DOCKET NO: A-98-49, II-A4-163 

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

FOR IDAHO NATIONAL LABORATORY: 

ADDITION OF LOT 2 WASTE TO WASTE STREAM ID-ANLE-S5000 

 

May 8–9, 2012 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

July 2012
ii 

TABLE OF CONTENTS 

Section Page

1.0 Executive Summary ............................................................................................................ 1

2.0 Purpose of Tier 1 Evaluation .............................................................................................. 5

3.0 Purpose of This Report ....................................................................................................... 5

4.0 Scope of the Tier 1 Evaluation............................................................................................ 6

5.0 Evaluation Personnel .......................................................................................................... 6

6.0 Technical Evaluation .......................................................................................................... 8

6.1 Programmatic Requirements and Acceptable Knowledge ..................................... 9

6.2 Radiological Characterization ............................................................................... 23

6.3 Real-Time Radiography ........................................................................................ 33

7.0 Conclusions ....................................................................................................................... 35

TABLE OF TABLES 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP ........ 3

Table 2. Tier 1 Evaluation Personnel .............................................................................................. 7

Table 3. Characterization Methods for the Waste Stream ............................................................ 12

Table 4. Shipment, Storage and Repackaging Traceability Analysis for Canister No. ANLE33 19

Table 5. Correlation of Can and Repackaged Drum Contents, Canister No. ANLE33 ................ 20

Table 6. AK Training Qualification Summary ............................................................................. 21

TABLE OF FIGURES 

Figure 1. Flow Diagram of the Characterization Process: Scrap Materials from Debris Waste 

Stream ID-ANLE-S5000 ............................................................................................... 25

Figure 2. Flow Diagram of the Characterization Process: Recoverable and Nonrecoverable 

Fissile Material from Debris Waste Stream ID-ANLE-S5000 ...................................... 26

ATTACHMENTS 

Attachment A: Approval Summary for INL-CCP RH Waste Characterization Program 

Attachment B: List of Documents Reviewed 

Attachment C: EPA Inspection Issue Tracking Form 
iii 

ABBREVIATIONS AND ACRONYMS 

A/G numbers alpha/gamma numbers (AGHCF) 

AGHCF Alpha Gamma Hot Cell Facility 

AK acceptable knowledge 

AKE acceptable knowledge expert 

AKSR acceptable knowledge summary report 

ANL Argonne National Laboratory 

ANL-E Argonne National Laboratory–East 

ANL-W Argonne National Laboratory–West 

ATR Advanced Test Reactor 

Ba barium 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

Ce cerium 

CFR Code of Federal Regulations 

Ci curie 

Co cobalt 

CRR characterization reconciliation report 

Cs cesium 

CTAC Carlsbad Technical Assistance Contractor 

DCF dose conversion factor 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 

DTC dose-to-curie 

EPA U.S. Environmental Protection Agency 

g/cm3

 grams per cubic centimeter 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

ID Idaho 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 
iv 

ITR independent technical reviewer 

LANL Los Alamos National Laboratory 

LWA Waste Isolation Pilot Plant Land Withdrawal Act

MCNP5 Monte Carlo N-Particle Transport Code RSICC Computer Code Collection, 

Oak Ridge National Laboratory 

MFC Materials and Fuel Complex 

MFP mixed fission products 

mR/hr milliroentgen per hour 

mR/hr/Ci milliroentgen per hour per curie 

mrem/hr millirem per hour 

Na sodium 

NCR nonconformance report 

NWPA Nuclear Waste Policy Act 

ORIGEN Oak Ridge Isotope Generation and Depletion Code 

Pu plutonium 

QA quality assurance 

RH remote-handled 

RSWF Radioactive Scrap and Waste Facility 

RTR real-time radiography 

SNF spent nuclear fuel 

SPM site project manager 

Sr strontium 

SS special source 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRU transuranic 

U uranium 

VE visual examination 

WAP Waste Analysis Plan 

WCPIP Waste Characterization Program Implementation Plan 

WIPP Waste Isolation Pilot Plant 

WSPF waste stream profile form 

WTS Washington TRU Solutions 
v 

WWIS WIPP Waste Information System 

Y yttrium 
1 

1.0 EXECUTIVE SUMMARY 

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

Tier 1 (T1) approval of the radiological process for containers of retrievably stored, remotehandled (RH) high-gamma transuranic (TRU) fuel specimens and debris (S5000) waste 

generated at the U.S. Department of Energy’s (DOE’s) Argonne National Laboratory-East 

(ANL-E) and stored at DOE’s Idaho National Laboratory (INL). These Lot 2 wastes are 

proposed for addition to INL Waste Stream ID-ANLE-S5000. This report discusses EPA’s 

evaluation of the radiological characterization of Lot 2 waste drums along with a review of 

acceptable knowledge (AK) documentation and radiography. The results of EPA’s evaluation 

confirm that Lot 2 waste packaged in 55-gallon drums can be added to Waste Stream 

ID-ANLE-S5000. 

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

using the system of controls that EPA evaluated during the baseline inspection conducted in June 

2006 and approved in January 2007 (See EPA Report A-98-49: II-A4-72 in EPA Air Docket). A 

summary of EPA’s approvals of the INL-CCP RH TRU waste characterization program is 

included as Attachment A. The baseline approval was specific to a certain number of drums, and 

any addition of new drums (if new or different scaling factors are required) to the approved 

waste stream required that such approval be sought as a T1 change prior to disposal of the wastes 

at the Waste Isolation Pilot Plant (WIPP). 

EPA conducted this evaluation in two parts: the radiological characterization processes, 

including dose-to-curie (DTC), and the real-time radiography (RTR) were inspected at INL near 

Idaho Falls, Idaho, on May 8–9, 2012; the AK inspection was performed as a desktop review, 

with a telephone interview on May 4, 2012. 

On March 28, 2012, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change 

to implement the radiological characterization process for the Lot 2 waste from ANL-E as part of 

INL Waste Stream ID-ANLE-S5000. The Lot 2 wastes are divided into high-gamma TRU waste, 

including irradiated fuel pin test specimens and scraps, and trash debris associated with the 

processing of the high-gamma TRU waste. INL-CCP developed one set of scaling factors for all 

containers of the Lot 2 debris, also sometimes called “scrap” in the INL-CCP documentation, 

and developed individual scaling factors for each canister1

 containing high-gamma TRU waste, 

also sometimes called either “canister” or “high-gamma” waste. 

This approval applies only to Lot 2 waste characterized using the radionuclide scaling factors 

evaluated as part of this inspection. Addition of any other Lot 2 waste with a different pedigree 

and/or scaling factors to Waste Stream ID-ANLE-S5000 requires a new T1 change request and 

EPA approval. 

 

1

 The Lot 2 waste was stored at INL in 48 canisters. The canisters are approximately 9.25 inches in 

diameter and 71.75 inches in length, including the 8-inch-long steel plug. Each canister contains up to eight cans, 

and each can will be repackaged into a 55-gallon drum prior to characterization and shipment to the WIPP facility. 

The 55-gallon drum of repackaged waste is the item that will be emplaced in the WIPP. The exact number of drums 

that will result from canister repackaging will be determined in the future. 
2 

Based on this evaluation, EPA has not added any new AK, radiological characterization or RTR 

T1 or Tier 2 (T2) change requirements. However, EPA has revised Table 1 to be consistent with 

more recent tiering changes resulting from T1 approvals since the baseline approval of January 

2007. 

This report discusses changes to specific INL-CCP documents using the term “freeze file.” As 

discussed in previous EPA reports, CCP may be required to revise a document as a result of an 

inspection-related EPA issue. Once CCP makes the required changes, the modified document is 

provided to EPA as a freeze file to serve as objective evidence that the changes are appropriate. 

EPA has agreed to accept a modified document as a freeze file to expedite review while CCP’s 

document control process generates the official version of the revised document and provides it 

at a later date. EPA must receive CCP’s controlled version of all revised documents no later than 

the end of the calendar quarter. In this case, all freeze files that support EPA’s approval of this 

T1 evaluation must be provided to EPA no later September 30, 2012. 

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

evaluation. This information will be provided through the EPA website and by emails to the 

WIPPNEWS list, in accordance with Title 40 of the Code of Federal Regulations (40 CFR) 

194.8(b)(3). 
3 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CC

(Based on June 12–16 and August 9 and 26, 2006, Baseline Inspection and Subsequent Tier 1 Evaluations, 

RH Waste Characterization 

Process Elements INL-CCP RH Waste Characterization Process – T1 Changes INL-CCP RH Waste Characte

Acceptable Knowledge (AK) Addition of containers to approved waste streams if new or different 

radionuclide scaling factors are required Any new waste streams not approved under this baseline Substantive modification(s)*** to CCP-AK-INL-5X0 orCCP-AK-INL-5X2 that have the potential to affect the 

characterization process Load management for any remote-handled (RH) waste stream 

Notification to EPA when updates been completed: 

• All future revisions of AK 

certification confirmation 

and CCP-AK-INL-502) 

• AK accuracy reports (prep

• Attachment 4 of CCP-TP-

updated AKSR Source Do

• Changes to AK document

Characterization Program [e.g., characterization reco

• A correlation or surrogate 

containers in this waste str(CH), based upon measurenondestructive assay resul

• The waste stream data pac

any modifications to the wincluding the CRR and AK

• Final DTC determination 

through 737, as identified 

Notification to EPA of the intentio

approved waste stream, including containers and volume(s) of wastegeneration, characterization, and dupdated AKSR documenting that tcontainers is the same as those covsubsequent T1 approvals† Submission of a list of fully charac

population of additional containers 

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

Application of new scaling factors for isotopic determination other 

than those documented in CCP-AK-INL-501 Use of any alternate radiological characterization procedure other than 

