that BAPL

- CCP's assumptions used to determine the impact of accounting for M042, M043, and Dolly tube DC11 on the radiological compositions of HIP 41

- 23, HIP 41

- 32 and HIP 41

- 33 are valid

. Table 2 presents BAPL

- CCP's final binning results and association of HIPs with general radiological categories based on AK, as presented in Attachment D (References U211, U212, U213, U231, U245, U259, and U399).

Table 2

. Radiological Composition of HIPs in Waste Stream BT

- T001, Results of Final Binning Analyses

Sampled? 233 U + Th EU + Th Th EU DU + Pu Combination 1

Binned

HIP

- 41

- 13 No 0% 67% 0% 33% 0%

--- HIP

- 41

- 21 No 0% 40% 10% 50% 0%

--- HIP

- 41

- 32 Yes 0% 68% 5% 27% 0%

---

HIP

- 41

- 05 Yes 0% 2% 2% 96% 0%

--- HIP

- 41

- 23 No 0% 0% 0% 100% 0%

---

HIP

- 41

- 24 No 3% 16% 0% 68% 16%

--- HIP

- 41

- 28 No 0% 9% 0% 75% 16%

--- HIP

- 41

- 33 Yes 0% 14% 0% 62% 24%

---

HIP

- 41

- 18 Yes 2% 14% 0% 85% 0%

--- HIP

- 41

- 27 No 0% 18% 0% 82% 0%

--- Unbinned

HIP

- 41

- 06 2 Yes

--- ---- ---- ---- ----- 100% HIP

- 41

- 15 2 Yes

--- ---- ---- ---- ----- 100% HIP

- 41

- 16 Yes 0 % 14 % 0 % 43 % 43 %

--- HIP

- 41

- 20 2 ,3 Yes

--- ---- ---- ---- ----- 100%

HIP

- 41

- 30 Yes 0 % 32 % 0 % 50 % 18 %

--- 1 The HIP contents were assumed to be various combinat ions of MT identified in other HIPs. No data were available concerning the MT in HIP 41

- 06 and 41

- 15. MT 36, 38, and 88 are present in HIP 41

- 20, although the percentages were not specified by BAPL

- CCP. 2 Excluded from binning evaluation because waste gener ating processes were associated with water that could alter the 137 Cs concentrations by dissolution; each HIP was sampled and unique scaling factors were developed. 3 The AKSR states that HIP 41

- 20 contains a very high percentage of EU

.14 EPA examined the binning data and the analysis that BAPL

- CCP performed in response to the finding. EPA verified that the composition of HIP 41

- 20 includes MTs 36, 38 39, and 88, as well
as non

- fuel waste that would not impact the radiological composition of the HIP’s conte nts. HIP 41

- 23 contained powder composed primarily of MT 36 and 39 without Th, and HIP 41

- 05 contained powder composed primarily of MT 39 (88%), with approximately 8% MT 36 and less than 4% MT 88 and 38. BAPL

- CCP associated HIP 41

- 23 with HIP 41

- 05 because the contents of both are primarily EU, concluding that the small percentage of Th fuel specimens in HIP 41

- 05 would have a small effect on the overall radionuclide distribution in the HIP. EPA agrees that association of HIP 41

- 23 with HIP 41

- 05 is appropr iate based on AK information. EPA found that the response to the finding was adequate because the modified binning was justified based on AK radiological information and sampling data (see Attachment D). Each group or "bin" was sampled, and the HIPs with in each bin were of similar radiological composition based on AK; therefore, application of sampling results to each HIP in the bin is technically justified. The AKSR was significantly revised to include information about binning, the different radiologica l MT, general radiological groupings, MT present in each HIP, and results of the AK

- based binning process. The AKSR, as modified in response to EPA's inspection and finding, is technically adequate.
(3) Data traceability was examined and found to be adequate

. Data traceability was evaluated to determine whether radiological data were traceable from the fuel specimens to the final 55

- gallon drum packaging and whether the HIPs are attributable to specific fuel types by reviewing available information for five drums. The Dolly tubes/cans 10 contributing waste to each HIP were identified and cross

- referenced to interim containers , 11 fuel specimens, and associated fuel types, as summarized in Table 3 (References P129, U212, U213, U231, U236, U245, U259 , and BDR s RHBA PLVE100001 , BARH1001, BARH1002, and BARH1003 )

. Table 3

. Data Traceability

Drum No. HIP No. Interim Container Dolly Tube/ Can Nos. MEL Process Area(s) Fuel Type(s) Source of Fuel Specimen Data

41

- 05

- 13 41

- 05 MS03 M017, M017Q Met 38, 88 U259 M041 36, 39 U259
41

- 20

- 1 41

- 20 TB3 M038 East 36, 39 U259 TB11 AF

- 1

– AF

- 4 Alpha 38, 88 U231
41

- 23

- 4 41

- 23 MS03 M039 East 36, 39 U259 M042, M042Q not available 1 U212/U211
41

- 27

- 14 41

- 27 MS04 M036, M036A Met 33, 34, 36, 38, 39, 88 U259

10 Wastes were initially packaged in pint or quart cans at the time of generation; however wastes had to be transferred to Dolly tubes for transportation to the East Cell Bank for storage. Wastes generated in the East Cell Bank may have been stored in pint or quart cans. 11 Interim containers are 3.5

- gallon cans or other sealable containers used to temporarily consolidate the Dolly tubes/cans for waste management/accountability within the MEL. The tubes/cans cannot be sealed; therefore they were sealed in the interim containers for temporary storage and were later removed from the interim contain ers in exactly the same condition with the same identification numbers.15 Drum No. HIP No. Interim Container Dolly Tube/ Can Nos. MEL Process Area(s) Fuel Type(s) Source of Fuel Specimen Data Can 1078, then 41

- 06 Can 1078 East COW 1

- 8 , 76, 92, 93, 89 2 U259/U236

41

- 33

- 9 41

- 33 MS01 M022 (SL1

- SL18) Met 11, 38, 39, 57, 88 U259 DC11 East 39 3

- 1 Fuel codes for M042 are not included in the source documents. Fuel specimen type is determi nable to Bettis Laboratory staff through a code in the specimen ID number (Reference U212); however, this information has been redacted ( U211 ). 2 This is potentially an incomplete list. Fuel specimen type is provided for only a small portion of the specimen s included in Can 1078; for information regarding the other specimens, see note ‘A’ (Reference U236). 3 From U398

BAPL

- CCP assumed that source document U259 contained a complete record of the fuel specimens packaged in each HIP ; this was found to not be th e case. During the traceability evaluation, EPA identified three occasions where Dolly t ubes and/or cans were excluded from U259. HIP 41

- 20 contains the contents of can M038 and Dolly t ubes AF

- 1 through AF

- 4. The contents of M038 are listed in U259, but th e AF Dolly tubes are not listed. Similarly, M042 (HIP 41

- 23) and DC11 (HIP 41

- 33) are missing from source document U259. As discussed in Item (2), EPA determined that s ince BAPL

- CCP had relied solely on source document U259 to develop the comprehensive sep aration of waste materials into categories (bins) , the less than comprehensive binning of sample materials could compromise the technical basis of scaling factor development

. EPA documented the issue as a finding ( see Attachment C). BAPL

- CCP’s response to the finding is described in Item (2) and Attachment D . EPA independently examined traceability information for HIPs 41

- 13, 41

- 15, and 41

- 16 to verify BAPL

- CCP’s response to the finding and found BAPL

- CCP’s impact assessment to be adequate (References P129, U213, U251, U252, U253, U254, U259, U260, U261, and U262 ). After the HIPs were packaged, it was determined that HIP 41

- 06 (packaged from can 1078) had an elevated dose rate. Approximately 60% by volume of the contents of this HIP was subsequently transfe rred to HIPs 41

- 06, 41

- 21, and 41

- 27, approximately 20% each. This operation is documented ( References U396 and U397 ) and took place prior to sampling and VE activities

. EPA determined that the AK record did not include this documentation. BAPL

- CCP identif ied the missing records and added them to the AK record. EPA finds data traceability from fuel specimen to 55

- gallon drum to be adequately established.
(4) The identification of the waste as transuranic and not high

- level waste, low

- level waste, or spent nucl ear fuel was examined and found to be adequate. The Land Withdrawal Act (LWA) prohibits the disposal of SNF and HLW as defined by the Nuclear Waste Policy Act (NWPA) at WIPP. The NWPA and DOE M435.1

- 1 12

12 DOE M435.1

- 1 is the Department of Energy’s Radioactive Waste Management Manual. s tate that spent nuclear fuel is “fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elements of which have not been separated by re processing... [However,] t est specimens of fissionable material irradiated for research and development only, and not production of power o r plutonium, may be classified as waste, and managed in accordance with the requirements of this Order when it is technically infeasible, cost prohibitive, or would16 increase worker exposure to separate the remaining test specimens from other contaminated
m aterial.” The NWPA states that HLW is “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 fissi on products in sufficient concentrations, and other highly radioactive material that the commission, consistent with existing law, determines by rule requires permanent isolation.”

