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 Avenue, NW

Washington, DC 20460

May 2011
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TABLE OF 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 of 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 Characterization............................................................................... 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......................................................................................................................... 34
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ATTACHMENTS

Attachment A: Documents Reviewed During the Baseline Inspection

Attachment B: Inspection Personnel List

Attachment C: EPA Inspection Issue Tracking 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/cm3 ..................... 28
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ACRONYMS AND INITIALIZATIONS

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR 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

Ci 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 Uranium

EPA U.S. Environmental Protection Agency

Eu europium

EU Enriched Uranium

FR Federal Register

g gram or grams

g/cm3 grams per cubic centimeter

HLW high-level waste

HIP high pressure container
iv

in inch or inches

ICP-MS Inductively Coupled Plasma-Mass Spectrometry

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 Carlo 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

mrem/hr millirem per hour

MT Material Types

nCi/g nanocurie per gram

NCR non-conformance 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

QAO 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 strontium
v

T1 Tier 1

T2 Tier 2

Th thorium

TMU Total Measurement Uncertainty

TRU transuranic

U uranium

VE visual examination

WCPIP Waste Characterization Program Implementation Plan

WIPP Waste Isolation Pilot Plant

WMP waste material parameter

WSPF Waste Stream Profile Form
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1.0 EXECUTIVE SUMMARY

This report discusses the U.S. Environmental Protection 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 characterization 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-BAPLCCP-RH-04.11-8 of the CCP’s waste 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: observation of the Visual Examination (VE) process on 

August 30, 2010, sample collection on September 23, 2010, and dose-to-curie (DTC) 

measurements on December 8, 2010 at Bettis Laboratory and the baseline inspection 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 generated 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 Stream 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 

radiochemical 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 one finding related to both the AK and radiological 

characterization processes that BAPL-CCP implemented to characterize RH Waste Stream BTT001 (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 program was technically adequate and appropriately documented.

In several cases, EPA reviewed the modifications to specific documents in the form of freezefiles1

 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 control 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 

documents 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, Revision 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 Bettis 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 (including 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 

characterization 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 report. 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 values to Waste Stream BT-T001 that is documented in CCP-AK-BAPL501, 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, EPA’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 basis. 

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 HIPs 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 this 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 

characterization components covered by this approval. Approval of any future or other past RH 
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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 INSPECTIONS

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)] for 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 applicable conditions and limitations, can adequately characterize TRU wastes 

and comply with the regulatory requirements imposed on TRU wastes destined for disposal at

the WIPP. An EPA inspection team conducts an on-site inspection to verify that the site’s system 

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 the 

WIPP Compliance Certification Application. 

Any compliance application shall: . . . Provide information which demonstrates 

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 described 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 certification 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 limiting 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 may 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 waste 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 measurement 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 REPORT

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 systems 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 elements. 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 characterization processes govern the scope of 

EPA’s inspection.
5

Manager, National TRU Program

Carlsbad Field Office

U.S. Department 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 proposed 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 Baseline 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-tracked 

radionuclides [americium-241 (241Am), cesium-137 (137Cs), plutonium-238 (238Pu), 239Pu, 

240Pu, 242Pu, strontium-90 (90Sr), uranium-233 (233U), 234U, and 238U] and other TRU 

radionuclides using a combination of AK and DTC with the application of radionuclidespecific 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 evaluated, 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 Laboratory 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 waste 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 waste 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, EPA 

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 WCPIP to 

adequately address RH waste characterization activities and 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 Laboratory 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 their 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 may 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 INSPECTION

7.1 Bettis Laboratory Background 

The Bettis Laboratory is located in West Mifflin, Pennsylvania, 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 (References 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 commercial programs including research and testing associated with 

the U.S. naval 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 cell banks: 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 were ultimately 
7

stored in the East Cell Bank and these 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 with 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 specimens; 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 swarf5 which ultimately became BAPL-CCP Waste Stream BT-T001. 