DTC with established scaling factors as documented in CCP-TP-504 

Notification to EPA when revision

CCP-TP-504 that require CBFO apSubmission of an updated CCP-AKradiological characterization proce
4 

RH Waste Characterization 

Process Elements INL-CCP RH Waste Characterization Process – T1 Changes INL-CCP RH Waste Characte

Substantive modification(s)*** to CCP-AK-INL-5X1 or CCP-TP-504 that have the potential to affect the characterization process Use of any alternate gamma detector with the OSPREYTM system characterization procedure other than the La3Br(Ce) detector observed 

in July 2010 Any new waste stream not approved under the baseline and/or subsequent T1 evaluations or addition of containers to an approved waste stream that requires changing the established radionuclide scaling factors

containers is the same as those covsubsequent T1 approvals† Submission of DTC batch data rep

packages for containers selected b

characterized containers provided 

Visual Examination of audio/video media (VE) 

Use of VE to characterize additional debris waste streams or waste 

from other Summary Waste Categories 

Notification to EPA when changes 

CBFO approval** are complete Submission of VE BDRs for conta

of fully characterized containers p

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

from an S3000 or S4000 waste stream 

Notification to EPA prior to addition of a new RTR unit(s) 

Notification to EPA when changes 

CBFO approval** are complete Submission of RTR BDRs for conlist of fully characterized containe

WIPP Waste Data System (WDS) (previously known as WWIS) 

None Changes made to WDS procedure(

Notes: The text in this table was modified for consistency with formatting changes made to other T1 reports. 

* INL-CCP will report all T2 changes to EPA every 3 months. ** Excluding changes that are editorial in nature or are required to address administrative concerns. New references that are included as part 

requested by EPA. 

*** Substantive modification refers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., the use of an i

measurement instrument or the use of the high-range probe as described in CCP-TP-504 for radiological characterization. 

† INL-CCP will report this T2 change immediately. 
5 

2.0 PURPOSE OF TIER 1 EVALUATION 

Certain changes to the waste characterization activities since the date of the site’s baseline 

inspection must be reported to and, if applicable, approved by EPA according to the tiering 

requirements set forth in 40 CFR 194.8 and incorporated in the INL-CCP RH baseline approval 

report cited in Attachment A. 

Under the changes to 40 CFR 194.8 promulgated in the Federal Register on July 16, 2004 

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

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

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

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

destined for disposal at the WIPP. 

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

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

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

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

are identified in the site-specific baseline inspection reports. When evaluating proposed T1 

changes for approval, EPA may conduct a site inspection to observe at first hand the 

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

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

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

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

continued compliance inspections to evaluate implemented T2 changes to verify adequacy. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to implement the radiological 

characterization process for the Lot 2 waste packaged in 55-gallon drums in Waste Stream 

ID-ANLE-S5000, as described in CCP-AK-INL-501, Revision 5. This report presents the 

technical basis of EPA’s approval decision regarding implementation of the radiological 

characterization process for the Lot 2 waste, which has been conveyed to DOE separately by 

letter. As discussed previously, EPA will also announce the decision on its website at 

www.epa.gov/radiation/wipp, in accordance with 40 CFR 194.8(b)(3). 

The DOE documents that EPA reviewed for this evaluation are cited in different sections 

throughout the report and are listed in Attachment B. Any of these documents can be requested 

from the following address: 

Carlsbad Field Office 

Manager, National TRU Program 

U.S. Department of Energy 

PO Box 3090 

Carlsbad, NM 88221-3090 
6 

4.0 SCOPE OF THE TIER 1 EVALUATION 

The scope of this evaluation is the radiological characterization of a subset of 55-gallon drums of 

Lot 2 waste from ANL-E in Waste Stream ID-ANLE-S5000. CBFO and INL-CCP determined 

that the drums containing Lot 2 waste are of the same pedigree as the previously approved 

ANL-E debris containers stored at INL. Based on criteria set forth by EPA during Baseline 

Inspection No. EPA-INL-CCP-RH-6.06-8 (Docket No. A-98-49; II-A4-72, January 2007) and 

the subsequent T1 evaluation (Docket No. A-98-49; II-A4-145, March 24, 2011), a T1 request is 

required for characterization of any waste using new or different scaling factors. Therefore, the 

scope of this T1 request is evaluation of the radiological characterization approach for the Lot 2 

waste in Waste Stream ID-ANLE-S5000, as specified in CCP-AK-INL-501, Revision 5, 

Appendices A and B. 

EPA has evaluated Waste Stream ID-ANLE-S5000 several times; however, as part of this 

review, EPA also confirmed that the Lot 2 waste described in CCP-AK-INL-500, Revision 10 

(the AKSR), is of the same pedigree in terms of AK as the previously approved ANL-E debris 

waste and is eligible for emplacement at the WIPP facility. 

Sections 6.1, 6.2 and 6.3 of this report detail the three technical areas assessed during this 

evaluation: 

• Programmatic requirements and AK. 

• Radiological characterization. 

• RTR. 

This evaluation involved expanding an existing waste stream to incorporate new containers and 

not the addition of a new summary category group or waste stream; therefore, EPA did not use 

inspection checklists. All references to the Waste Characterization Program Implementation Plan 

(WCPIP) in this report refer to Revision 2, unless specified otherwise.2

5.0 EVALUATION PERSONNEL 

EPA and its support personnel conducted telephone interviews and met on site at INL with INLCCP personnel in several disciplines. The EPA evaluation team members and the personnel 

contacted are listed in Table 2, with their affiliations and technical areas of expertise. This list 

includes personnel present at meetings conducted as part of this evaluation.

 

2

 U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste Characterization 

Program Implementation Plan,” Revision 2, Carlsbad, New Mexico, April 21, 2011. 
7 

Table 2. Tier 1 Evaluation Personnel 

Personnel Name Affiliation Area of Expertise, Function 

Conference 

Callsa 

INL Site 

Visitb 

Ed Feltcorn EPA ORIA T1 Evaluation Lead Inspector   Rajani Joglekar EPA ORIA T1 Evaluation Inspector  Lindsey Bender EPA ORIA Observer Kathleen Economy EPA ORIA Observer Connie Walker SC&A AK, Inspector Rose Gogliotti SC&A Radiological Characterization, Inspector  Amir Mobasheran SC&A Radiological Characterization, Inspector  Patrick Kelly SC&A Radiological Characterization, Inspector   Dorothy Gill SC&A RTR, Inspector  Scott Smith CCP AKE Jene Vanced CCP Radiological Characterization, Technical ExpertDerek Ott WTS-CCP Radiological Characterization, Technical Expert  Joe Harvill CTAC Radiological Characterization, Technical Expert  Michael Sensibaugh WTS-CCP CCP Manager  Irene Quintana WTS-CCP RH Project Manager   Marcus Pinzel DOE-CBFO CBFO RH Manager   D.K. Ploetz WTS-CCP RCT Manager Rhett Bradford CTAC CBFO QA Observer Tom Morgan CBFO NTP CCP Manager  Ron Reeves WTS-CCP Observer James Malmo DOE-Idaho Observer Greg Smith WTS-CCP INL-CCP Vendor Project Manager Fred Oney CCP RTR Operator  Corey Boland CCP DTC Operator Bruce LaRue ID DEQ INL OP Observer Ben Roberts DOE-Idaho Idaho RH-TRU Project Manager Tom Clements CH2M-WG Idaho, LLC TRU Program, Manager Raj Bhatt CH2M-WG Idaho, LLC TRU Program, Scientist Joe Wachter Canberra Observer Patsy Gilbert LANL Interactive Meeting Coordinator  

a Several conference calls were held during May and June 2012 to discuss technical aspects of AK and radiological characterization. 

b Onsite evaluation of DTC and RTR at INL on May 8–9, 2012. 

c Interactive meeting to evaluate radiological characterization calculations in Albuquerque, NM, on June 21, 2012; most participants w

Albuquerque; Rose Gogliotti and Amir Mobasheran participated by telephone. 

d Jene Vance is listed because he prepared many of the technical reports that support this evaluation, even though he did not actively p

telephone call or meeting.
8 

6.0 TECHNICAL EVALUATION 

Waste-Generating Activities

Waste Stream ID-ANLE-S5000 was generated in the Alpha Gamma Hot Cell Facility (AGHCF) 

at ANL-E from the destructive and nondestructive examination of irradiated and unirradiated 

reactor fuel materials and associated hot cell activities. These wastes were transferred to INL for 

storage and characterization prior to emplacement in WIPP. The waste’s radionuclide content is 

derived from sectioning, grinding and polishing of fuel materials for gamma spectrometry, hightemperature testing, fission gas collection and analysis, macrophotography and profilometry. The 

repair of in-cell equipment, cell maintenance and waste management also generated debris waste, 

including portions of fuel sections, fines and related materials (References C066, C108, C1031 

and U001). 

Beginning in 1975, ANL-E sorted TRU waste from fissile scrap, recoverable fines and related 

material. These segregated fissile and fines wastes were placed into cans and inserted into special 

canisters; each canister houses up to eight cans. Materials within the cans were assigned to one 

of five categories during packaging: 

 

• Combustible operations scrap (trash). 

• Noncombustible operations scrap (trash). 

• Irradiated structural material (activated hardware). 

• Nonrecoverable fissile material (fuel specimens not in cladding). 

• Recoverable fissile material (fuel in intact fuel pin cladding). 