Waste Stream BT

- T001 is composed of test residues, test materials, and th e resultant test fragments from the fuel specimens, including irradiated fragments and disperse d particulate (fines and dust). Operations at the MEL did not include the separation or reprocessing of irradiated fuel el ements withdrawn from a reactor. As a r esult, waste stream BT

- T001 is not composed of SNF or HLW as defined by the LWA and NWPA and is therefore eligible for disposal at WIPP as RH TRU waste (References P100, U201, U256 , and U267).
(5) Defense status of the waste was evaluated and found to be adeq uate ly documented

. Initially, the AKSR did not include sufficient information to indicate that examination of the ATR and Shippingport fuels discussed in 7.1, above, contributed directly to development of defense technologies. EPA discussed this lack of i nformation with BAPL

- CCP, who then revised the AKSR in sufficient detail to clarify the role played by ATR and Shippingport.
(6) The Acceptable Knowledge Summary Report and implementation of acceptable knowledge as required in Attachment A of the Waste Chara cterization Program Implementation Plan were evaluated and found to be adequate. Initially, the AKSR did not adequately address the waste stream definition, radiological composition of the waste stream, physical characteristics of the waste stream, defens e status of the waste stream, and drum or waste traceability [see Items (1), (2), (3), and (5) for additional detail]. BAPL

- CCP revised the AKSR to adequately address these technical deficiencies. The WCPIP Revision 0d is the primary document governing t he RH waste characterization program, and Attachment A of this document provides requirements explicit to the assembly, use, and interpretation of AK. These requirements address personnel responsibilities and training, compilation and data acquisition, AK data review, interpretation, qualification and reconciliation, waste stream profile form preparation, and AK records. These requirements are addressed in Items 1

- 16; refer to these items for EPA's review of the required elements.
(7) Acceptable knowledge sup port documents, including the sampling and analysis plan , and related document tracking were evaluated and found to be adequate. The sampling and analysis plan for Waste Stream BT

- T001 describes the basis for the sampling, sampling methods and protocols, sampling and laboratory quality assurance (QA) and is discussed in Section 8.2. The sampling plan was adequate for the purposes of collecting representative sample data for scaling factor development.17 Documents are tracked in the Acceptable Knowledge Sour ce Document Reference List (CCP

TP

- 005, Attachment 4), as well as in individual report reference lists. Comparison of Attachment 4 and references lists in each of these documents indicates that Attachment 4 had not been updated at the time of the inspectio n to include the calculation packages and other references presented in the revised AKSR and the revised Radiological Characterization Report. Attachment 4 was revised to include references generated in response to EPA's finding (see Attachments C and D).
(8) Implementation of the Waste Characterization Program Implementation Plan requirements was evaluated and found to be adequate. The WCPIP, Revision 0d, presents the characterization requirements for RH waste necessary to demonstrate compliance with 40 CFR 194.24 (c)(4) which requires that a system of controls be established to ensure that waste emplaced in the WIPP will not exceed upper or lower limiting waste parameters. This system of controls must include measurement, sampling chain of custody records, record

- keeping systems, waste loading schemes, and other documentation including AK [40 CFR Part 194 (c)(3)]. See Items (1) through (16) of this section for AK compliance requirements including record

- keeping systems in Items (3) and (7) and waste loading schemes pertaining to LLW in Item (15). Sections 8.2 and 8.3 address radiological characterization and VE, respectively.
(9) Content and technical adequacy of the Certification Plan were evaluated and found to be adequate.

The WCPIP Revision 0D states that the Certification Plan must include the following:

a. A description of the rationale for attaining each DQO, including the selection of peer review, equivalent QA program, or confirmatory testing as methods of qualifying AK information for each DQO b. A listing of the DQOs, and identification of which methods will be used to assess compliance with the DQOs, and the rationale for the selection of the method(s), including specific methods of AK qualification

CCP

- AK

- BAPL

- 502 , Revision 0 is the Certification Plan and Confirmatory Testing Plan (Certification Plan), although confirmatory testing was not performed. BAPL

- CCP indicated that AK would be qualified using characterization techniques listed in the WCPIP and a combination of techniques to qualify AK informati on. The Certification Plan describes the waste stream ; waste stream DQOs and Quality Assurance Objectives ( QAOs ); and how th e waste stream will be characterized by sampling and analysis, DTC, and VE . The Certification Plan does not state that AK will be co nfirmed and , in fact , BAPL

- CCP representatives indicated that while the site provided information allowing waste stream review and HIP r adiological grouping [see Item ( 2) ] , the technical AK data necessary to develop scaling factors w ere not provided. There fore, BAPL

- CCP found it necessary to perform sampling and analysis, the results of which were used to identify and determine the relative radiological composition of each sampled HIP. Item (7) and Sections 8.2 Items (2) and (3) address sampling and analysi s, including applicable QA and quality control (QC) requirements. EPA finds the Certification Plan to be acceptable.18 (10) Content and technical adequacy of the draft Waste Stream Profile Form and Characterization Reconciliation Report were evaluated and found to be adequate. The draft WSPF and CRR were provided to EPA on February 4, 2011, and a revised draft CRR was provided on May 3, 2011, in response to the EPA finding [see Items (2) and (3) and Attachment C]. The WSPF and both CRRs included all the require d data fields. These documents were provided for this inspection only and will be revised and finalized as characterization of the waste stream progresses. EPA expects to receive copies of the final WSPF and related attachments when they are available.
(11) P ersonnel training was evaluated and found to be adequate.

The WCPIP , Revision 0d specifies that AK personnel responsible for compiling AK, characterizing RH TRU waste streams using the AK process, and assessing the AK characterization shall be qualified a nd trained in the following areas:

**•** RH WCPIP

**•** The nonconformance and corrective action processes

**•** Procedures presented in Attachment A of the WCPIP

**•** Site

- specific training relative to the contents of the site’s waste streams

**•** Determining radiological contents of individual containers Training records for Jim Luginbyhl [Acceptable Knowledge Expert (AKE)] and Irene Quintana [Site Project Manager (SPM) ] were examined and found to be complete

. BAPL

- CCP representatives informed EPA that they are no longer required to document reading of revised procedures. When procedures are substantially revised, AKEs are required to attend a briefing regarding the change. Attendance sheets document compliance. EPA will revisit the issue of proper documentation of training to new procedures after the new WCPIP is implemented

. Jene Vance and Jim Holderness performed the radiological characterization , including compilation of necessary AK support documents . While this approach appeared appropriate during initial EPA RH inspections, in practice, this has resulted in the inclusion of less radiological characterization information in the related AKSR

. Consequently, the AKSR has required consistent revision to include more radiological information. More overlap between CCP

- AK

- BAPL

- 500 an d CCP

- AK

- BAPL

- 501 in terms of the AK radiological composition of the waste wa s nece ssary; this was corrected through a freeze file and subsequent revision of CCP

- AK

- BAPL

- 500 [see Items (2) and (6)].
(12) The Correlation and Surrogate Summary Form process was evaluated and was found to be not applicable.

BAPL

- CCP representatives stated that there is no analogous CH component of Waste Stream BT

- T001 so a CSSF was not prepared.19 (13) Data limitations, non

- conformance reports, and discrepancy resolution forms were
exa mined and found to be adequate.

BAPL

- CCP provided DR004, dated June 11, 2010, to address application of EPA hazardous waste numbers to Waste Stream BT

- T001, which was previously identified and managed as non

hazardous. BAPL

- CCP also provided three NCRs to EPA as part of this inspection. NCR

RHBAPL

- 0001

- 10 and NCR

- RHBAPL

- 2143

- 11 were generated in response to problems with the sampling process, and NCR

- RHBAPL

- 0300

- 11 was generated in response to a scale mechanical error during the DTC process. As a result of these NCRs, one HIP (HIP 41

- 33) had to be re

- sampled, and all 15 HIPs had to be re

- weighed. All three NCRs have generation dates that are the same as their final approval dates. NCR

- RHBAPL

- 0001

- 10 is dated over a month after the sample was declared to hav e an excessive dose rate and rejected in favor of a new sample. The dates for NCR

- RHBAPL

- 0300

- 11 indicate that i t was generated and completed on January 26, 2011; however, according to DTC BDR BAPLRHDTC11001, all weighing was completed by January 15, 2011 (most took place in early December). EPA finds that BAPL

- CCP can adequately prepare DR forms and NCRs when appropriate; however, the delayed NCR generation suggests that the NCRs were prepared retrospectively, and not in response to the actual non

- conformi ng acts. EPA did not investigate this matter further. Data limitations are included as a line item on Attachment 5 of the WCPIP, Appendix A (Attachment 3 of CCP

- TP

- 005) that is included as a cover page to every source document . EPA did note that a few sou rce documents were identified in this attachment as NOFORN when the documents had been declassified, and that a few NOFORN documents were not identified as such. BAPL

- CCP indicated that they are encouraged to avoid identifying the NOFORN documents as such on the Attachment 3s of CCP

- TP

- 005 . EPA is not concerned about d ocuments being described at a higher level of class ification than they really are.
(14) Acceptable knowledge accuracy was assessed and found to be adequate.

BAPL

- CCP provided EPA with a draft AK accuracy report that was prepared solely for this inspection on March 26, 2011. All 15 HIPs have been fully characterized and AK accuracy was found to be 100%. The AK accuracy report contains several typographical errors, and EPA expects that these will b e corrected in the final AK accuracy report. The AK accuracy report did not need to be revised due to EPA’s finding because the containers were not reassigned to a new SCG and none of the containers failed to meet the DQOs

. EPA expects that a copy of the f inal AK accuracy report will be provided when it is available.
(15) Load management was assessed and was found to not be applicable.

BAPL

- CCP indicated that load management will not be performed for this waste stream.
(16) Attainment of data quality objectives t hrough acceptable knowledge verification was evaluated and found to be acceptable. As a result of the analysis presented in Items 1

- 1 5 , above, EPA was able to assess how each DQO will be addressed. The following DQOs must be addressed as per the WCPIP:20 **•** De fense 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 meta ls and cellulose, plastic, and rubber
When evaluated as a whole, CCP

- AK

- BAPL

- 500, Revision 2, CCP

- AK

- BAPL

- 501, Revision 1, CCP

- AK

- BAPL

- 502, Revision 1 , and other AK and supporting source documents presented in Attachment A of this report indicate that the WCPIP

- specified DQOs have been met. Summary of A cceptable K nowledge Findings and Concerns The EPA inspection team identified one finding related to AK, which is discussed in multiple areas above. A copy of the EPA Inspection Issue Tracking Form is inclu ded in Attachment C and BAPL

- CCP’s response is included in Attachment D. EPA considers all aspects of this finding to have been adequately addressed, and there are no open findings or concerns related to AK resulting from this inspection. Proposed Baselin e Approval EPA is proposing to approve the AK process evaluated during this baseline inspection. This approval is limited to the 15 HIPs packaged in 55

- gallon drums in Waste Stream BT

- T001.