Waste Details

The EU, EU + Th, Th, 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 derived from the activities described above, and Bettis Laboratory 

radiation surveys indicated surface dose rates6

 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 final 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 and dispersed 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 specimens [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 

designed 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 the 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 criterion 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) Obtaining 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 personnel 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) Evaluating 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 Attachment 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 BAPL-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 technical 
9

information had to undergo the Public Utterance process prior to release to EPA, including key 

documents that are typically provided to EPA well in advance of the inspection. While this is 

understandable, it added to the complexity of the inspection process particularly when BAPLCCP 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 

demonstrated compliance with 40 CFR 194.8 requirements for RH Waste Stream 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

• Verification 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 characterization methodology, including radiological and physical 

composition of the waste and 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) 

• Correlation 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 objectives (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 inspection. 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 BAPLRHDTC11001 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 BTT001 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 activities 

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, or 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 several 

different activities in the MEL cell banks contributed to the waste stream. The Radiological 
11

Characterization Report (CCP-AK-BAPL-501) states that the radiological compositions of 

individual HIPs are distinct, and can be grouped into at least five general 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-specific 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, clarifying that all activities were associated with fuel pin or sample testing that 

generated a total of 15 HIPs (e.g., References U214 and U243). The revised AKSR also clarified 

that wastes were initially collected in Dolly tubes8 or other containers [see Item (3)] and were 

ultimately repackaged into 15 HIPs. The 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 safety 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 of 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 Characterization 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 processes 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 adequate.

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 associate 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 memorandum (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 verified 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 

dimensions 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 the physical composition of the waste stream is adequately described.

EPA also found that the AKSR presented only a broad radiological composition that appeared to 

contradict 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 analysis 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 traceability 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 personnel and EPA 

formalized it as a finding on an EPA Inspection Issue Tracking Form as No. BAPL-CCP-RHAK-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 information 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 233U (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 groupings: 

• 233U + 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 with 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 233U 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. Accordingly, 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 does not alter the original fuel type contribution in HIP 41-

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

33 is composed predominantly of EU (Reference U398), so accounting for DC11 does not 

significantly alter the radiological composition of HIP 41-33. However, BAPL-CCP determined 

that due to inclusion of the omitted 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.

BAPL-CCP also identified an apparent 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 

Reference 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? 233U + Th EU + Th Th EU DU + Pu Combination1

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-41-062 Yes --- ---- ---- ---- ----- 100%

HIP-41-152 Yes --- ---- ---- ---- ----- 100%

HIP-41-16 Yes 0% 14% 0% 43% 43% ---

HIP-41-202,3 Yes --- ---- ---- ---- ----- 100%

HIP-41-30 Yes 0% 32% 0% 50% 18% ---

1

The HIP contents were assumed to be various combinations 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 generating processes were associated with water that could alter the 137Cs 

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 contents. 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 appropriate 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 within 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 radiological 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/cans10

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 BDRs RHBAPLVE100001, 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 available1 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 containers 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, 892

U259/U236

41-33-9 41-33 MS01 M022 (SL1-SL18) Met 11, 38, 39, 57, 88 U259

DC11 East 393 -

1

Fuel codes for M042 are not included in the source documents. Fuel specimen type is determinable 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 specimens 

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 the case. During the traceability 

evaluation, EPA identified three occasions where Dolly tubes and/or cans were excluded from 

U259. HIP 41-20 contains the contents of can M038 and Dolly tubes AF-1 through AF-4. The 

contents of M038 are listed in U259, but the 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 since BAPL-CCP had relied solely on source document U259 to 

develop the comprehensive separation 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 transferred 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 

identified 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 nuclear 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 M435.1-112

 12 DOE M435.1-1 is the Department of Energy’s Radioactive Waste Management Manual.

state that spent 

nuclear fuel is “fuel that has been withdrawn from a nuclear reactor following irradiation, the 

constituent elements of which have not been separated by reprocessing... [However,] test 

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

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

the requirements of this Order when it is technically infeasible, cost prohibitive, or would 
16

increase worker exposure to separate the remaining test specimens from other contaminated 

material.” 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 fission products in sufficient 

concentrations, and other highly radioactive material that the commission, consistent with 

existing law, determines by rule requires permanent isolation.” 