Filled canisters were shipped to INL from 1975 to 1984, where they were stored as high-gamma 

TRU material. A total of 51 canisters that were originally considered recoverable were 

subsequently defined as waste. This T1 report addresses the addition of these canisters to Waste 

Stream ID-ANLE-S5000 (References P006, P009, P018, P032, C3660, P063, P067, P3657, 

U002, U342, U3552 and U3900). 

Documents, Waste Containers, and Batch Data Reports and Calculation Packages 

Provided

EPA evaluated the documentation that INL-CCP had prepared to support the inclusion of the 

Lot 2 waste in Waste Stream ID-ANLE-S5000, specifically, CCP-AK-INL-500, Revision 10, 

CCP-AK-INL-502, Revision 5, and CCP-AK-INL-501, Revision 5. EPA’s review of these 

documents identified several technical issues that necessitated the revision of CCP-AK-INL-500, 

CCP-AK-INL-502, some AK documentation (see section 6.1), Appendices A and B to CCP-AKINL-501, and several radiological characterization documentation (see section 6.2). The revised 

documents were provided to EPA prior to the conclusion of this T1 evaluation. Attachment B is 

a list of all documentation that EPA reviewed in support of this T1 evaluation, including BDRs 

and calculation packages. 

Unlike previous T1 evaluations, EPA was not able to obtain the original records that provided 

technical support for some aspects of the radiological characterization process. To address this, 
9 

EPA selected a random sample of canisters and requested that INL-CCP personnel reproduce 

specific calculations that were deemed to be the most important to the development of 

radionuclide-specific scaling factors. EPA requested that these calculations be provided in a 

workable Excel spreadsheet so that their technical adequacy could be assessed directly. EPA also 

requested that INL-CCP take the same approach for a subset of the 583 fuel pins to verify the 

scaling factor development for debris waste. INL-CCP personnel created the requested 

documents and presented them to EPA using an interactive format at a meeting in Albuquerque, 

NM, subsequent to the evaluation at INL. The interactive meeting allowed EPA technical 

personnel to complete their assessment of the radiological characterization process. Following 

this meeting, there were several rounds of email correspondence to clarify or correct minor 

discrepancies and to complete EPA’s evaluation of this T1 change. 

6.1 Programmatic Requirements and Acceptable Knowledge 

EPA examined the programmatic requirements and AK process and associated information to 

determine whether INL-CCP demonstrated compliance with the requirements of 40 CFR 194.8 

for Lot 2 as part of Waste Stream ID-ANLE-S5000. 

Waste Characterization Element Description

As part of this evaluation, EPA reviewed the following with respect to programmatic 

requirements and the use of AK for RH waste characterization: 

• Inspection scope and waste stream identification. 

• Identification of the DOE RH WCPIP’s waste characterization process. 

• Adequacy of the certification plan and other WCPIP documentation. 

• Adequacy of the WCPIP waste characterization pathway. 

• Adequacy of training. 

• Adequacy of the waste stream profile form (WSPF) and related attachments. 

• Adequacy of nonconformance and discrepancy resolution (DR) documentation. 

• Waste stream definition, including radiological and physical characteristics. 

• Role of AK in the characterization methodology, including scaling factors. 

• Verification that the subject waste is of defense origin and is not high-level waste 

(HLW), low-level waste, or spent nuclear fuel (SNF). 

• Adequacy of AK procedure and procedure implementation. 

• Adequacy of the AKSR and associated source documents. 

• AK data traceability. 

• Attainment of data quality objectives (DQOs).
10 

Technical Evaluation

(1) The scope of the Tier 1 request and the waste stream determination were examined for 

Waste Stream ID-ANLE-S5000 and found to be adequate.

Argonne National Laboratory (ANL)-CCP stated that Waste Stream ID-ANLE-S5000 initially 

consisted of no more than 1,000 30-gallon drums of debris waste generated through operations 

and decontamination and decommissioning of the AGHCF and M-Wing facilities. This T1 

request proposes to add 48 RH waste canisters. Source Document P3657 indicates that there are 

51 canisters in the Lot 2 population, but Canister Nos. ANLE4, ANLE50 and ANLE51 were 

removed from the waste stream due to the presence of sodium and the subsequent need to 

remediate them. These remaining remediated canisters from Lot 2 can be added to Waste Stream 

ID-ANLE-S5000 if ANL-CCP can demonstrate that the radiological characterization processes 

discussed in section 6.2 of this report are applicable. When these remaining canisters are added, 

EPA notification and supporting documentation as a T2 change are necessary. 

The WCPIP defines a waste stream as “waste material that is (1) generated from a single 

process/activity and (2) similar in material, physical form, and radiological properties.” Based on 

this definition, EPA examined the AKSR, source documents and other material to verify that the 

Lot 2 waste belongs in Waste Stream ID-ANLE-S5000. 

The AGHCF was a hot cell complex in which metallurgical research on fuel pins and associated 

nuclear materials was performed. Both destructive and nondestructive sectioning and 

examination of irradiated and unirradiated fuels were conducted. The AGHCF K-Wing (K-1 and 

K-2 hot cells) and M-Wing (M-4 hot cell) facilities were used for fuel pin examination. The 

majority of fuel pins were part of the Fast Breeder Fuel Program (68.8%), with the balance 

including fuel pins from light-water reactors (16.0%), fuel plates from the ANL-E Reduced 

Enrichment for Research and Test Reactors Program (2.6%), and fuel pins from graphite reactors 

(0.4%) and water-moderated reactors (4.5%). Unirradiated fuels were also examined (7.7%). 

Fuels were identified by fuel pin identification numbers and alpha/gamma (A/G) numbers, and 

ANL-E kept detailed records that correlated specific fuels sectioned to waste generated. The 

waste stream includes waste from Lot 2 and Waste Stream ID-ANLE-S5000, and the waste 

stream as a whole was generated from 1971 to 1995. The Lot 2 waste portion of the waste stream 

was generated from 1975 to 1984, during which time TRU waste was sorted from fissile fines 

and scrap, placed into special canisters, and transferred to INL for storage and later 

characterization prior to WIPP disposal (References P006, P009, P018, P032, C3660, P063, 

P067, P3657, U002, U342, U3552 and U3900). The Lot 2 canisters were generated during the 

overall fuel examination process; therefore, they share a process with Waste Stream ID-ANLES5000, which was previously addressed in EPA’s baseline approval. 

The Lot 2 and Waste Stream ID-ANLE-S5000 wastes consist of combustible and 

noncombustible debris. However, the Lot 2 wastes also contain fuel fines and materials that are 

present only in small quantities in Waste Stream ID-ANLE-S5000. Source documents contain 

information about the physical composition of waste in each canister, including the differences 

and the similarities between the two populations (References U3900 and C3660). The physical 

composition of this waste is well understood based on packaging information and supports the 
11 

inclusion of the Lot 2 waste in Waste Stream ID-ANLE-S5000 (References C3464, C3698, 

P3089, P3115 and P3182). See Item (7) for additional information. 

Based on loading records and other data, EPA found that the radiological composition of the 

Lot 2 waste differed from Waste Stream ID-ANLE-S5000 (see Tables 6 and 7 in the AKSR) 

(References C3660, P058, P063, U3552, U3900 and U3901). This is due to differences in 

radionuclide reporting between the two populations and their fuel pins. EPA compared the list of 

fuel pins associated with both waste groups to verify that the wastes share common fuel pin 

sources and, therefore, have similar radiological signatures (References U4042 and INL-CCP 

2006). Based on data used by INL-CCP to generate scaling factors, EPA found that Waste 

Stream ID-ANLE-S5000 and Lot 2 waste share approximately 33% of their A/G numbers, 

indicating that the radiological compositions of the two populations differ. This is to be expected 

because the Lot 2 waste was generated from 1975 to 1984 and Waste Stream ID-ANLE-S5000 

was generated from 1971 to 1995. The Lot 2 waste and Waste Stream ID-ANLE-S5000 contain 

radionuclides from similar fuel types, and the presence of some common A/G numbers is 

sufficient to include the Lot 2 waste in Waste Stream ID-ANLE-S5000. See Item (7) for 

additional information about the radiological composition of the waste stream. 

(2) The certification plan, as revised to include a description of the waste characterization 

process, was examined and found to be complete. 

The WCPIP requires that the certification plan describe the process for certification of the waste 

stream, including a description of the following: 

• AK characterization methods selected to meet the DQOs, including the justification for 

the selection of the methods. 

• Quality assurance (QA) objectives for the selected methods. 

• Characterization and testing methods not included in the WCPIP in sufficient detail to 

allow for CBFO approval prior to implementation. 

• Summary of the program documents to be prepared during the characterization and 

qualification methods. 

The certification plan states that a combination of characterization methods was employed to 

characterize Waste Stream ID-ANLE-S5000 and to meet DQOs, specifically AK, radiological 

characterization, and RTR. 

INL-CCP used AK to determine and describe the waste stream and to define DQOs required by 

the Waste Isolation Pilot Plant Land Withdrawal Act (LWA), such as the defense status of the 

waste [see Item (9)] and the absence of HLW and SNF [see Item (8)]. AK was also input to 

ORIGEN 2.23

 modeling to determine scaling factors for DTC. The certification plan states that 

the ORIGEN 2.2 output was adjusted using factors developed for Los Alamos National 

Laboratory (LANL) RH canisters that were verified by mass spectrometry performed on the 

same fuel pins. EPA approved the use of LANL-based data in EPA’s INL RH baseline; the 

 

3

 ORIGEN is the Oak Ridge Isotope Generation and Depletion Code. 
12 

approval remains applicable because the Lot 2 canisters contain radionuclides from the same 

type of fuel pins as at LANL. That is, the same method that was used to verify AK data as part of 

the baseline approval remains applicable to this T1 request, so additional verification is not 

required. 