8.2 Radiological Characterization

Waste Characterization Element De scription The radiological characterization of BAPL

- CCP Waste Stream BT

- T001 TRU relies on DTC, in conjunction with radionuclide

- specific scaling factors that were developed for Waste Stream BT

T001 based on the following three sources of information:

**•** A K for Waste Stream BT

- T001, as summarized in CCP

- AK

- BAPL

- 500 and associated source documents

**•** Radionuclide

- specific l aboratory results from the analysis of smear 13

**•** Analyses of fuel types to develop scaling factors fo r the six HIPs that had not been sampled via “binning,” i.e., matching the sampled and nonsampled HIPs based on the closeness of the relative contributions to the HIPS from the various fuel types. samples collected for nine of the 15 HIPs

13 A swipe , wipe or smear is a non

- quantitative test for the presence of removable radioactive material s in which a surface or area is wiped with a filter paper or other substance, which is then assayed for specific radionuclides using destructive or nondestructive techniques.21 The radiological characterization methods used for this BA PL

- CCP RH TRU waste stream were evaluated in terms of the technical adequacy, as supported by the program’s documents, procedures, and controls, and the knowledge and understanding of the personnel involved in the RH waste characterization program. During this RH inspection, the EPA inspection team evaluated the following elements of the BAPL

- CCP radiological characterization program:

**•** Sample collection observed at Bettis Laboratory in September 2010

**•** External gamma measurements made at Bettis Laboratory in December 2010

**•** Development of DTC correlation s for each drum a t a nominal waste density using the Monte Carlo N

- Particle Transport Code (MCNP5 ® ) to model the drum’s gamma dose rate based on a one

- curie source of 137 Cs and europium

- 154 ( 154 Eu), assuming they are the main contributors to the dose

**•** Derivation of radionuclide scaling factors for the WIPP

- tracked radionuclides using the analysis of smear (swipe) samples obtained from the nine sampled HIPs

**•** Representativeness and technical adequacy of the analytical data used to support the scaling factors

**•** Determination of radionuclide scaling factors using the “binning” performed for the remain in g, nonsampled six HIPs.

Documents Reviewed

All Bettis

- CCP RH radiological characterization documents that were reviewed to support this inspection are listed in Attachment A

. Technical Evaluation The EPA inspection team evaluated the following aspects:
(1) The radiological characterization process and its documentation were evaluated and found to be adequate. The radiologi cal characterization process for Waste Stream BT

- T001 was comparable to the processes observed at previous RH TRU sites. A flow diagram depicting the overall radiological characterization process is shown in Figure 1, below. Several aspects of this process required additional documentation; in specific, the manner in which the 15 HIPs were associated based on common attributes, referred to as binning, as discussed in Section 8.1 Items (2) and (3), above. Upon closer examination, the EPA inspection team conc luded the information upon which the binning was based was not comprehensive, i.e., that sample containers had been inadvertently excluded. This had the potential to compromise the technical basis of the scaling factor development and was discussed with BA PL

- CCP AK and radiological characterization personnel. As a result, EPA generated Inspection Issue No. BAPL

- CCP

- RH

- AK

- 11

- 01F (see Attachment C for a copy of this form). BAPL

- CCP personnel agreed to reevaluate the records and ensure that the binning was cor rect, which resulted in the revision of several documents, the DTC BDR, and the generation of a new calculation package (see Attachment D). EPA evaluated22 Figure 1

. Flow Diagram for the Overall Characterization of Waste Stream B T

- T00123 the revised documents and accepted that the finding had been adequately addressed with respect to radiological characterization. The AK aspect of the finding is discussed in Section 8.1 Items (2) and (3), above. EPA considers this finding closed.
(2) The collection of representative samples from the High Pressure Inner Container s was evaluated and found to be adequate and appropriately documented. The sampling and analysis plan describes the sampling basis, methods, and applicable QA/QC. Procedure CCP

- TP

- 512, Revision 3, presents the sampling procedures implemented by BAPL

CCP for sampling Waste Stream BT

- T001. EPA reviewed both of these documents and found them adequate for their intended purposes. The sampling plan binned the 15 HIPs into six cate gories based on AK and ensured that each category , along with the relative percent contribution of each of the four fuel types, EU, EU + Th, Th and DU + Pu, was represented. The categories and their associated HIPs were as follows :

**•** Very high EU content ( HIP 41

- 20 and HIP 41

- 23)

**•** Relatively high DU + Pu content (HIP 41

- 16)

**•** Mid

- range DU + Pu content (HIP 41

- 24, HIP 41

- 28, HIP 41

- 30 and HIP 41

- 33)

**•** Moderate Th and Th + U content (HIP 41

- 18 and HIP 41

- 27)

**•** Relatively high Th breeder fuel content (HIP 41

- 13, HIP 41

- 21 and HIP 41

- 32)

**•** Relatively low Th and Th + U content (HIP 41

- 05) These groups are somewhat different than those that ultimately defined the waste stream based on sampling results, inspection results, and the EPA finding resolution. As documented in the sampling plan, three smear samples were taken from each of the following nine HIPs: HIP 41

- 05, HIP 41

- 06, HIP 41

- 15, HIP 41

- 16, HIP 41

- 18, HIP 41

- 20, HIP 41

- 30, HIP 41

- 32, and HIP 41

- 33. A co

- located sample was also collected, resulting in a total of 2 8 samples. T he sampling plan also documented the methodology for calculating the minimum number of samples required and the QAOs and QC requirements based on the analytical laboratory’s criteria. J. Holderness prepared a memorandum summarizing the analytic al results, the achievement of the QAOs and pertinent statistical analyses of the data, which are provided in a total of twenty data packages (see Attachment A). The QAOs for sampling were accuracy, precision, representativeness, completeness, and comparab ility, all of which were achieved, as documented by the Holderness memorandum. EPA observed the sample collection process at Bettis Laboratory on September 23, 2010, and evaluated these activities against the sampling plan. The sampling activities occurre d in the MEL, Hot Cell No. 11 with HIP 41

- 33 and the VE container, and the Bettis Laboratory manipulator operators worked in the Cell 13 Work Area. The HIP and VE container connect via a threaded connection and the HIP contents were emptied into the VE con tainer and then back into the HIP five times directly prior to sampling, ensuring that all sampled surfaces were adequately coated with residue. Once the sample material was back in the HIP, operators collected three samples, as follows: in the threaded ne ck of the HIP; in the threaded neck of the VE container; and on the bottom of the VE container. Samples consisted of long

- handled swabs which were transferred to a plastic bag directly post

- collection. EPA observed all aspects of the24 sample collection, inc luding: the use of contamination barriers; decontamination of the manipulators between samples; preventing cross

- contamination of samples; transferring samples to clean containers; and collecting radiation readings in cell and from the three samples. The
s ampling personnel consisted of one Bettis individual reading the sample collection procedure out loud (M. Crossen) and two manipulator operators who repeated each step prior to executing it (J. Williams and C. Carpenter); the Cognizant Engineer, A. Samme l , author of the procedure , was overseeing the effort. Bettis Laboratory personnel worked from their own procedure and all activities were executed using step

- tracking , a process that follows this general approach: prior to performing an action, M. Crossen r ead each procedural step out loud; J. Williams and C. Carpenter acknowledged the specific action directed by the step; J. Williams and C. Carpenter then executed the step; and M. Crossen indicated on a paper copy of the procedure that the step had been exe cuted. This process was repeated for every step. This approach is thorough and time intensive, and the documentation for the process is comprehensive. BAPL

- CCP personnel ensured that all aspects of CCP

- TP

- 512 were executed, although they did not actually p erform any of the sampling actions. Sampling of all the HIPs was documented in three sampling BDRs, Nos. BARH1001, BARH1002, and BARH1003, all of which EPA evaluated and found to be adequate. BDR No. BARH1001 contained the co

- located sample required by the sampling and analysis plan. The Independent Technical Reviewer (ITR) checklist for this batch had the N/A (not applicable) answer indicated for question No. 11 which asked: Was a co

- located sample (field duplicate), collected once per sampling batch or ev ery seven days (whichever is more frequent)? (Attachment 1). This was incorrect as a co

- located sample had been collected as required. However, the error was not quality affecting and EPA accepted BAPL

- CCP’s verbal commitment to correct this entry to Yes

. BAPL

- CCP agreed to provide a copy of the NCR that will be generated to enable this change to be processed. There were no concerns regarding the technical adequacy or documentation of sample collection for Waste Stream BT

- T001.
(3) The radiochemical data were found to be representative and technically adequate to support their intended use, the development of radionuclide

- specific scaling factors. The Idaho Project Cleanup Project Analytical Laboratory 14 located at the Idaho National Laboratory in Idaho Fall, I D, analyzed a total of 28 smear samples collected from sampling nine of the 15 HIPs, as described above. This included one laboratory duplicate sample per analytical batch. EPA had inspected and approved this laboratory in 2010 in conjunction with a T1
eva luation to add an INTEC RH TRU waste stream to the Idaho National Laboratory’s certification (see Docket No. A

- 98

- 49; II

- A4

- 130). The suite of analyses performed was as follows:

**•** Liquid Scintillation Counting for the determination of 241 Pu

**•** Chemical separat ion and Gas Flow Proportional counting for the determination of 90 Sr

**•** Chemical separation and Alpha Spectrometry for the determination of 241 Am, curium

- 244 ( 244 Cm ) , 245 Cm, 238 Pu, 239 Pu/ 240 Pu, and 228 Th

**•** Gamma Spectrometry for the determination of 154 Eu and 1 37 Cs

**•** Inductive coupled Plasma

- Mass Spectrometry for the determination of 233 U, 234 U, 235 U, 236 U, 238 U, 239 Pu, 240 Pu, and 242 Pu