Waste Stream BT-T001 is composed of test residues, test materials, and the resultant test 

fragments from the fuel specimens, including irradiated fragments and dispersed particulate 

(fines and dust). Operations at the MEL did not include the separation or reprocessing of 

irradiated fuel elements withdrawn from a reactor. As a result, 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 adequately 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 information 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 Characterization 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, defense 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 the 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 support 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 Source Document Reference List (CCPTP-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 inspection 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 information. The Certification Plan describes the waste stream;

waste stream DQOs and Quality Assurance Objectives (QAOs); and how the waste stream will 

be characterized by sampling and analysis, DTC, and VE. The Certification Plan does not state 

that AK will be confirmed and, in fact, BAPL-CCP representatives indicated that while the site 

provided information allowing waste stream review and HIP radiological grouping [see Item 

(2)], the technical AK data necessary to develop scaling factors were not provided. Therefore, 

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 analysis, 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 required 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) Personnel 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 and 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 and CCP-AK-BAPL-501 in terms of the AK radiological composition of 

the waste was necessary; 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 

examined 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 nonhazardous. BAPL-CCP also provided three NCRs to EPA as part of this inspection. NCRRHBAPL-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 have an excessive dose rate and rejected in favor of a new 

sample. The dates for NCR-RHBAPL-0300-11 indicate that it 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-conforming 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 source 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 

documents being described at a higher level of classification 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 be 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 final 

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 through acceptable knowledge verification was 

evaluated and found to be acceptable.

As a result of the analysis presented in Items 1-15, above, EPA was able to assess how each

DQO will be addressed. The following DQOs must be addressed as per the WCPIP:
20

• Defense determination

• TRU waste determination

• RH waste determination

• Activity determination (total and activity per canister, including quantification and 

identification of the 10 EPA WIPP-tracked radionuclides)

• Residual liquids

• Physical form, including metals and cellulose, plastic, and rubber

When evaluated as a whole, CCP-AK-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 Acceptable Knowledge 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 included 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 Baseline 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 Description

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 BTT001 based on the following three sources of information:

• AK for Waste Stream BT-T001, as summarized in CCP-AK-BAPL-500 and associated 

source documents

• Radionuclide-specific laboratory results from the analysis of smear13

• Analyses of fuel types to develop scaling factors for 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 materials 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 BAPL-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 correlations for each drum at 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 137Cs and europium-154 (154Eu), 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 

remaining, 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 radiological 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 concluded 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 BAPL-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 correct, which resulted in the revision of several documents, the

DTC BDR, and the generation of a new calculation package (see Attachment D). EPA evaluated 
22

Figure 1. Flow Diagram for the Overall Characterization of Waste Stream BT-T001
23

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 Containers 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 BAPLCCP 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 categories 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 28 samples. The 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 analytical 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 comparability, 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 occurred 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 container 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 neck 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 the 
24

sample collection, including: 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 

sampling 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. Sammel, 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 read 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 executed. 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 perform 

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 every 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 Laboratory14 located at the Idaho National 

Laboratory in Idaho Fall, ID, 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 

evaluation 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 241Pu

• Chemical separation and Gas Flow Proportional counting for the determination of 90Sr

• Chemical separation and Alpha Spectrometry for the determination of 241Am, curium-244 

(

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

• Gamma Spectrometry for the determination of 154Eu and 137Cs

• Inductive coupled Plasma-Mass Spectrometry for the determination of 233U, 234U, 235U, 

236U, 238U, 239Pu, 240Pu, and 242Pu

 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 use 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 verification 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

• All 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, 101094, 

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 incorrect sample number was entered on CCP-TP512, 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) measurements reported positive 

values for 239Pu and 240Pu, which were determined by taking the average ratios of 239Pu/(239Pu + 