INL-CCP revised the certification plan to state that AK accuracy calculations based on AK–AK 

comparison was not meaningful [see Item (12)]. The plan also presented QA objectives for the 

selected characterization methods, and addressed the AKSR and radiological characterization 

technical reports. EPA finds that the certification plan includes the required elements and is 

adequate. 

5164

(3) The waste characterization pathway was identified, and documentation of the approach 

was adequate. 

Table 3 summarizes the waste characterization pathway as presented in the revised certification 

plan and radiological characterization technical report. 

Table 3. Characterization Methods for the Waste Stream 

Item Method Location of Method 

Description Supporting BDR 

Physical 

Parameters 

Characterization by radiography CCP-AK-INL-502 INLRHRTR12002 

Radiological 

Parameters 

Radiological characterization 

using AK-derived scaling factors 

verified by sampling and analysis 

of another debris waste stream. 

DTC used to derive radiological 

characteristics. 

CCP-AK-INL-501 

CCP-AK-INL-502 

INLRHDTC12002 

INL-CCP used AK to identify the waste stream, exclude HLW and SNF, verify the defense 

status of the waste stream and support isotopic compositions. The physical composition of the 

waste stream, including the absence of prohibited items, was determined using radiography. The 

characterization pathway was adequately identified. 

 

(4) Examples of nonconformance and discrepancy resolution documentation were examined 

and found to be adequate. 

INL-CCP did not provide a nonconformance report (NCR) pertinent to this T1 request because 

none have been generated or required thus far. EPA had examined the INL-CCP NCR process 

previously and found it to be adequate. Discrepancy resolutions (DRs) for the Lot 2 T1 request 

were not prepared, but INL-CCP provided several relevant DRs (References DR11, DR12 and 

DR14 through DR22). INL-CCP demonstrated adequate implementation of the NCR and DR 

processes. 
13 

(5) The acceptable knowledge procedure and related attachments were examined and found 

to be adequate and appropriately implemented. 

During the WCPIP revision process, CBFO transferred AK procedural requirements from the 

WCPIP to procedure CCP-TP-005, Revision 22. CCP subsequently revised Revision 22 as part 

of the resolution of CBFO CAR11-043 (Revision 23) and again revised the procedure on 

November 28, 2011, to incorporate additional WCPIP requirements (Revision 24). Many Waste 

Stream ID-ANLE-S5000 documents, including Revision 5 of the AKSR, were created under 

CCP-TP-005, Revision 24; other documents were created under Revision 23 or previous 

revisions, depending on the date the document was prepared. EPA found that CCP-TP-005, 

Revision 24, reflected all applicable WCPIP requirements and expects that all document 

revisions and procedure implementation will follow the requirements in the revision of CCP-TP005 that is in place at the time of the activity. 

INL-CCP provided CCP-TP-005, Attachments 1, 2, 3, 4, 5, 6, 8, 11, 14 and 15: 

• “Attachment 1 – Acceptable Knowledge Documentation Checklist” is the roadmap 

identifying source documents that provide required information. 

• “Attachment 2 – Record of Communication” is an interview form. It may be used to 

generate source documents identified by a “C” when CCP performs an interview (e.g., 

Reference C380). 

• “Attachment 3 – Acceptable Knowledge Source Document Summary” summarizes 

source document contents. An Attachment 3 is prepared for each source document, and 

all Attachment 3s are considered to be CCP QA records. The original source document 

summarized in the accompanying Attachment 3 is not considered a QA document unless 

CCP generated the original source document. Copies of all source documents are retained 

in CCP’s non-QA records; original source documents are retained at the generator site. 

• “Attachment 4 – Acceptable Knowledge Source Document Information List” was 

updated March 23, 2012, to include new references supporting the additional T1 canisters 

of high-gamma waste. 

• “Attachment 5 – Hazardous Constituents” addresses hazardous waste numbers. This 

attachment is not applicable and EPA did not review it. 

• “Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and 

Packaging” is addressed in Item (7) below. 

• “Attachment 8 – Waste Containers List” was updated to include the T1 high-gamma 

canisters as well as repackaged associated drums. 

• “Attachment 11 – Acceptable Knowledge Source Document Discrepancy Resolution” is 

addressed in Item (4) above. 

• “Attachment 14 – CCP Acceptable Knowledge Accuracy Report” is addressed in Item 

(12) below. 
14 

• “Attachment 15 – CCP TRU Waste Correlation and Surrogate Summary Form” was 

provided, but EPA did not review it because the form was provided as part of the original 

baseline and was evaluated at that time. 

The attachments were prepared on forms presented in CCP-TP-005, Revisions 18, 23 or 24, 

depending on the revision in place at the time. This is acceptable because implementation of the 

AK process for this waste stream spanned many generations of CCP-TP-005 revisions. 

INL-CCP did not provide CCP-TP-005, Attachments 7, 9, 10, 12 and 13, for the following 

reasons: 

• “Attachment 7 – Radionuclides” was not prepared and is not applicable because the AK 

nondestructive assay memorandum is specific to contact-handled wastes. 

• “Attachment 9 – Waste Characterization Data Cross-Reference” is a reference tool and, 

therefore, does not require completion of a form. 

• “Attachment 10 – Acceptable Knowledge Re-evaluation Checklist” was not prepared 

because it was not necessary. 

• “Attachment 12 – Example Form and Content Guide for AK Summary Reports” is a 

reference tool for writing the AKSR. AKSR adequacy is addressed in Item (6) below. 

• “Attachment 13 – CCP Waste Stream Characterization Checklist” is provided when 

characterization of a waste stream is near completion and, therefore, has not yet been 

prepared. This is acceptable, given the timing of the evaluation. 

EPA found that CCP-TP-005 was adequately implemented. 

(6) The acceptable knowledge summary report, associated source documents and reference 

list were examined and found to be adequate. 

EPA reviewed the AKSR and questioned deficiencies in the descriptions of the process, physical 

waste and packaging, and radiological composition. INL-CCP revised the AKSR to address these 

deficiencies (CCP-AK-INL-500, Revision 11, freeze file4

). The AKSR provides necessary 

information presented in CCP-TP-005, Attachment 12, and was adequately revised to address 

deficiencies identified by EPA during the evaluation. 

(7) The overall radiological and physical properties of the waste stream were examined and 

found to be adequately described based on acceptable knowledge. 

Physical Properties: 

Waste Stream ID-ANLE-S5000 is composed of approximately 210 cubic meters of debris waste 

(1,466 repackaged 30-gallon drums overpacked into 55-gallon drums), including the highgamma waste (References C3660, U3552 and U3900). INL-CCP estimated that the overall waste 

material parameter weight percentage for the waste stream is about 78% inorganic material and 

22% organic material, based on inventory records for 123 30-gallon Waste Stream ID-ANLE-

 

4

 See the discussion of freeze files in the executive summary. 
15 

S5000 drums packaged from 1990 through 1995 (Reference C332). This estimate did not include 

canister data. 

AK documentation indicates that Lot 2 combustible waste is composed of grinding papers, rags, 

tissue-type wiping materials, and other similar materials and that noncombustible Lot 2 waste is 

composed of bottled and unbottled fuel fines, bonded clad material, pipe nipple containers, 

irradiated structural materials and waste related to fuel specimen sectioning and preparation (e.g., 

fragments, granules, metallurgical mounts [hereafter referred to as “met mounts”], fuel 

impregnated with epoxy, sweeps and fines) (References U3607, U3900, U3552 and U4032). 

These data suggest that the physical composition of Lot 2 waste is somewhat different than the 

original Waste Stream ID-ANLE-S5000, which was generated through cell operations and 

decontamination and decommissioning. However, the AKSR (p. 44) states, “based on review of 

the descriptions provided, the waste is similar in composition with the waste containers 

previously evaluated for waste material parameter estimates.” EPA verified this assertion by 

examining waste records for the 48 canisters in the T1 request in source documents (References 

U3607, U3552, U4032 and U3900). EPA reviewed data that show the Lot 2 wastes consist of 

approximately 33% combustible and 69% noncombustible material based on historical waste 

loading documentation. EPA verified that the overall Lot 2 waste composition is generally 

consistent with Waste Stream ID-ANLE-S5000, but Lot 2 waste contains more fuel-related 

waste and fuel particulates. All Lot 2 canisters will be repackaged and remediated to remove 

liquids, as necessary, so the resulting waste content may be modified as a result of this activity. 

The physical characteristics of the Lot 2 waste are well understood. 

Radiological Properties: 

Waste Stream ID-ANLE-S5000 was generated from the destructive and nondestructive 

examination of irradiated and unirradiated reactor fuel materials and associated hot cell support 

activities. AKSR Table 6 indicates that plutonium-239 (239Pu) and uranium-235 (235U) are the 

predominant radionuclides by mass in Waste Stream ID-ANLE-S5000, and cesium-137 (137Cs) 

and iron-55 are the predominant radionuclides by activity, noting that mixed fission products 

also constitute a significant contribution to the total curie content. EPA previously evaluated the 

radiological composition of AGHCF Waste Stream ID-ANLE-S5000 (Docket No. A-98-49, 

Reports II-A4-72, II-A4-97 and II-A4-122) and found the radiological composition of the waste 

stream to be adequately represented at the time of these reviews. Therefore, EPA did not repeat 

the detailed review of source documents to verify adequate calculation of AKSR Table 6. 