14 This facility was formerly known as the INTEC (Idaho Nuclear Technology Center) laboratory.25 EPA reviewed selected analytical data from the 20 BDRs to ensure complete and accurate reporting of the results and verify the us e of appropriate QC. This review demonstrated that:

**•** BDR narratives provided a complete and correct description of the analytical processes

**•** Appropriate analytical procedures were used for sample preparation and analysis

**•** Appropriate standards and verificati on samples were employed

**•** Acceptance criteria had been established for the pertinent attributes

**•** Control samples were within acceptance criteria (see NCR No. 105645 below)

**•** Analytical results were reported in correct units and data were flagged as required

**•** Al l data had been subject to review before release, as documented in the BDRs NCRs were generated as needed. For example, the laboratory initiated NCR No. 105645 because of low Laboratory Control Sample (LCS) recoveries in analytical batch Nos. 101093, 1010 94, 101095, and 10196. These LCS failures were accepted and the data were used as is because they were used as relative determinations to support isotopic ratios. NCR

- RHBAPL

- 2143

- 11 in BDR No. ALD10053G was initiated because the i ncorrect s ample number was entered on CCP

- TP

512, Attachment 1 , Sample Tracking Form. This condition was identified during the Independent Technical Review and the final disposition of the NCR was use as is

. Thirteen of the 27 Inductively Coupled Plasma

- Mass Spectrometry (ICP

- MS) m easurements reported positive values for 239 Pu and 240 Pu, which were determined by taking the average ratios of 239 Pu/( 239 Pu + 240 Pu) and 2 40 Pu/( 239 Pu + 240 Pu) from the 13 samples where both isotopes were measured. These ratios were then multiplied by the 239 Pu/ 240 Pu ratio for each sample as determined by alpha spectrometry to derive their fractions as 0.412 for 239 Pu and 0.588 for 240 Pu. While not measured in any of the samples, the 241 Pu value was conservatively estimated to be equal to the instrument det ection limit (IDL) for 242 Pu, whose typical activity contribution to the total TRU concentration is less than 1%. The QAOs for the laboratory analyses were accuracy, precision, representativeness, completeness and comparability, all of which were achieved.
(4) The determination of scaling factors for sampled and nonsampled High Pressure Inner Containers was evaluated and was found to be adequate. Developing scaling factors for the sampled HIPs was based primarily on the analytical results from the smear sampl es collected at Bettis Laboratory, discussed in (2) and (3), above. The radiometric and mass spectrometry data from the Idaho Project Cleanup Project Analytical Laboratory were adequate for this purpose. The nonsampled HIPs were correlated with the sample d HIPs based on their similarities with respect to fuel types, discussed in Section 8.1 Item (2) and summarized in Table 2, above. As discussed in several places throughout this report, the association or binning of HIPs was found to have excluded some con tainers and had to be revised to ensure it was comprehensive, as captured in the EPA finding (see Attachments C and D). Although this required revising the DTC BDR and several calculation packages, the impact on the actual values was small. Scaling factor development for the nonsampled HIPs was also complicated as a result of apparent differences due to enhancements and/or depletions of 137 Cs based on its solubility in water, which was used in some waste generating operations. This required adjustments to t he scaling factors for HIPs 41

- 24 and 41

- 28. Scaling factors for a sampled (HIP 41

- 05) and nonsampled26 HIP (41

- 13) are summarized in Table 4, below. There were no concerns regarding the technical adequacy of developing scaling factors for the sampled and no nsampled HIPs.

Table 4

. Bettis Scaling Factors for Two HIPs

Radionuclide HIP 41

- 05 137 Cs Scaling Factor, Ci Radionuclide/Ci 137 Cs HIP 41

- 13 137 Cs Scaling Factor, Ci Radionuclide/Ci 137 Cs Th

- 228 3.39E

- 04 2.43E

- 03 U

- 233 8.11E

- 05 4. 43E

- 04 U

- 234 1.06E

- 04 2.11E

- 04 U

- 235 1.25E

- 06 6.95E

- 06 U

- 236 1.83E

- 05 1.02E

- 05 U

- 238 1.48E

- 08 8.31E

- 07 Pu

- 238 1.02E

- 01 2.72E

- 02 Pu

- 239/Pu

- 240 5.48E

- 04 2.70E

- 03 Pu

- 239 2.26E

- 04 1.11E

- 03 Pu

- 240 3.22E

- 04 1.59E

- 03 Pu

- 241 6.45E

- 03 9.60E

- 03 Pu

- 242 2.22 E

- 04 1.17E

- 03 Am

- 241 1.82E

- 03 6.60E

- 03 Cm

- 244 7.58E

- 04 3.80E

- 03 Cm

- 245 4.03E

- 05 1.14E

- 04

Sr

- 90 1.65E+00 8.13E

- 01 Cs

- 137 1.00E+00 1.00E+00 Eu

- 154 1.70E

- 02 1.23E

- 02
(5) C omputer modeling to develop the dose

- to

- curie correlation was evaluated and was foun d to be adequate.

BAPL

- CCP used the MCNP ® computer code to develop DTC correlations for the sample material packaged in HIPs, which are placed inside steel shield containers of two thicknesses, 2.5 inches or 3.25 inches. Calculations were performed for a 1

- curie (Ci) source of 137 Cs and 154 Eu at a nominal density of 0.7 g/cm 3 at an assumed fill height of 60% and yielded values in units of roentgen per hour per Ci of 137 Cs and 154 Eu (R/hr/Ci) [see Item (10), below] . There were no concerns regarding the tech nical adequacy of this modeling to develop DTC correlations.
(6) Correlation of the radionuclide inventory values to the cesium

- 137 concentration for each drum was evaluated and was found to be technically adequate and appropriately documented. The complete list of radionuclides included in the radiological characterization of the BAPL RH TRU waste is as follows: 233 U, 234 U, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am, 244 Cm, 245 Cm, 228 Th, 90 Sr, 90 Y, 137 Cs , 137 m Ba, and 154 Eu. The radionuclides that were reported are summarized in Table 5. The application of the DTC correlations developed for 137 Cs and 154 Eu involved the partitioning of the average total dose rate measured into the contributions of each of these two gamma

- emitters, and determining the 137 Cs inventory in each drum to be multiplied by the scaling factors for sampled and nonsampled HIPs, as discussed in several areas of this27 section. There were no concerns regarding the technical adequacy of this modeling to develop DTC correlations.

Tab le 5

. Summary of the Reported Radionuclides in the 27 Smear Samples

Radionuclide Number of Reported Values Th

- 228 27 U

- 233 27 U

- 234 27 U

- 235 27 U

- 236 27 U

- 238 23 Pu

- 238 27 Pu

- 239/Pu

- 240 27 Pu

- 239 17 Pu

- 240 13 Pu

- 241 24 Pu

- 242 0 Am

- 241 27 Cm

- 244 27 Cm

- 245 26

Sr

- 90 27 Cs

- 134 3 Cs

- 137 27 Co

- 57 3 Co

- 60 7 Eu

- 152 8

(7) The technical basis and documentation of total measurement uncertainty were evaluated and found to be adequate. The development of Total Measurement Un certainty (TMU) for Waste Stream BT

- T001 is based on the propagation of uncertainties present in specific aspects of the determination of the radiological constituents of RH TRU waste. These aspects are assumed to be independent, which allows them to be ad ded in quadrature

. 15 The TMU determination included contributions of the following:

**•** 137 Cs DTC correlation

– MCNP ® code, and modeling uncertainties

15 Adding in quadrature is a standard statistical technique that allows one to combine the square root of the sum of each contributor to uncertainty squared, resulting in a lower value than if the values had been simply added. For example, the 239 Pu total uncertainty for HIP 41

- 05 is derived by taking the square root of (27.1%) 2 plus (20.3%) 2

, which equals 33.9%, which is smaller than if the values had simply been added, i.e., 47.4%.28 **•** 137 Cs and 154 Eu dose measurement uncertainty

**•** Scaling factor uncertainty

– including sample data uncertainty (except 242 Pu)

**•** Uncertainty in the isotopic fractions ( 239 Pu and 240 Pu)

**•** Uncertainty in the 242 Pu scaling factor due to use of the ICP

- MS IDL values

**•** Composition of the fuels in nonsampled HIPs
A general treatment of TMU is presented in CCP

- AK

- BAPL

- 501 , Sec tion 6, and in Uncertainty Analysis for BAPL HIPs , BAPL

- RH

- 03 (Reference U352 ). The overall uncertainties for the sampled and nonsampled HIPs are consistent with what EPA has observed for RH determinations at other RH TRU generator sites, and are summarize d for a sampled HIP (41

- 05) and a nonsampled HIP (41

- 13) in Table 6, below. As expected, the scaling factor and total uncertainty are greater for the nonsampled HIPs. There were no concerns regarding the technical derivation and documentation of TMU for Be ttis

- CCP Waste Stream BT

- T001.