240Pu) and 240Pu/(239Pu + 240Pu) from the 13 samples where both isotopes were measured. These 

ratios were then multiplied by the 239Pu/240Pu ratio for each sample as determined by alpha 

spectrometry to derive their fractions as 0.412 for 239Pu and 0.588 for 240Pu. While not measured 

in any of the samples, the 241Pu value was conservatively estimated to be equal to the instrument 

detection limit (IDL) for 242Pu, 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 samples 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 sampled 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 containers 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 137Cs based on its solubility in water, 

which was used in some waste generating operations. This required adjustments to the scaling 

factors for HIPs 41-24 and 41-28. Scaling factors for a sampled (HIP 41-05) and nonsampled 
26

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 nonsampled HIPs.

Table 4. Bettis Scaling Factors for Two HIPs

Radionuclide

HIP 41-05

137Cs Scaling Factor,

Ci Radionuclide/Ci 137Cs

HIP 41-13

137Cs Scaling Factor,

Ci Radionuclide/Ci 137Cs

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 2.22E-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) Computer modeling to develop the dose-to-curie correlation was evaluated and was 

found 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 137Cs and 154Eu at 

a nominal density of 0.7 g/cm3 at an assumed fill height of 60% and yielded values in units of 

roentgen per hour per Ci of 137Cs and 154Eu (R/hr/Ci) [see Item (10), below]. There were no 

concerns regarding the technical 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: 233U, 234U, 235U, 238U, 238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 241Am, 244Cm, 

245Cm, 228Th, 90Sr, 90Y, 137Cs, 137mBa, and 154Eu. The radionuclides that were reported are 

summarized in Table 5. The application of the DTC correlations developed for 137Cs and 154Eu 

involved the partitioning of the average total dose rate measured into the contributions of each of 

these two gamma-emitters, and determining the 137Cs inventory in each drum to be multiplied by 

the scaling factors for sampled and nonsampled HIPs, as discussed in several areas of this 
27

section. There were no concerns regarding the technical adequacy of this modeling to develop 

DTC correlations.

Table 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 Uncertainty (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 added in quadrature.

15 The TMU determination included contributions of the 

following:

• 137Cs 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 239Pu 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

• 137Cs and 154Eu dose measurement uncertainty 

• Scaling factor uncertainty – including sample data uncertainty (except 242Pu)

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

• Uncertainty in the 242Pu 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, Section 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 summarized 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 Bettis-CCP Waste Stream BT-T001.

Table 6. Overall Uncertainty of Two HIPs at the Nominal Density of 0.7 g/cm3

Radionuclide

HIP 41-05

Total 137Cs 

Uncertainty

HIP 41-05

Total Scaling 

Factor 

Uncertainty

HIP 41-05

Total 

Uncertainty

HIP 41-13

Total 137CsUncertainty

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% 103.6% 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 adequate.

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 containing 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 

detector (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 in 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 Ranges for the Geiger 

Mueller Probes, and Acceptance Criteria for the Source Checks. 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 and 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 Contents, 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 revision 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 adequate.

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 configurations, 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 multipliers were then used by Bettis Laboratory to establish the waste’s 

classification as RH, as documented in the Bettis Laboratory Memorandum B-NEO(NE)DNE64E, 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 contained 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 

determinations 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 calculation 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 characterization 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 

CCP-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 activities, 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 approved 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 characterization:

• 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.

Technical 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.