The Lot 2 waste contains portions of the actual fuel pins that were sectioned and tested in the 

facility, and the radiological composition of the Lot 2 population is based on generator-provided 

data, as presented in AKSR Table 7. Lot 2 canister information was obtained from several 

sources, including retrievable storage canister data irradiated high-level gamma TRU scrap 

material forms (Form SPM-50), nuclear material transaction reports (Form AEC-741) and 

shipment—special source (SS) material forms (Form SPM-43) (References C3660, P058, P063, 

U3552, U3900 and U3901). These data indicate that 235U and 238U are the predominant 

radionuclides by weight in the Lot 2 canister subpopulation. Mixed fission products (MFP) 

constitute the vast majority (over 94%) of total activity in the Lot 2 canisters, with cerium-144 

(

144Ce) the second largest contributor to the total curie content. 
16 

EPA observed that the overall distribution within Waste Stream ID-ANLE-S5000 (AKSR Table 

6) was different than that for the Lot 2 population (AKSR Table 7), which would not be expected 

if the two groupings contained radionuclides from the same (or nearly the same) fuel pin 

populations. EPA also compared the fuel pin data associated with Waste Stream ID-ANLES5000 and Lot 2 canister waste used by INL-CCP to calculate scaling factors and found that 

approximately 33% of the A/G numbers were common to the two subpopulations. Because the 

majority of fuel pins associated with Waste Stream ID-ANLE-S5000 are not common with Lot 2 

waste, different Lot 2 and Waste Stream ID-ANLE-S5000 radiological compositions are 

expected, as shown in AKSR Tables 6 and 7 (References U4042 and INL-CCP 2006). INL-CCP 

explained the difference between AKSR Tables 6 and 7 as follows: 

• The different radionuclide distributions in AKSR Tables 6 and 7 reflect actual differences 

in the radionuclide contents of Waste Stream ID-ANLE-S5000 and Lot 2, as well as the 

level of detail reported by the waste generators. For example, MFP were reported as 

individual activities in Waste Stream ID-ANLE-S5000, but MFP in Lot 2 were reported 

as one activity (References C348, U015 and U017). Also, the calculated 238U 

composition in Lot 2 waste is calculated by weight (mass) whereas Waste Stream IDANLES5000 reports 238U by activity. Due to its low specific activity, the mass or activity 

values for the same amount of 238U differ considerably. If 238U is excluded, the weight 

percent distributions of the two populations are comparable (References C3660, U3552, 

U3607, U3900 and U3901). 

• The scaling factor calculations for Lot 2 include approximately 80 additional fuel pins 

that were obtained through ongoing AK data acquisition. This means that the Lot 2-

specific AK data used to develop Table 7 may include different or additional fuel pins 

than are in the Waste Stream ID-ANLE-S5000 AK data. 

The different radiological signatures for Waste Stream ID-ANLE-S5000 and Lot 2 waste can be 

explained, and the radiological composition of the Lot 2 waste is generally well understood 

based on AK. INL-CCP revised the AKSR to include additional information about the fuel 

material populations associated with both waste types. The radiological composition of the Lot 2 

waste is adequately described and explained. 

(8) The waste stream information was examined and indicates that the waste stream does not 

contain spent nuclear fuel or high-level waste. 

The LWA, Section 12, prohibits the disposal at the WIPP of SNF and HLW, as defined by the 

Nuclear Waste Policy Act (NWPA). The NWPA states that SNF is “fuel that has been withdrawn 

from a nuclear reactor following irradiation, the constituent elements of which have not been 

separated by reprocessing.” DOE M 435.1-15

expands on this definition and states that “test 

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

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

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

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

material.” The NWPA defines HLW as “the highly radioactive material resulting from the 

 

5

 DOE M 435.1-1 is DOE’s “Radioactive Waste Management Manual,” Revision 1, issued June 2001. 
17 

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.” The Lot 2 waste includes fuel 

particles, sections, fragments and fines generated by sectioning spent fuel pins. AK data do not 

indicate that intact rods are included in the waste stream, so the waste does not contain SNF. 

Also, HLW was not generated because the fuel was not chemically modified. 

As shown in Item (1), the Lot 2 waste is equivalent to Waste Stream ID-ANLE-S5000 and that 

equivalency applies also to the absence of SNF and HLW. 

(9) The waste stream information was examined and indicates that the waste stream is 

defense in origin. 

RH TRU waste is eligible for disposal at the WIPP if it was generated in whole or in part by one 

of the atomic energy defense activities listed in Section 10101(3) of the NWPA. As described in 

CCP-AK-INL-500, Revision 11, the fuel pins in Waste Stream ID-ANLE-S5000 were associated 

with defense and nondefense activities related to nuclear power, fuel and weapons development. 

DOE test and research reactors that contributed fuel elements to DOE’s overall defense program 

include the Experimental Breeder Reactor-II, Zero Power Plutonium (Physics) Reactor, 

Advanced Test Reactor (ATR), Transient Reactor Test Facility, and Hanford Fast Flux Testing 

Facility, some of which also contributed fuels to the AGHCF program. AK documentation 

verifies the ongoing receipt and examination of mixed oxides, carbide and alloy fuels at the 

AGHCF (References C046, C074, C124, C330, P002, P585, P586, P1001, U009, U040 and 

U076). Defense activities are associated with these reactors. In addition, INL-CCP identified the 

following defense-related activities that were conducted at the AGHCF (References C006, C011, 

C068, C092, C103, C124, C152, C305, P028, P320, P585, P599, P835, U001, U007, U023, 

U045, U076 and U307): 

• Examination of Naval Research Laboratory specimens from the Knolls Atomic Power 

Laboratory, Bettis Atomic Laboratory, and the ATR. The ATR is the principal irradiation 

facility for the development of naval reactor fuels and materials. 

• Gulf General Atomic sponsored defense-related programs at the INL Materials and Fuel 

Complex (MFC) that sent fuel specimens to the AGHCF (e.g., oxide fuel designated 

G1-7). 

• Irradiation of lithium-containing specimens at the ATR to generate tritium as part of 

classified defense research and development activities (naval reactor development and 

defense nuclear materials security). 

Wastes from all programs were combined during testing. Subsequent waste generation practices 

resulted in the comingling of defense and nondefense waste materials. Separation of waste 

material from different fuel pins and other destructively examined specimens was not performed, 

and ANL-E did not separate defense- and nondefense-related waste associated with the Lot 2 

Waste (References C001, C036, C125, C381, C1031, U001, U013, U1003, P001, P002 and 
18 

P025). Based on the extent of waste comingling, Waste Stream ID-ANLE-S5000, including the 

Lot 2 waste that is the subject of this T1 evaluation, contains defense-related waste. 

(10) The draft waste stream profile form and characterization reconciliation report were 

examined and found to be adequate. 

With implementation of the WCPIP, INL-CCP elected to generate a single WSPF that satisfied 

both the WCPIP and the New Mexico Environment Department permit. INL-CCP originally 

provided a draft WSPF that included only the canisters in the T1 request, implying that the 

canisters were considered to be a separate waste stream. Upon EPA’s request for clarification, 

INL-CCP provided a revised WSPF that included totals for both the previous containers and the 

T1 canisters, showing that the T1 is an addition to an existing waste stream rather than a new 

waste stream. A 2007 change notice was also provided. INL-CCP representatives indicated that 

CCP-TP-002, Revision 24, removes the requirement to generate a change notice, instead 

requiring WSPF revision whenever the subsequent data reconciliation shows that the new data 

do not match the WSPF description. Revision 24 requires revision of the WSPF, if mandated by 

new information, and is satisfactory. The draft revised WSPF is acceptable, and a final WSPF 

will be prepared in the future. Also, the draft characterization reconciliation report associated 

with the WSPF is acceptable. 

(11) Drum data are traceable and are in the acceptable knowledge record. 

EPA verified traceability of Lot 2 canister loading, management and characterization through 

review of source documents. Canister No. ANLE33 was selected for traceability analysis 

because it contains cans that include several different types of waste. EPA did not review the 

traceability of AK fuel pin data to INL-CCP’s can or canister designation because this was 

successfully demonstrated at that time. Instead, EPA evaluated the following steps of canister 

movement from loading at ANL-E through INL-CCP characterization: 

1. High-gamma TRU waste transferred to INL from ANL-E in canisters was first received 

at the Hot Fuel Examination Facility (HFEF) or Fuel Conditioning Facility before being 

transferred to the MFC Radioactive Scrap and Waste Facility (RSWF) for storage 

(References C3660, U3552, U3900 and U3901). 

2. At RSWF, waste containers were stored in liners designated by a letter and number; for 

example, canister No. ANLE33 was placed in Liner D-12. These liners are sealed carbonsteel pipes set and buried vertically in the ground, the tops of which protrude 2 to 4 

inches above the ground (Reference P3657). 

3. Canisters were typically placed in 16-inch-diameter liners, but in 1989, an upgrade to the 

RSWF was initiated because of concerns about liner corrosion, which required movement 

or “translocation” of some containers to new, cathode-protected liners. For example, in 

1997 Canister No. ANLE33 and its liner were removed and the canister was relocated to 

a cathode-protected 24-inch liner. Other canisters were opened and only the internal 

container of each was transferred to a new cathode-protected standard 16-inch liner 

(References P2040, P3657 and U3552). 
19 

4. From 2009 to 2010, canisters were transferred from storage to Idaho Nuclear Technology 

and Engineering Center (INTEC) for subsequent repackaging in either Building CPP650, the New Waste Calcining Facility, or Building CPP-666, the Fluorinel Dissolution 

Process and Fuel Storage Facility (References P3657, P4119). Following repackaging, 

INL-CCP characterizes waste for eventual shipment to WIPP. 

Table 4 presents the source documents reviewed and information obtained for Canister 

No. ANLE33. It is important to determine whether repackaged drums are associated with the 

correct canister and that drum contents are appropriately identified to ensure that the appropriate 

scaling factor is applied. Table 5 presents the original contents of the cans in Canister No. 