Table 6

. Overall Uncertainty of Two HIPs at the Nominal Density of 0.7 g/cm 3

Radionuclide HIP 41

- 05 Total 137 Cs Uncertainty HIP 41

- 05 Total Scaling Factor Uncertainty HIP 41

- 05 Total Uncertainty HI P 41

- 13 Total 137 Cs

Uncertainty HIP 41

- 13 Total Scaling Factor Uncertainty HIP 41

- 13 Total Uncertainty

Th

- 228 27.1% 8.9% 28.5% 27.1% 51.1% 57.8% U

- 233 27.1% 17.2% 32.1% 27.1% 51.7% 58.4% U

- 234 27.1% 1.5% 27.2% 27.1% 52.3% 58.9% U

- 235 27.1% 2.4% 27.2% 27.1% 53.7% 60.2% U

- 238 27.1% 58.5% 64.5% 27.1% 55.1% 61.4% Pu

- 238 27.1% 1.7% 27.2% 27.1% 57.0% 63.1% Pu

- 239 27.1% 20.3% 33.9% 27.1% 57.9% 64.0% Pu

- 240 27.1% 14.3% 30.7% 27.1% 56.2% 62.4% Pu

- 241 27.1% 8.9% 28.6% 27.1% 51.4% 58.2% Pu

- 242 27.1% 100% 10 3.6% 27.1% 111.8% 115.1% Am

- 241 27.1% 7.3% 28.1% 27.1% 53.0% 59.5% Cm

- 244 27.1% 2.5% 27.2% 27.1% 54.4% 60.8% Cm

- 245 27.1% 47.4% 54.6% 27.1% 63.2% 68.8%

Sr

- 90 27.1% 3.1% 27.3% 27.1% 17.0% 32.0% Cs

- 137 27.1% 0.0% 27.1% 27.1% 0.0% 27.1% Eu

- 154 27.1% 7.3 % 28.1% 27.1% 20.3% 33.9%

Y

- 90 27.1% 3.1% 27.3% 27.1% 17.0% 32.0% Ba

- 137m 27.1% 0.0% 27.1% 27.1% 0.0% 27.1% Total Activity 27.1% 1.9% 27.2% 27.1% 7.6% 28.2%
(8) Execution and documentation of the dose

- to

- curie technique were assessed and found to be adequ ate. EPA observed the DTC technique on December 8, 2010, in the Crane Aisle of the East High Bay of the MEL at Bettis Laboratory. Bettis Laboratory personnel had set up a manually operated crane on the north

- south axis of the building to hoist the drums c ontaining HIPs onto the DTC assembly. EPA observed the DTC process for Drum No. 41

- 13

- 5 beginning with Bettis Laboratory personnel loading it on the Mettler Toledo General Scale GE25, Serial Number DCO918, for weighing. This scale had a current calibration that was valid until February 28,29 2011, and it was checked with reference weights prior to use, as documented on the scale’s calibration certificate obtained at Bettis Laboratory. The drum was weighed and the weight (302.10 kg) recorded. Bettis Laboratory personnel then lifted the drum into the DTC assembly. BAPL

- CCP personnel Tommy Mojica and James Rowsell observed Bettis Laboratory personnel perform this process and ensured that it was performed in accordance with CCP

- TP

- 504, Revision 10. Both Mojica and Rowsell were listed on the list of qualified individuals (LOQI) and were current on relevant training. Background and detector checks were performed and recorded prior to taking drum measurements; the values were recorded using the appropriate gamma detec tor (Thermo Electron Model FH 40 G Dose Rate Measuring Unit with FHZ 612 Probe). A copy of the Measurement Control Report was provided to EPA and it included all pertinent information. Measurements were made in four locations on the drum’s circumference (0 **°** , 90 **°** , 180 **°** , and 270 **°** ) and all measurements were recorded on the Container Data Sheet, a copy of which was provided to EPA. The measurements and all accompanying parameters were acceptable and a copy of this and the other forms cited above are contained i n DTC BDR BAPLRHDTC11001, as discussed in Item (9), below. BAPL

- CCP personnel consulted an operator aid that was posted in the area, CCP Operator Aid: RH

- DM

- BAPL

- 001, 12/10/10 . This listed tolerances for the Test Drum Weights, Scale Error, Operational Rang es for the Geiger Mueller Probes , and A cceptance C riteria for the S ource C hecks. There were no issues regarding the execution and documentation of DTC for Waste Stream BT

- T001.
(9) Radionuclide documentation in dose

- to

- curie batch data reports was assessed an d found to be adequate. The DTC results for all 15 HIPs were documented in a single BDR, BAPLRHDTC11001. The EPA inspection team verified that this BDR included the following:

**•** SPM Checklist, Attachment 8

**•** BDR Cover Sheet, Attachment 4

**•** BDR Table of Content s, Attachment 5

**•** BDR Narrative Summary, Attachment 6

**•** ITR Review Checklist, Attachment 7

**•** Measurement Control Report with all parameters acceptable, Attachment 1

**•** Container Data Sheets for 15 containers, Attachment 2

**•** Waste Container DTC Conversion Records with all required parameters for 15 containers, Attachment 3

**•** Evidence of signatures by the ITR on Attachment 7 and an SPM on Attachment 8

**•** Type of waste in each container on Attachment 3, steel

**•** TRU determination for all containers on Attachment 3

**•** Correct revis ion of CCP

- TP

- 504 (Revision 10) There were no concerns regarding the technical adequacy of the radionuclide documentation in DTC BDR BAPLRHDTC11001 for the 15 HIPs in Waste Stream BT

- T001.30 (10) Remote

- handled determinations were evaluated and found to be adeq uate.
The determination that the HIPs were RH, i.e., had contact dose rates in excess of 200 mrem/hr, must be based on unshielded dose rates. This required the use of a surface dose multiplier, defined as the ratio of the surface dose rate where no credit is taken for shielding to the shielded dose rate. This was done using MCNP ® to model the unshielded dose on the drum top, bottom and sides for two shielding thicknesses, 2.5 inches and 3.25 inches, and dose rate multipliers were developed for both configu rations, as documented in calculation package BAPL

- RH

- 07, Calculation of Drum Surface Dose Rate (Reference U356) [see Item (5), above]. The measured (shielded) dose rate was corrected using the surface dose multiplier to make the RH determination. These mu ltipliers were then used by Bettis Laboratory to establish the waste’s classification as RH, as documented in the Bettis Laboratory Memorandum B

- NEO(NE)DNE

64E, dated April 12, 2011, titled Erratum: Surface Dose Rates for 55

- Gallon drums Loaded with Bettis Laboratory Remote Handled Transuranic Debris Waste Stream BT

- T001 . There were no concerns regarding the RH determination of the 15 HIPs in Waste Stream BT

- T001.
(11) TRU determinations were evaluated and were found to be adequate.

DTC BDR BAPLRHDTC11001 cont ained values and the associated uncertainties for the 10 WIPP

- tracked radionuclides plus other radionuclides, as appropriate, for all 15 HIPs. In all cases the TRU alpha concentration exceeded 100 nCi/g. There were no concerns regarding the TRU determinati ons of the 15 HIPs in Waste Stream BT

- T001. Summary of Radiological Characterization Findings and Concerns The EPA inspection team identified one finding and did not identify any concerns related to radiological characterization. The finding had bearing on AK and aspects of it are discussed in Section 8.1, above. A copy of the EPA Inspection Issue Tracking Form recording the finding is provided in Attachment C. EPA considers this concern to have been adequately addressed upon submission of revisions of ca lculation packages, one new calculation package, the DTC BDR and freeze file changes to CCP

- AK

- BAPL

- 501. The formal response submitted by CBFO is included as Attachment D to this report. There are no open findings or concerns related to radiological charac terization resulting from this inspection. Proposed Baseline Approval EPA is proposing to approve the radiological characterization process consisting of DTC as described in CCP

- TP

- 504 in conjunction with the radionuclide scaling factors documented in CC P

- AK

- BAPL

- 501, Revision 1, that were evaluated during this baseline inspection. This approval is limited to the 15 HIPs containing Waste Stream BT

- T001.31 8.3 Visual Examination Waste Characterization Element Description As part of the inspection of the VE ac tivities, the EPA inspection team focused on overall procedural technical adequacy and implementation, as well as the identification of WMPs and prohibited items, in reviewing the following VE elements:

**•** Documentation of VE activities through use of an ap proved procedure

**•** Proper execution through observation of VE activities at Bettis Laboratory

**•** Management oversight and independent review of VE activities

**•** Training of VE personnel VE was used to determine the following aspects of TRU waste characterizatio n:

**•** Types and amounts of WMPs

**•** Confirmation of the Waste Matrix Code

**•** Presence or absence of prohibited items

Documents Reviewed

All Bettis Laboratory and BAPL

- CCP VE documents that were reviewed to support this inspection are listed in Attachment A

.

Tec hnical Evaluation During the inspection, the EPA inspection team evaluated the technical elements of the VE process. These areas are summarized as follows: (1) Overall procedural technical adequacy and implementation were assessed and found to be adequate.

T he VE procedure is documented in CCP

- TP

- 500 and contains specific information on performing VE, including identification of prohibited items, assignment of WMPs, data recording and technical review of examination results. The EPA assessed this procedure fo r technical adequacy and completeness and did not identify any issues.
(2) Characterization of WMPs and prohibited items was assessed and found to be adequate. EPA observed the VE process at Bettis Laboratory on August 30, 2010 . All VE activities occurred in the MEL, Hot Cell No. 11 with HIP 41

- 33, in conjunction with the sampling activities described in Section 8.2 Item (2), above, with the Bettis Laboratory manipulator operators working in the Cell 13 Work Area while being observed by BAPL

- CCP VE operators. The HIP was attached to a VE container via a threaded connection and the HIP contents were emptied into the VE container. Bettis Laboratory personnel and BAPL

- CCP VE operators examined the HIP’s contents in accordance with Bettis Laboratory procedure MEL

- 10

- 016

-32 NE O

- TWD using step

- tracking described in Section 8.2 Item (2), above. The two BAPL

- CCP VE Operators, Tommy Mojica and Spencer Pattee, performed VE in accordance with the sampling plan during this operation and recorded their activities in Notebook O LB RHBAPL

VE

- 001, 2010. The sample material resembled a coarse dust and was the only item in the HIP. Bettis Laboratory and BAPL

- CCP personnel performed and documented VE comprehensively for HIP 41

- 33. VE was also performed when each HIP was placed in a 55

- gallon drum for final disposal. EPA examined records generated for these two events and determined that both had been generated in accordance with procedure requirements and were technically adequate. Data sheets were completed and signed as required, and reviews by the ITR and SPM were adequately performed and appropriately recorded. There were no concerns relative to the characterization of WMPs and prohibited items.
(3) Documentation of VE activities was examined and found to be adequate.