The 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 for 

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

NEO-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 OLB RHBAPLVE-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 BDR 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.” Waste 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 No. 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 this 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 the 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 reviewed 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 documented 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. Department 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 for 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 Regulations, 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 Environment, 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 

Management 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 30, 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, Compliance 

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 Program 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, January 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 and 

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-BAPL-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 Transuranic 

Radiological Characterization Technical Report for Bettis Atomic Power Laboratory RemoteHandled Transuranic Fuel Debris Waste, Waste Stream: BT-T001, Revision 0, March 29, 2011

CCP-AK-BAPL-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Bettis Atomic Power Laboratory RemoteHandled 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: BTT001, Revision 0, March 10, 2011

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: BTT001, 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, Training and Qualification Plan, Revision 30, December 29, 2010

CCP-QP-005, TRU Nonconforming Item Reporting and Control, Revision 19, October 14, 2010

CCP-QP-008, Records Management, Revision 18, March 30, 2011
A-2

CCP-TP-005, Attachment 4, Acceptable Knowledge 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

CCP-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

Characterization Reconciliation Report for Waste Stream BT-T001, Draft for Audit Purposes, 

Provided 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 personnel (LOQI), January 26, 2011

Memorandum: Analysis of Sample Data for Bettis Atomic Power Laboratory (BAPL), Waste 

Stream BT-T001, J. Holderness, February 14, 2011

Qualification cards and training records for VE operators/ITRs

Raw data, analytical batch 101093

Sampling BDR Nos. BARH1001, BARH1002, and BARH1003

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 Stream BT-T001, Draft 

for Audit Purposes, Provided April 4, 2011
A-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 Program, 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. 

Maharam, WAPD-T-442, March 1, 1957

P104, Light Water Breeder Reactor (LWBR), BET-10-U, May 28, 1975

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 Minkus, 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 Decrudding of Irradiated Specimens, V.J. Figliolia, HLP #22, Revision 3, July 31, 

1974

P127, Alpha Cell Waste Nuclide Distribution, R. Pfeifer, Work Request 20001430, Revision 0, 

July 10, 2001

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)-

244, Revision 3, August 1989
A-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 Ultrasonic 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 Log, 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 Attachment 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 for 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, April 6, 1992

U260, Route Card G-502, Fuel Specimens 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 Regions, G.J. 

Powell, G518, April 26, 1983

U264, Personnel Interview with Ron Minkus and Ron Pfeifer, J.W. Luginbyhl, March 10, 2010
A-5

U267, Technical Work Record 23070, HIP Contents Examination, S.P. Ruzicka, TWR 23070, 

December 2, 2009

U269, Visual Exam of HIPs

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, Revision 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 Completion 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 Containers, BAPL, 23120, August 3, 2010

U398, Technical Work Record 23008; RE: Fuel Type 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, 2011
B-1

ATTACHMENT B: PERSONNEL CONTACTED DURING INSPECTION

Personnel Name Affiliation Area of Expertise, 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 

Kira 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 

Justin Breauchy BMPC-Bettis Manager Nuclear Production 

Michael Brown BMPC-Bettis Site Technical Representative - Manager 

MEL Project

   

Donna 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 

Robert 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 Environmental Engineering 

Tommy Mojica CCP-WTS VPM CEE HSGS 

Jeremy Molitoris BMPC-Bettis Manager Nuclear Engineering  

Tom Morgan DOE CBFO Observer    

Paul Moritzky NRLFO-Pittsburgh Environmental Safety Health and Radcon  

Todd Munther DOE 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 

Operations

 

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 sample 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 issue 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 characterization process

• Identify all Bettis Laboratory CCP documents (e.g., CCP-AK-BAPL-500, CCP-AK-BAPL501, 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 provide 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. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: 4-22-11
D-1

ATTACHMENT D: CCP RESPONSE TO EPA’S ISSUE BAPL-CCP-RH-AK-11-01F 

Identification of Issue

As discussed in 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 waste were sampled and 6 were 

not. It was expected that the HIPs that were not sampled would have a similar radionuclide distribution 

to another HIP that was sampled if the relative contribution of the fuel types to the two HIPs were 

nearly equal. Accordingly, 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 given 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 specimen 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 M043, 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 source 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 accounted 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 fuel 
D-3

type contributions to HIP 41-20 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 enriched 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 overall 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, which 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 the 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 

Thorium

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% 85% 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 this 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 CRR – 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 for 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 Spectrometry 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 individual 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 Report 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 approach 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 for the fuel types.