ANLE33, the repackaged drum contents, and waste type assigned by CCP as part of the 

radiological characterization process. The original can numbers do not necessarily correspond to 

repackaged drum numbers, but the comparison shows that the original cans’ contents are 

reflected in repackaged drums and that CCP adequately identified the type of waste in the drums. 

Table 4. Shipment, Storage and Repackaging 

Traceability Analysis for Canister No. ANLE33 

Source 

Document Date Record Record Content and Information Comments 

U3900 1975 

Retrievable 

Storage Canister 

Data Sheets 

Canister Data Sheets, 

High-Level Gamma 

Transuranic Scrap 

Metal 

Preshipment canister data; 

description of individual can 

contents for each canister, Can 

Nos. 33-A through 33-G 

U3552 1979 Sealion Database Nuclear Materials 

Transaction Report 

Documents shipment of material 

from ANL-E to ANL-W; 

includes transfer report SS 

materials transfer forms 

U3552 1979 Sealion Database 

Radioactive Waste 

Storage and Disposal 

Requisition 

(Form 110) 

Canister acceptance at INL’s 

RSWF, Liner No. D-12. Includes 

RSWF log and SS shipment 

form 

U3552 1997 Sealion Database 

Database Only, No 

Original 

Documentation 

Provided 

Translocation of canister from 

16" to 24" liner at RSFW 

None 2010 INL-CCP 

Conference Call 

No Documentation 

Provided 

Movement from RSWF to 

Building CPP-666 for 

repackaging 

U4032 2011 RH Repackaging 

Data Sheets Form 880 

Documents repackaging of 

original cans into CCP Drum 

Nos. 33A–33I. 
20 

Table 5. Correlation of Can and Repackaged Drum Contents, Canister No. ANLE33 

Original 

ANLE 

Can 

Number 

Retrievable Storage 

Canister Data 

(U3900) 

CCP 

Drum 

Number 

RSWF Repackage Log Data 

(U4032) 

CCP Radiological 

Characterization Drum 

Content Description 

CCP-TP-005 

Attachment 8 

33-A 

Noncombustible Operations 

Waste – Dissolved Na 

Residue in Dri-Rite Powder 

33-A 

Broken glass pieces, plastic 

lids, paint can, gravel chunks – 

30-minute exposure time 

Unspecified (presumed to 

be trash) 

33-B 

Noncombustible Operations 

Waste – Dissolved Na 

Residue in Dri-Rite Powder 

33-B 

Met mounts, plastic sample 

bottles, “structural material” – 

30-minute exposure period 

Met mounts 

33-C Combustible Operations 

Waste 33-C Met mounts and plastic glass bottles Met mounts 

33-D Combustible Operations 

Waste 33-D Fuel pins and fragments; immersion filter paper Fuel pins (pieces) 

33-E Nonrecoverable Fissile 

Material Mounts, Sweeps & 

Fines Glass and Metal 

Containers 

33-E1 

E-1 Fuel pins, Met-L-X, and 

fines split into three drums – 

E, D and F 

Fuel pins (pieces) 

33-F Recoverable Fissile 

Material Fuel in Clad 33-F See above Fuel pins (pieces) 

33-G Noncombustible Operations 

Waste – Dissolved Na 

Residue in Dri-Rite Powder 

33-G Fines and metals (Can 408) Fines and Met-L-X 

33-H Noncombustible Operations 

Waste – Dissolved Na 

Residue in Dri-Rite Powder 

33-H Fines and Met-L-X Cans 403, 

404, 405 and 410 Fines and Met-L-X 

— No Container 33-I Fines and Met-L-X Fines and Met-L-X 

INL-CCP accessed the site Sealion database to obtain traceability information. The Sealion 

database is an INL searchable database that includes original paperwork associated with waste 

(including ANL-E waste canister paperwork), as well as liner characterization information, 

extensive search capabilities, a reference library and batching information. This database was 

queried, and the results were included in Reference U3552. 

EPA determined that the information associated with each container is traceable through the 

major phases of waste shipment, acceptance, transfer, repackaging and CCP characterization. 

(12) The AK accuracy report was examined and found to be adequate. 

The WCPIP requires preparation of an AK accuracy report that assesses accuracy based on the 

percentage of waste containers that required reassignment to a new summary category group or 

new waste stream, based on AK reevaluation of measurement data. The WCPIP also requires 

INL-CCP to develop a method to compare radionuclide data derived from measurement with AK 

radionuclide information. When AK is used to characterize waste, AK accuracy based on 

comparing the results of measurement (e.g., DTC) and AK is not meaningful because this simply 

compares AK data, rather than verifying the accuracy of AK through actual measurement. The 

AK accuracy report was revised to recognize this condition. The AK accuracy report included 20 

of the Lot 2 canisters and presented the AK accuracy to be 100% based on the above broad 

criteria. The revised AK accuracy report is adequate. 
21 

(13) Acceptable knowledge training was examined and found to be adequate. 

The WCPIP indicates that characterization program 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: 

• The WCPIP. 

• Characterization program NCR and corrective action processes. 

• Site-specific training relative to the site’s waste streams, e.g., current AKSRs. 

• Determination of the radiological contents of individual containers.

The WCPIP also states that the “RH TRU characterization program is responsible for 

maintaining records of the training provided to personnel responsible for compiling AK” 

(page 33). Table 6 presents the training received by key AK personnel interviewed during the 

inspection, as documented by the cited information.

Table 6. AK Training Qualification Summary 

Name WCPIP 

Nonconformance 

and Corrective 

Action 

(CCP-QP-005) 

Site-Specific 

Training 

Determining 

Radiological 

Contents of 

Containers 

Current Revision of 

CCP-TP-005 

Scott Smith Qual Card 

Email verification 

that CCP‐QP‐005, 

Rev. 21, was read, 

issued 3/5/12

Author of IDANLE-S5000 

AKSR 

Briefing Revision 24: Briefing 

Mark Doherty Qual Card 

Email verification 

that CCP‐QP‐005, 

Rev. 21, was read, 

issued 3/5/12

Author of IDANLE-S5000 

Certification 

Plan 

Briefing Revision 24: Briefing 

EPA expects INL-CCP to accompany each approval request with up-to-date training 

documentation for all AK personnel that includes periodic briefings and training to keep AK 

personnel abreast of AK documents and WCPIP revisions. EPA will rely on inspection 

interviews to determine whether AK Experts are familiar with procedure revisions that are less 

critical. 

(14) Data quality objectives were evaluated and found to be adequately met. 

The WCPIP identifies the following DQOs that must be addressed: 

Defense Waste, HLW and SNF Determination (Regulatory Basis: LWA): This ensures that the 

waste stream was generated by atomic energy defense activities, is not HLW and is not SNF, as 

discussed above in Items (9) and (8), respectively. These are addressed in CCP-AK-INL-500, 

Revision 11 (with freeze file edits), and CCP-AK-INL-502, Revision 5. 
22 

Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP): 

• TRU Waste Determination: Waste must contain more than 100 nanocuries of TRU 

isotopes per gram of waste. 

• RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem 

per hour (mrem/hr) and less than 1,000 rem per hour.

6

• Activity Determination: The total waste inventory can be no more than 5.1 million curies 

of RH TRU; activity limit per canister is 23 curies per liter; and all radionuclides 

important to release calculations must be tracked. 

The technical aspects of these three DQOs are addressed in CCP-AK-INL-500, Revision 10, and 

CCP-AK-INL-501, Revision 5, as discussed in Section 6.2 below. 

Physical Properties (Regulatory Basis: EPA Certification of the WIPP): 

• Liquids: The absence of liquids in excess of 1% of the container volume must be 

confirmed. 

• Physical Form: The physical form of the waste must be determined to delineate the waste 

stream as required by the final certification rule.

These two DQOs are addressed, as discussed in Item (7) above. 

EPA determined that the documents cited above support that all DQOs were achieved either 

through AK, radiography or the radiological characterization process. EPA also determined that 

the waste stream was appropriately identified based on process, radiological and physical 

information, and that the appropriate WCPIP elements were adequately addressed. 

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team did not identify any AK-related findings or concerns relative to the 

addition of the Lot 2 waste to Waste Stream ID-ANLE-S5000 during this T1 change evaluation. 

Changes to Tiering

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

identified during the baseline inspection and subsequent T1 evaluations. 

 

6

 “Rem” or “millirem” 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 terms “dose equivalent” or “dose equivalent rate.” The actual difference among these 

values for the purpose of this report is negligible. 
23 

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA approves the T1 request to add Lot 2 canister waste 

to Waste Stream ID-ANLE-S5000. 

6.2 Radiological Characterization 

Waste Characterization Element Description

The radiological characterization of INL-CCP Lot 2 relies on DTC in conjunction with 

radionuclide-specific scaling factors that were developed for this waste stream based primarily 

on the following two sources of information: 

• AK, as summarized in CCP-AK-INL-501 and associated source documents. 

• Radionuclide-specific results from the ORIGEN2.2 analyses based on AK documentation 

of the initial composition, burnup and irradiation time for 583 fuel pins. 

The radiological characterization methods used for INL-CCP Lot 2 were evaluated in terms of 

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: 

• External gamma measurements (DTC and OSPREY) made at INL. 

• Development of the DTC correlation for 55-gallon drums using waste densities ranging 

from 0.01 grams per cubic centimeter (g/cm3

) to 2.0 g/cm3 based on MicroShield®

modeling of the drum’s gamma dose rate using a one-curie source of 137Cs for debris 

(scrap) waste. 