EPA reviewed BD R No. RHBAPLVE100001 containing VE data for the HIP containers examined during this campaign. WMP weights were not assigned during VE of RH waste because all waste items are reported into the WIPP Waste Information System/Waste Data System as “plastic.” Wa ste item categories were identified, for example, “cellulosics” (C) and “other metal” (OM), and recorded on the VE data sheets. Table 2 of CCP

- TP

- 500 provides a complete listing of WMPs. A listing of prohibited items is provided in Table 1 of the procedure and the absence/presence of these items was recorded on VE data sheets. No prohibited items were identified during VE of the subject HIPs. There were no concerns relative to the documentation of VE activities.
(4) Training of VE personnel was adequate.

The two BAPL

- CCP VE Operators, Tommy Mojica and Spencer Pattee, were listed on the current CCP LOQI and training records for both indicated that they were current on all VE and all other required training. Summary of VE Findings and Concerns

The EPA team did not identify any findings or concerns related to VE during this baseline inspection. Proposed Baseline Approval EPA is proposing to approve the VE process for RH TRU Waste Stream BT

- T001 as observed at Bettis Laboratory and as documented in the VE BDR N o. RHBAPLVE100001 evaluated for this baseline inspection.

9.0 RESPONSE TO COMMENTS This section is reserved for responses to public comments.33 10.0 SUMMARY OF RESULTS

10.1 Environmental Protection Agency Findings and Concerns

The one finding identified during thi s inspection related to the waste characterization processes BAPL

- CCP implemented to characterize RH TRU debris waste. A copy of the EPA Inspection Issue Tracking Form that captures the finding is included in Attachment C of this report. The documents BAPL

- CCP/CBFO submitted to address the finding are included or summarized in Attachment D. The specific AK and radiological characterization items from the finding and relevant BAPL

- CCP responses are discussed in the preceding sections of this report. The EPA inspection team completed their review of the freeze files or revised documents and determined that they adequately addressed all aspects of the finding ; EPA considers th e finding to be closed. No BAPL

- CCP EPA issues related to this inspection remain open at this time. As stated in Section 1.0 of this report, BAPL

- CCP must provide to EPA all relevant AK and radiological characterization documents that required revisions reflected in various freeze files that EPA received as a response to the finding and r eviewed for technical adequacy before the end of the public comment period for the proposed approval of the BAPL

- CCP RH waste characterization program.

10.2 Conclusions This proposed approval is based on EPA’s baseline inspection conducted on four occasions: at the EPA ORIA offices in Washington, D.C. on April 12 through 13, 2011; and at Bettis Laboratory to observe the VE process on August 30, 2010, sample collection on September 23, 2010, and DTC measurements on December 8, 2010 . EPA determined that the BAPL

- CCP RH waste characterization program is technically adequate. EPA, therefore, is proposing to approve the BAPL

- CCP RH waste characterization program for RH Waste Stream BT

- T001 that was evaluated during this baseline inspection, as described and document ed in this report. The proposed approval includes the following:
(1) The AK process for BAPL

- CCP RH TRU debris Waste Stream BT

- T001 (2) The radiological characterization process using DTC and radionuclide scaling factors for assigning radionuclide values to Waste Stream BT

- T001, as documented in CCP

- AK

- BAPL

- 501 , Revision 1 , and supporting calculation packages detailed in this report (3) The VE process to identify WMPs and the physical form of the waste
This proposed approval is limited to the 15 HIPs of RH TRU debris wastes from Bettis Laboratory Waste Stream BT

- T001 . Wastes other than these are excluded from this proposed approval. Characterization of any additional RH wastes by BAPL

- CCP will require a new baseline inspection and approval.34 11.0 REFERENCES U.S. Departmen t of Energy, Carlsbad Field Office, “Contact

- Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant (CH

- WAC),” Revision 3, DOE/WIPP

- 02

- 3122, Carlsbad, New Mexico, April 25, 2005. U.S. Environmental Protection Agency, “Criteria f or the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. U.S. Code of Federal Regulation s, Title 40 , Protection of Environment , Part 191, “Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High

- Level and Transuranic Radioactive Wastes.” U.S. Code of Federal Regulations, Title 40 , Protection of En vironment , Part 194, “Criteria for the Certification and Re

- Certification of the Waste Isolation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.” U.S. Department of Energy, Office of Environmental Management, “Radioactive Waste Man agement Manual,” DOE M435.1

- 1, July 9, 1991, Change 1: June 19, 2001. U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste Characterization Program Implementation Plan,” DOE/WIPP

- 02

- 3214, Revision 0D, Carlsbad, New Mexico, October 3 0, 2003. U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the Waste Isolation Pilot Plant, DOE/CAO 1996

- 2184, Carlsbad, New Mexico, 1996. U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C, Complia nce Recertification Application 2004, DOE/WIPP/2004

- 3231. U.S. Nuclear Regulatory Commission, “Contact

- Handled Transuranic Waste Authorized Methods for Payload Control (CH

- TRAMPAC). U.S. Department of Energy, Carlsbad Field Office, “Quality Assurance Pro gram Document (QAPD),” DOE/CBFO

- 94

- 1012, Revision 11 , Carlsbad, New Mexico, June 2010.A

- 1 ATTACHMENT A : DOCUMENTS REVIEWED ACMM 3200, Preparation/Separation Logbook, pages ALD

- 1380

- 32, 33 & 37 ALD 10052I, Radiochemical Analysis Data Report, Revision 0, Jan uary 13, 2011 ALD 10052L, Radiochemical Analysis Data Report, Revision 0, February 14, 2011
ALD 10053I, ICP

- MS Isotopic Data Report Narrative, Revision 0, January 13, 2011 ALD 10054A, Actinides by Alpha Spectrometry, Radiochemical Analysis Data Report a nd Narrative, Revision 0, January 20, 2011

CCP

- AK

- BAPL

- 500 , Central Characterization Project Acceptable Knowledge Summary Report for Bettis Laboratory Remote

- Handled Transuranic Debris Waste, Waste Stream: BT

- T001, Revision 1 , January 25, 2011

CCP

- AK

- BAP L

- 500 , Central Characterization Project Acceptable Knowledge Summary Report for Bettis Laboratory Remote

- Handled Transuranic Debris Waste, Waste Stream: BT

- T001, Revision 2, May 16, 2011

CCP

- AK

- BAPL

- 501 , Central Characterization Project Remote

- Handled Tra nsuranic Radiological Characterization Technical Report for Bettis Atomic Power Laboratory Remote

Handled Transuranic Fuel Debris Waste, Waste Stream: BT

- T001, Revision 0, March 29, 2011

CCP

- AK

- BAPL

- 501 , Central Characterization Project Remote

- Handled Tra nsuranic Radiological Characterization Technical Report for Bettis Atomic Power Laboratory Remote

Handled Transuranic Fuel Debris Waste, Waste Stream: BT

- T001, Revision 1

CCP

- AK

- BAPL

- 502, Central Characterization Project RH TRU Waste Certification Plan fo r 40 CFR Part 194 Compliance and Confirmation Test Plan for Bettis Laboratory Waste Stream: BT

T001, Revision 0 , March 10, 2011

CCP

- AK

- BAPL

- 502, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmati on Test Plan for Bettis Laboratory Waste Stream: BT

T001, Revision 1

CCP

- AK

- BAPL

- 505A, Sampling and Analysis Plan for Bettis Atomic Power Laboratory Remote

- Handled Transuranic Debris Waste, Waste Stream BI

- T001, Revision 0, August 27, 2010

CCP

- QP

- 002, Tr aining an d Qualification Plan, Revision 30 , December 29, 2010

CCP

- QP

- 005, TRU Nonconforming Item Reporting and Control, Revision 19, October 14 , 2 010

CCP

- QP

- 008, Records Management, Revision 18, March 30 , 20 11A

- 2 CCP

- TP

- 005 , Attachment 4, Acceptable Knowled ge Source Document Reference List, October 29, 2010

CCP

- TP

- 005, Attachment 4, Acceptable Knowledge Source Document Reference List, April 27, 2010

CCP

- TP

- 005, Attachment 6 , Waste Form, Waste Material Parameters, Prohibited Items, and Packaging , December 2 , 2010

CCP

- TP

- 005, Attachment 8 , Waste Containers, Revision 1, January 27, 2011

C CP

- TP

- 500 , Revision 10, CCP Remote

- Handled Waste Visual Examination, December 29, 2010

CCP

- TP

- 512, CCP Remote

- Handled Waste Sampling, Revision 4, December 29 , 2010

Charac terization Reconciliation Report for Waste Stream BT

- T001, Draft for Audit Purposes, P rovided April 4, 2011 and May 3, 2011

DTC BDR No. BAPLRHDTC11001

ICP

- MS

- 3 Standard Preparation Record, pages ALD 1301

- 38 to 43

Inter

- Office Correspondence, from C. M. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report, Bettis Atomic Power Laboratory, Waste Stream BT

- T001 , Lot 1, For Audit Purposes Only, March 26 , 2011 List of currently qualified VE personne l (LOQI), January 26, 2011 Memorandum: Analysis of S ample Data for Bettis Atomic Power Laboratory (BAPL), Waste Stream BT

- T001, J. Holderness, February 14, 2011
Qualification card s and training records for VE operators/ITRs Raw data, analytical batch 101093 Sampling BDR Nos. BARH1001, BARH1002, and BARH 1003 Training documentation, Qualification Cards and Site

- Specific RH Training for J. Luginbyhl and I. Quintana, provided March 30, 2011 and March 25, 2011

VE BDR No. RHBAPLVE100001

WCPIP Revision 0D , Attachment 4

- Waste Stream Profile Form, Waste Stre am BT

- T001 , Draft for Audit Purposes, Provided April 4, 2011A

- 3 C213, Letter to W. Vitvitsky; RE: Radionuclide Distribution for East and West Cell Banks, M.W. Weisfield, WAPD

- MT(CER)

- 2792, May 27, 1994 P100, The United States Naval Nuclear Propulsion Progra m, Naval Reactors, July 31, 1998 P102, Cultural Resource Assessment Bettis Atomic Power Laboratory, Allegheny County. Pennsylvania, Christine E. Davis, May 1, 2002 P103, The Design and Construction of the Enlarged Westinghouse Hot Laboratory, A.L. Mahara m, WAPD

- T

- 442, March 1, 1957 P104, Light Water Breeder Reactor (LWBR), BET

- 10

- U, May 28, 19 7 5 P107, Preparation of Metallographic Specimens, R.G. Pleifer, MEL(T)1

- 2, Revision 1, January 15, 1985 P108, Pressure Mounting of Fuel Rod Specimens, Ronald Mink us, MELT 2

- 3, March 3, 1980 P112, Sectioning Specimens on the Slow Speed Abrasive Cut Off Wheel, M.J. Hill, MEL(T) 2

- 6, Revision 11, April 16, 1986 P113, Sectioning Specimens on the Precision Cut

- Off Wheel, W. Vitvitsky, MEL (T) 3

- 6, Revision 6, June 18, 1987 P120, Procedure for Decontaminating Items in the 10KW Ultrasonic Cleaner, L.M. Behr, HLP No 29, Revision 1, June 13, 1967
P121, APAC Dec rudding of Irradiated Specimens, V.J. Figliolia, HLP #22, Revision 3, July 31, 1974
P127, Alpha Cell Waste Nucl ide Distribution, R. Pfeifer, Work Request 20001430, Revision 0, July 10, 200 1 P129, Repackaging of MEL TRU Waste Material, R. Pleiler, HLP

- 433 RCE# 2005

- 781

- MEL, Revision 0, December 14, 2005 U201, News Release: Bettis Atomic Power Laboratory Celebrates 50th Anniversary, B.J. Schramm, BET

- 3

- U U207, Hot Lab and Alpha Facility Floor Plan Drawings U209, Phase I of the Metallographic Process for the East Cell Bank U211, Bettis Irradiation Test Planning Guide, Irradiation Material Technology, WAPD

- MT(I)

- 24 4, Revision 3, August 1989A

- 4 U212, Operation Record of Met Cell Equivalent Gram Loss, Book #2 and #3, March 3, 1982 through November 11, 1986 U213, Grinding Equivalent Gram Loss Logbook No.1, Book #1, February 1977 through February 1981
U214, Book #1 Ultr asonic Cleaning Logbook, Various, Book 1, March 12, 1975
U220, Technical Work Record No. 70084

- Depletion Reviews, Terry Carper, TWR 70094, May 1995 U231, Sludge Information Data Sheet, W.G. Smert, March 18, 1993 U236, COW Logbook #2, Waste Disposal Lo g, COW #2, January 1973 through November 1979 U241, Specimens Which Contributed to Sludge Activity, February 29, 1992 U243, Miscellaneous Maps of Bettis, MEL Floor Plans and Photos
U245, Attachment 1, HIP

- 41 Container Packaging Data Log, HLP 433 Attachm ent 1, Revision 0, December 2005 through January 2006
U251, Technical Work Record 12314, M.W. Weisfield, TWR 12314, January 8, 1981 U252, Logbook #2 for Fuel Crush Etching CLAD Rinse, M. Monico, August 17, 1979 U253, List of Samples in AC

- 93

- 1 to AC93

- 7
U254, Route Card G492, Specimens f or Fission Gas Sampling, R. Mallory, G

- 492, March 8, 1982 U256, Bettis Experimental Facilities, Bettis Hot Laboratory, November 1978
U259, Containers

- HIPs and Waste Cans, A pril 6, 1992
U260, Route Card G

- 502, Fuel Spe cimens from alt clad R.B. Trans #1, G.J. Powell, G

- 502, September 29, 1982 U261, Route Card G503, Fuel Specimens from Type 6 Transient #1, G.J. Powell, G503, September 29, 1982
U262, Route Card GS18 , Transverse MET Sections in Most Severe Overload Region s, G.J. Powell, G518, April 26, 1983 U264, Personnel Interview with Ron Minkus and Ron Pfeifer, J.W. Luginbyhl, March 10, 2010A

- 5 U267, Technical Work Record 23070, HIP Contents Examination, S.P. Ruzicka, TWR 2 3070, December 2, 2009
U269, Visual Exam of HI Ps
U270, HIP Material Parameters U350, Sample Data Input Check, J. Vance, BAPL

- RH

- 01, Revision 0, March 18, 2011 U351, Scaling Factor Development, J. Vance, BAPL

- RH

- 02, Revision 1, April 18, 2011

U352 , Uncertainty Analysis, J. Vance, BAPL

- RH

- 03 , Revisi on 1, April 18, 2011 U353, Evaluation of Radionuclide Reporting Requirements, J. Vance, BAPL

- RH

- 04, Revision 0, March 18, 2011
U354, DTC Derivation for Cs

- 137, J. Vance, BAPL

- RH

- 05, Revision 1, April 18, 2011 U355, DTC Spreadsheet, J. Vance, BAPL

- RH

- 06, Revision 1, April 18, 2011
U356, Calculation of Drum Surface Dose Rate, J. Vance, BAPL

- RH

- 07, Revision 1, April 18, 2011 U390, Response to EPA Finding, Jene Vance, April 22, 2011 U396, Technical Work Record 23219: Memo from BAPL re: TWR 23120 Completio n Date (for drum splitting operations), BAPL, 23219, April 20, 2011 U397, Technical Work Record re: Splitting of MEL East Transuranic Waste in HIP

- 41

- 06 into Additional C ontainers, BAPL, 23120, August 3, 2010
U398, Technical Work Record 23008; RE: Fuel T ype in MEL TRU Material, R. Pfeifer, TWR 23008, April 15, 2011 U399, Fuel Type Relative Contribution to the HIPs, J. Vance, BAPL

- RH

- 08, Revision 0, April 18, 2011B

- 1 ATTACHMENT B: PERSONNEL CONTACTED DURING INSPECTION

Personnel Name Affiliation Area of Ex pertise, Function VE Sampling DTC EPA HQ Edward Feltcorn U.S. EPA ORIA Inspection Team Leader    Rajani Joglekar U.S. EPA ORIA Inspection Team  Lindsey Bender U.S. EPA ORIA Inspection Team    Connie Walker SC&A Inspection Team, AK 

Kir a Darlow SC&A Inspection Team, AK  Dorothy Gill SC&A Inspection Team, VE  Rose Gogliotti SC&A Inspection Team, RC  Patrick Kelly SC&A Inspection Team, RC     Amir Mobasheran SC&A Inspection Team, RC 
S. Corey Boland CCP DTC Lead  J ustin Breauchy BMPC

- Bettis Manager Nuclear Production 
Michael Brown BMPC

- Bettis Site Technical Representative

- Manager MEL Project    

D onna Di Renna BMPC

- Bettis Environmental Controls Environmental Safety and Health  
Jason DiVecchio BMPC

- Bettis Manager Design Nuclear Engineering 

Mark Doherty CCP

- TechSpecs AKE  Marvin Garrett BMPC

- Bettis Manager Radiological Controls  Paul C. Gomez CBFO/CTAC STL

– Technical Specialist 

Dan Hagerty BMPC

- Bettis ESH Director  Jim Holderness WTS

- CCP Radiological Characterization 

R obert Kebe BMPC

- Bettis Manager Environmental Controls  Kelly Kopchinsky NRLFO

- Pittsburgh Environmental Safety Health and Radcon  John Koury NRLFO

- Pittsburgh Assistant Manager for Operations  Chris Labee NRLFO

- Pittsburgh Environmental Safety Health and Radcon     Jim Luginbyhl LANL

- CCP BAPL

- CCP AKE  Todd McIntyre NRLFO

- Pittsburgh Environmental Safety Health and Radcon 

Bill Mihalco BMPC

- Bettis Manager Environmen tal Engineering  Tommy Mojica CCP

- WTS VPM CEE HSGS  J eremy Molitoris BMPC

- Bettis Manager Nuclear Engineering  

Tom Morgan DOE CBFO Observer     P aul Moritzky NRLFO

- Pittsburgh Environmental Safety Health and Radcon   Todd Munther DO E FO FA Program Director 

Jim Oliver DOE/CBFO

- CTAC Observer   Spencer Pattee WTS

- CCP VE HSG Operator 

D.K. Ploetz WTS

- CCP CCP Manager  Irene Quintana WTS

- CCP SPM    

David Riley BMPC

- Bettis Manager Nuclear Engineering and Operation s   Michael Sensibaugh WTS

- CCP CCP Projects Manager  Jene Vance WTS

- CCP Radiological Characterization   Louis Wade WTS

- CCP CCP

- QAE  Lisa Watson LANL

- CCP AKE C

- 1 ATTACHMENT C : EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. BAPL

- CCP

- RH

- AK

- 11

- 01F
Inspection No. EPA

- BAPL

- CCP

- RH

- 04.11

- 8 Issue Number: BAPL

- CCP

- RH

- AK

- 11

- 01F Date: April 13, 2011

- Final Inspector: Kira Darlow Attachments? YES NO Sample Size: 5 Population size (if known): 15 Description of Issue: BAPL

- CCP used AK source document U259 to develop a comprehensive separation of waste materials into categories (bins). Separating the HIPs into bins (binning) was based on identifying common radiological attributes based on AK and was the foundation for the development of radionuclide

- specific scaling factors. It was assumed that source document U259 contained a complete record of the fuel specimens packaged in each HIP but this was found to not be the case. EPA identified three instances where sampl e containers (Dolly Tubes and/or cans) were excluded. EPA finds that the less

- than

- comprehensive binning of sample materials could compromise the technical basis of scaling factor development. EPA requires that BAPL

- CCP do the following:

**•** Confirm that issu e identified by the EPA Inspection Team is valid

**•** Bound the extent of the issue and present documentation that the contents of all 15 HIPs have been reviewed and that all are, in fact, appropriately accounted for