• Development of the DTC correlation for 55-gallon drums using MCNP modeling of the 

drum’s gamma dose rate for high-gamma (canister) waste, including an internal 1-gallon 

paint can, when applicable. 

• Scaling factors developed based on ORIGEN 2.2 modeling. 

Documents Reviewed

All INL-CCP RH radiological characterization documents that were reviewed to support this 

inspection are listed in Attachment B. As a result of EPA’s review, several of the INL-CCP 

documents required revision, and all relevant versions are shown in Attachment B. 

Technical Evaluation

The EPA inspection team evaluated the following: 

(1) The overall radiological characterization process and its documentation were evaluated 

and found to be adequate. 
24 

The radiological characterization process for the Lot 2 waste was comparable to the processes 

observed at previous RH TRU sites. The main technical components consisted of the following: 

determining isotopic distributions to develop radionuclide-specific scaling factors, measuring 

each drum’s external exposure (dose) rate, and computer modeling to correlate the waste 

container’s dose rate and radionuclide concentration. Each of these components is discussed in 

subsequent items in this section. Members of the EPA inspection team prepared two flow 

diagrams documenting the processes, shown in Figure 1 and Figure 2 below, based on CCP-AKINL-501. The radiological characterization process for Lot 2 was found to be technically 

adequate and appropriately documented. 

Any new RH waste stream not approved to date or the addition of drums to Waste Stream IDANLE-S5000 that requires changing the established radionuclide scaling factors or the use of a 

different radiological characterization process from what is documented in CCP-AK-INL-501, 

Revision 5, remains a T1 change. (See Table 1.) Any change to CCP-AK-INL-501 that requires 

CBFO approval remains a T2 change. (See Table 1.) 
25 

Source: Based on CCP-AK-INL-501. 

Figure 1. Flow Diagram of the Characterization Process: Scrap Materials from Debris 

Waste Stream ID-ANLE-S5000 

Determine Scaling Factors: Determine DTC Conversion Factors:

Execute DTC to Determine Drum’s 137Cs Activity:

Locate and retrieve canister loading 

records for the 48 canisters to identify 

all of the fuel pins and fuel specimens 

related to the loaded material and 

estimate the loaded fuel quantities

Locate and retrieve available records 

and literature to determine the reactor 

type, pre-irradiation fuel compositions, 

fuel burnup levels and reactor discharge 

dates

Calculate weighted, and reactor-typeadjusted, radionuclide activities to 

determine a single set of 137Cs-based 

scaling factors for the reportable 

radionuclides by dividing the total 

activity of each radionuclide by the total 

activity of 137Cs 

Use MicroShield®to model the gamma dose rate at one meter 

from the drum surface, based on a 1-Ci source of 137Cs

Find the mean gamma dose rate based on four measurements 

at one meter from the surface of the drum 

Divide the 137Cs mean dose rate by the DTC conversion 

factor to find the 137Cs activity in curies 

Multiply the 137Cs activity by the scaling factors to determine 

activities of the radionuclides of interest

Determine the uncertainties in reported activities and masses 

of the radionuclides 

Make ORIGEN 2.2 runs for fuel pins to 

determine post-irradiation fuel 

radionuclide compositions 

Determine the contribution of 137Cs contained in the drum to 

the dose rate measured, using gamma spectrometry and 

finding the contribution of 60Co to the dose rate measured 

Develop DTC conversion factor (mR/hr/Ci)-density 

relationship for 137Cs for the geometry of a 30-gallon drum, 

containing a can loaded with scrap materials and overpacked 

with a 55-gallon drum 
26 

Source: Based on CCP-AK-INL-501. 

Figure 2. Flow Diagram of the Characterization Process: Recoverable and Nonrecoverable 

Fissile Material from Debris Waste Stream ID-ANLE-S5000 

Determine Canister-Based Scaling Factors: Determine DTC Conversion Factors:

Execute DTC to Determine Drum’s 137Cs Activity:

Locate and retrieve canister loading 

records for the 48 canisters to identify 

the ones loaded with cans containing 

recoverable fissile material (fuel in 

intact cladding) and nonrecoverable 

fissile material (fuel specimens not in 

cladding) and to estimate the loaded 

fuel quantities

Locate and retrieve available records 

and literature to determine the reactor 

type, pre-irradiation fuel compositions, 

fuel burnup levels and reactor discharge 

dates for the fuel in each canister

Calculate weighted (and reactor-typeadjusted) 137Cs-based scaling factors for 

the reportable radionuclides for each 

canister by dividing the total curies of 

each radionuclide by the total curies of 

137Cs contained in the canister

Consider the following geometries: 

• A can of recoverable fissile material in a wire basket, 

loaded into a 30-gallon drum overpacked in a 55-gallon 

drum with the can centered vertically in the drum 

• A can of nonrecoverable fissile material, spread across the 

bottom of a 30-gallon drum overpacked in a 55-gallon drum 

Find the mean gamma dose rate based on four measurements 

at 1 meter from the surface of the drum 

Divide the 137Cs mean dose rate by the DTC conversion 

factor to find the 137Cs activity in curies 

Multiply the 137Cs activity by the scaling factors to determine 

activities of the radionuclides of interest

Determine the uncertainties in reported activities and masses 

of the radionuclides 

Make ORIGEN 2.2 runs to determine 

post-irradiation fuel compositions for 

the fuel pins involved in each canister 

Determine the contribution of 137Cs to the dose rate measured, 

using gamma spectrometry to find the contribution of 60Co to 

the dose rate measured 

Use MCNP5 to model the gamma dose rate at 1 meter from 

the drum surface, based on a 1-Ci source of 137Cs, as the DTC 

conversion factor (mR/hr/Ci) 
27 

(2) The development of scaling factors based on cesium-137 was found to be technically 

adequate and correctly documented. 

In the context of the INL-CCP RH characterization program, a scaling factor is the ratio of the 

activity of a typically difficult-to-measure radionuclide, e.g., 239Pu, to an easily measured 

radionuclide, in this case 137Cs. Assuming that the container-specific measured dose rate is 

attributable essentially to 137Cs, the container’s dose rate and 137Cs concentration can be 

correlated. Using radionuclide-specific scaling factors, 238Pu, 240Pu, 233U, 234U and other 

radionuclides are quantified by scaling them to the 137Cs content, i.e., the container’s measured 

dose rate. This allows the determination of multiple radionuclides by virtue of a single 

measurement of the container’s dose rate. Scaling factors for the high-gamma and scrap wastes 

were calculated as discussed below. 

High-Gamma Wastes: 

Each canister received its own set of 137Cs-based scaling factors. ORIGEN 2.2 was used to 

develop radionuclide distributions for each of the fuel pins as described in CCP-AK-INL-501 

and documented in References U4043 and U4051. 

The fuel pin segments in each Lot 2 canister were identified and correlated with the ORIGEN 

2.2-generated data for each segment. Fast reactor fuel pins were adjusted to account for observed 

discrepancies between ORIGEN 2.2 results and measured values in fast reactor fuel (i.e., 

benchmark adjustment). Results were further adjusted to account for the fuel segment heavy 

metal ratio divided by 106

. The activities of each radionuclide in a canister were summed and 

divided by the calculated 137Cs activity of that canister to produce the scaling factor for that 

radionuclide. 

Unlike in previous T1 evaluations, EPA was not able to obtain the exact records (for example, 

calculation spread sheets to derive scaling factors) that provided technical support for some 

aspects of the radiological characterization process. This information has been used or is 

necessary for EPA to evaluate the calculations and ensure that they are valid. To address this 

lack of actual records, EPA asked that INL-CCP recreate the specific spreadsheets for EPAselected canisters as a surrogate for actual data. EPA selected a random sample of canisters for 

the high-gamma wastes and a subset of the 583 fuel pins for the debris portion and requested that 

INL-CCP personnel reproduce a sample of the calculations that were deemed to be the most 

important to the development of radionuclide-specific scaling factors. EPA requested that these 

calculations be provided in a workable Excel spreadsheet so that their technical adequacy could 

be assessed directly. The spreadsheets that INL-CCP produced were not intended to be the 

documentation of record and served as a means of confirming the technical adequacy of the 

calculations. Specifically, EPA selected the calculation of scaling factors and estimation of 

uncertainty based on the ORIGEN 2.2 output for two randomly-chosen canisters for the highgamma component, Canister Nos. 19 and 36; additionally, a subset of 12 fuel pins was chosen to 

demonstrate the process for debris (scrap). Because this was a demonstration, the full set of 602 

fuel pins was not used. INL-CCP presented the calculations supporting the characterization of 

the two canisters and debris in three Excel files during an interactive Web conference on 

June 21, 2012. 
28 

From this presentation, EPA determined that the scaling factors calculated for Canister No. 36 in 

the presentation did not match those in CCP-AK-INL-501, Revision 5. Following this discovery, 

DOE determined that this discrepancy was caused by an extra fuel pin being included as part of 

the canister calculations in the original calculation. This was found to be an isolated instance 

affecting only Canister No. 36. As a result, CBFO agreed to amend all documentation to reflect 

this change to Canister No. 36. 

Scrap (Debris) Wastes: 

A single set of 137Cs-based scaling factors was developed for all Lot 2 scrap (debris) waste. 

Because comingling did occur, no single canister can be accurately correlated to the debris 

wastes. To account for this, each of the 602 ORIGEN 2.2 runs was used to calculate a single set 

of scaling factors to represent the scrap waste materials. The debris waste had several more 

ORIGEN 2.2 runs than the total number of canisters because several fuel pins were 

administratively removed from the waste stream. Because comingling did occur in the debris, it 

is still appropriate to include the ORIGEN 2.2 runs corresponding to those pins in the 

calculations for debris scaling factors. 