**•** Identify the impact of this issue on the cha racterization process

**•** Identify all Bettis Laboratory CCP documents (e.g., CCP

- AK

- BAPL

- 500, CCP

- AK

- BAPL

501, calculation packages, and Batch Data Reports) that do and do not require revision and a justification of these decisions

**•** Provide a written response documenting the results of BAPL

- CCP’s impact analysis and include this as a source document, including a table(s) comparing the association of all waste materials and HIPs before and after BAPL

- CCP addresses this issue

**•** Complete document revisions and provi de revised documents to EPA for review
B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: J. Vance, J. Holderness, M. Brown, C. Labee, M. Sensibaugh, I. Quintana, M. Doherty, and J. Luginbyhl E. Addi tional Comments: None

F. Site Response Information: Site Response Required? YES NO Site Response Due Date: 4

- 22

- 11D

- 1 ATTACHMENT D: CCP RESPONSE TO EPA’ S ISSUE BAPL

- CCP

- RH

- AK

- 11

- 01F

Identification of Issue

As disc ussed i n the Radiological Characterization Technical Report prepared for the EPA baseline inspection for the Bettis Atomic Power Laboratory RH TRU waste stream BT

- T001 , nine of the 15 high

- pressure containers (HIPs) containing the fuel examination debris w aste were sampled and 6 were not. It was expected that the HIPs that were not sample d would have a similar radionuclide distribution to a nother HIP that was sample d if the relative contribution of the fuel types to the two HIPs were nearly equal. According ly, the AK records were reviewed to identify the fuel type of each fuel specimen that had contributed to the waste within a given HIP. Specifically , the AK Source Document U259 was used to extract the fuel type information. The number of specimens of a giv en fuel type in each HIP were counted and entered into a spreadsheet. The relative contributions of the fuel types were then calculated as a basis for the binning. In the inspection it was determined that the AK record showing the listing of the specimens contributing to the HIPs was not complete. Specifically, the fuel specimens associated with five Dolly Tubes and two cans were potentially omitted from the specimen listing. The containers of fuel debris waste that were potentially missing from the specim en listing are as follows:

HIP Number Container 41

- 20 AF

- 1, AF

- 2, AF

- 3 and AF

- 4 (all Dolly Tubes) 41

- 23 Can M042 41

- 32 Can M043 41

- 33 Dolly Tube DC11

Confirmation and Extent of the Issue
It was confirmed that, with the exception of can M04 3, the AK records show these containers as being added to the identified HIPs. This is shown on the following extract which is the first page from AK Source Document U259 showing the containers and Dolly Tubes added to the HIPs.D

- 2 A Technical Work Record (AK Source Document U398 ) from Bettis subsequently determined that the material from can M043 had been placed into Dolly Tubes SL37 through SL81 which are accounted for in the above HIP loadings. This, in effect, eliminates can M043 as a contributing sour ce to the HIPs. The Dolly Tubes that contained the material from can M043were added to HIPs 41

- 21 (SL37 through SL58) and 41

- 32 (SL59 through SL81). The 22 fuel specimens that contributed to the 23 Dolly Tubes that were added to HIP 41

- 32 were already acco unted for in the original binning. Further investigation showed that the Dolly Tubes AF

- 1 through AF

- 4 contained fuel debris waste predominantly from thorium fuels specimens. (AK Source Document Number U231 ) The original fuelD

- 3 type contributions to HIP 41

- 2 0 indicated all enriched uranium and no thorium fuel. With the inclusion of the omitted thorium fuel type, the fuel type contributions would be altered to the extent that HIP 41

- 20 would no longer be representative of HIP 41

- 23, which the records indicate is all enriched uranium. It should be noted that HIP 41

- 20 was sampled and consequently the presence of thorium fuels was accounted for in the sample results. However, it would be necessary to associate HIP 41

- 23 with another HIP that is predominantly enri ched uranium. HIP 41

- 05 was identified as a suitable replacement for HIP 41

- 20 in the binning process. HIP 41

- 05 contains fuel debris waste from 96% enriched uranium specimens and only 4% thorium fuel specimens which would have a small effect on the overal l radionuclide distribution in the HIP. The investigation into grinding loss records (AK Source Document Number U212 ) for can M042 uncovered information showing the specific fuel specimens and associated fuel types contributing to the debris in this can. A total of 91 fuel specimens were included in this can, all of which were enriched uranium. This was confirmed by Bettis in a Technical Work Record dated 4/15/11. (AK Source Document Number U398 ) This did not alter the original fuel type contribution, whic h was already 100% enriched uranium. Records identifying the specific fuel specimens and associated fuel types could not be located for Dolly Tube DC11. However, Dolly Tube DC11 is just one of 19 Dolly Tubes added to HIP 41

- 33. Accordingly, the impact on the fuel type contributions from a single Dolly Tube would be small.
Impact of Issue on Characterization Process
Overall, the impact on the binning process described in the Radiological Technical Report to associate the non

- sampled HIPs with the sampled HIPs by the fuel type contributions requires only one change to that described in the report. Namely, HIP41

- 23 has now been associated with HIP 41

- 05 rather than HIP 41

- 20 as was done in the original binning. The result of the binning effort provided in t he RCTR is shown below:
Sampled Enriched Uranium and Thorium Thorium Enriched Uranium Depleted Uranium and Plutonium HIP

- 41

- 13 No 67% 0% 33% 0% HIP

- 41

- 21 No 40% 10% 50% 0% HIP

- 41

- 32 Yes 68% 5% 27% 0%

HIP

- 41

- 20 Yes 0% 0% 100% 0% HIP

- 41

- 23 No 0 % 0% 100% 0%

HIP

- 41

- 24 No 16% 0% 68% 16% HIP

- 41

- 28 No 9% 0% 75% 16% HIP

- 41

- 33 Yes 14% 0% 62% 24%

HIP

- 41

- 18 Yes 14% 0% 86% 0% HIP

- 41

- 27 No 18% 0% 82% 0%D

- 4 The final binning resulting from the omission is shown below:
Sampled U

- 233 and Th orium Enriched Uranium and Thorium Thorium Enriched Uranium Depleted Uranium and Plutonium HIP

- 41

- 13 No 0% 67% 0% 33% 0% HIP

- 41

- 21 No 0% 40% 10% 50% 0% HIP

- 41

- 32 Yes 0% 68% 5% 27% 0%

HIP

- 41

- 05 Yes 0% 2% 2% 96% 0% HIP

- 41

- 23 No 0% 0% 0% 100% 0%

HIP

- 41

- 24 No 3% 16% 0% 68% 16% HIP

- 41

- 28 No 0% 9% 0% 75% 16% HIP

- 41

- 33 Yes 0% 14% 0% 62% 24%

HIP

- 41

- 18 Yes 2% 14% 0% 8 5 % 0% HIP

- 41

- 27 No 0% 18% 0% 82% 0%
The binning process is further described in Calculation BAPL

- RH

- 08 , which has been generated to support th is response to the EPA finding.

Identification of CCP

- BAPL Documents Revised and Non

- Revised
The documents that have been revised as a result of this finding are:

CCP

- AK

- BAPL

- 500 (Revision in process

– summary of changes in attached file “Response to EPA Finding) CCP

- AK

- BAPL

- 501 (Revision in process

– summary of changes in attached file “Response to EPA Finding) BAPLRHDTC11001 Calculation BAPL

- RH

- 02 Rev. 1 Calculation BAPL

- RH

- 03 Rev. 1 Calculation BAPL

- RH

- 06 Rev. 1 Draft CR R

– correction to TRU Alpha Activity Concentration and Total Activity Determination for HIP41

- 23

- 4 were updated based on the reassigned scaling factor. The surface dose rates have not been publicly released based on the reassignment of the scaling factor f or this HIP and the values are not included. CCP

- TP

- 005 Attachment 4 updated to reflect newly referenced AK source documents. The documents that have not been revised as a result of this finding are:D

- 5 Calculation BAPL

- RH

- 01, Radiochemistry and Mass Spectr ometry Data Input Check. The binning process does not change the analysis data reported for the sampled HIPs.

Calculation BAPL

- RH

- 04, Determination of Reportable Radionuclides. The scaling factors were used to evaluate the relative contribution of the ind ividual radionuclides to the radiological hazard. The scaling factors were not changed for the 15 HIPs.

AK Source documents referenced in CCP

- AK

- BAPL

- 500 were not changed due to this finding as the records were provided from Bettis. Draft AK Accuracy Rep ort has not changed as the containers were not reassigned to a new summary category group nor did any containers failed to meet the Data Quality Objectives. The Radiochemistry and RH Waste Sampling BDRs were not changed due to this finding as the scaling factor for HIP41

- 23

- 4 was reassigned and this HIP was not sampled.

RHBAPLVE100001

– the visual examination characterization data were not changed as the containers met the RH VE quality assurance objectives.

CCP

- AK

- BAPL

- 502

– the characterization approac h for waste stream BT

- T001 did not change as a result of this finding. Additional documentation included to support revision to CCP

- AK

- BAPL

- 500 includes source documents U396 and U397. Additional documentation included to support revision to CCP

- AK

- BAPL

- 501 includes BAPL

- RH

- 05 Rev. 1 BAPL

- RH

- 07 Rev.1, and BAPL

- RH

- 08. BAPL

- RH

- 08 was prepared to document the binning of the various fuel types contributing to the waste in each of the 15 HIPS to determine the relative contribution of each fuel type in the HIPs

. Waste Material Parameters was calculated.

HIP41

- 15 RESEARCH RESULTS Research through the AK records for HIP

- 41

- 15 revealed that reference to 97

- 7L in source document U259 is a typographical error. The correct number is 93

- 7L and is supported by source documents P129, page 15; U259 page 1; U259 page 46; and U220 page 6. Page numbers are referencing the pagination at the bottom of each page of the document. The traceability of HIP

- 15 uses the route card in U260 to go back to the generation of the waste fo r the fuel types.