 

EPA requested CBFO provide a demonstration of the calculation to present the technical details 

of the debris scaling factor generation process. A subset of nine fuel pins was used to 

demonstrate the calculation process without requiring that CBFO regenerate the population of 

602 ORIGEN 2.2 runs. The fuel pin segments were identified and the ORIGEN-generated data 

for each segment were compiled into average scaling factors for the population. Fast reactor fuel 

pins in the debris were adjusted in the same manner as was done for the canisters. Additionally, 

the Reduced Enrichment for Research Test Reactor fuel plates were adjusted by a factor of 1/8.6 

to account for their size relative to the other fuel pins. Radionuclide results were then adjusted to 

account for benchmark analysis and the activities of each radionuclide were summed and divided 

by the calculated 137Cs activity to produce the set of debris scaling factors. 

Upon receipt of documentation indicating that all minor corrections had been made, EPA 

determined that the process of scaling factor development was technically adequate and correctly 

documented for both the high-gamma and debris (scrap) wastes. 

(3) Computer modeling to develop the dose-to-curie correlation was evaluated and was 

found to be adequate. 

Separate modeling was done for the high-gamma and debris wastes to accurately model both 

waste configurations. 

High-Gamma Wastes: 

One-gallon cans of high-gamma waste contain discrete pieces or segments of fuel pins and are 

not commingled, allowing scaling factors to be developed for each individual canister. Modeling 

the dose rate correlation to the drum content was done using MCMP5 in two geometries, 

recoverable and nonrecoverable fissile materials. 

The recoverable fissile materials geometry consists of waste in a wire basket inside a 1-gallon 

container (paint can) overpacked in a 30-gallon drum, overpacked in a 55-gallon drum. The wire 
29 

basket is assumed to be 4 centimeters high in the paint can, though the actual waste height does 

not have significant impact on the calculation. This geometry of waste was assumed to have a 

DTC value of 53.44 milliroentgen per hour per curie 137Cs (mR/hr/Ci) at 1 meter. 

The nonrecoverable fissile materials geometry (either fines or met mounts) has the materials 

placed loosely inside the 30-gallon drum, which is then overpacked in a 55-gallon drum. The 

fines are mixed with Met-L-X at a 5:1 ratio. The material is assumed to occupy a 1-gallon 

volume at the bottom of the 30-gallon container and is assumed to have a height of 2.24 

centimeters, though this assumption does not have a significant impact on modeling. The fines 

are assumed to have a density of 1.3 g/cm3; the met mounts are typically mounted in epoxy, so

their density is assumed to be 1.0 g/cm3. For this geometry, the DTC correlation value at 1 meter 

was found to be 145.5 mR/hr/Ci 137Cs for fines with Met-L-X and 147.9 mR/hr/Ci 137Cs for met 

mounts. Because the difference is minimal, INL-CCP used the average of these two values 

(146.7 mR/hr/Ci 137Cs) for both fines with Met-L-X and met mounts. 

Scrap (Debris) Waste: 

INL-CCP used the MicroShield®

 computer code to develop the DTC correlation for a 30-gallon 

drum containing scrap waste inside a 55-gallon drum. This was based on the assumption that a 

1-curie source of 137Cs was uniformly distributed within the drum and that the only significant 

gamma emitter in the drum was 137Cs. Adjustments for the presence of cobalt-60 (60Co) are 

based on actual measurements taken during DTC using the OSPREY system7 and are recorded 

on the “Waste Container Dose-to-Curie Conversion Record” spreadsheet from the current 

revision of CCP-TP-504. The contributions of other gamma emitters (e.g., europium-154) were 

negligible. This provided the specific correlation of a container’s measured dose rate and 137Cs 

content for waste densities from 0.01 g/cm3 to 2.0 g/cm3. Based on the measured 1-meter dose 

rates, a least-squares curve-fitting routine was used to derive a function relating waste density 

and MicroShield®-calculated dose rates, represented by the following equation: 

Y = 25.625x2 – 116.29x + 184.05 when R2 = 0.9993 

Figure B5-1 of CCP-AK-INL-501, Revision 5, shows the graphical representation of the 137Cs 

correlation, and Reference U4045 details the development of the DTC calculation. 

EPA had no concerns regarding the modeling to develop the dose-to-curie correlation for highgamma and debris waste. The use of any alternate scaling factors other than those documented in 

CCP-AK-INL-501, Revision 5, remains a T1 change. (See Table 1.) 

(4) Correlation of radionuclide values to the 137Cs concentration for each drum was evaluated 

and was found to be technically adequate and appropriately documented. 

INL-CCP applied the DTC correlation factor to determine the 137Cs concentration in each drum 

using the arithmetic mean of four 1-meter dose measurements, made at the vertical midpoint at 

four 90-degree intervals. This value was divided by the DTC correlation factor corresponding to 

 

7

 INL-CCP uses the term “Gamma Spectroscopy” to refer to the OSPREY gamma system that provides the 

contribution of 60Co to each container’s dose rate. See EPA Docket No. A-98-49; II-A4-131 for EPA’s July 2010 

evaluation of the OSPREY. 
30 

the waste density. INL-CCP used the dose measurements with radionuclide-specific scaling 

factors to quantify the following radionuclides: 233U, 234U, 235U, 238U, 238Pu, 239Pu, 240Pu, 241Pu, 

242Pu, americium-241 (241Am), 137Cs, barium-137m (137mBa, 137Cs progeny), strontium-90 (90Sr), 

and yttrium-90 (90Y, 90Sr progeny). This list goes beyond the 10 WIPP-tracked radionuclides 

because all radionuclides that contribute to at least 95% of the radionuclide hazard, at least 95% 

of the thermal loading, and any radionuclide that contributes greater than 1% of the total must be 

reported, which includes 137mBa and 90Y.8

 Additionally, the 235U value must be considered for 

criticality purposes. The determination of radionuclide activities by INL-CCP for Lot 2 is 

technically adequate and correctly documented. 

(5) The technical basis and documentation of total measurement uncertainty were evaluated 

and found to be adequate. 

The development of total measurement uncertainty (TMU) for Lot 2 is based on the propagation 

of uncertainties present in 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.9 The 

TMU determination included contributions of the following: 

•

137Cs DTC correlation (for debris waste) – MicroShield® code, MicroShield® modeling, 

and waste density uncertainties. 

•

137Cs DTC correlation (for high-gamma waste) – MCNP5 code, MCNP5 modeling, and 

waste density uncertainties. 

•

137Cs activity measurement – dose rate measurement uncertainty and uncertainty due to 

the contribution of other gamma-emitting radionuclides. 

• Scaling factor uncertainty – sample data uncertainty (except 233U and 242Pu), isotopic 

fractions uncertainty (239Pu and 240Pu). 

• Material distribution – uncertainty as a result of the variation in material distribution 

between drums. 

A general treatment of TMU is presented in CCP-AK-INL-501, Revision 5, and the detailed 

treatment of TMU is provided in Calculation Package INL-RH-117, Revision 0 (Reference 

U4046) for debris (scrap). Each of the 48 canisters of high-gamma waste has its own calculation 

package to document its TMU derivation. Each package is designated INL-RH-113-XX, 

Revision 0 (Reference U4049-XX), where “XX” refers to the number of the specific canister. 

The overall uncertainties are consistent with what EPA has observed for RH determinations at 

other RH TRU generator sites. 

Based on EPA’s request, CBFO prepared Excel spreadsheets that documented the detailed 

calculation of uncertainties for randomly chosen Canister Nos. 19 and 36 and a subset of the 

 

8

 Transportation is not within EPA’s regulatory purview; however, this information may be useful in 

understanding a container’s radionuclide composition. 

9

 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 what would be obtained if the values 

were simply added. 
31 

debris (scrap) waste. This demonstration showed that uncertainty calculations were consistent 

with calculations of TMU for other waste streams. EPA had no concerns regarding the 

calculation of TMU for the canisters based on this demonstration. 

(6) Execution and documentation of the dose-to-curie and gamma spectroscopy techniques 

were assessed and found to be adequate. 

EPA observed the DTC technique on May 10, 2012, at INTEC in Building 659, Room 306. The 

INL-CCP DTC operator was David Pinnock, who was listed on the current list of qualified 

individuals (see below). DTC personnel began by performing the operational check on Scale No. 

724422, which was last calibrated on March 21, 2012, and is due for recalibration on March 21, 

2013. This check was not witnessed by EPA inspectors but was documented appropriately in the 

logbook. The operator weighed the drums and recorded the weight on the Measurement Control 

Report (CCP-TP-504, Revision 12, Attachment 2) and summarized this activity in the 

operational logbook. 

DTC personnel performed the source checks for Thermo Scientific Model FH 40 G Dose Rate 

Measuring Unit with FHZ 612 Probe (Instrument No.) attached to Probe No. XC0674, with the 

option of using Probe No. XC0675. The ambient background was measured and source checks 

were performed for the high and low ranges, and all measurements were recorded on the 

Measurement Control Report and summarized in the operational logbook. DTC personnel 

consulted “CCP Operator Aid: RH-DM-INL-002, Revision 15, 4-09-12,” which listed tolerances 

for the test drum weights, scale error, operational ranges for the Geiger Mueller probes and 

acceptance criteria for the source checks. DTC operators also performed a source check for the 

OSPREY LaBr10 Probe No. 13000014 using 137Cs source No. 1181-64 INL 1D; CP-7CS001 

positioned with the appropriate jig. DTC operators took a background dose reading while all 

containers were in a shielded position. 

EPA observed an overhead crane lift Drum No. ANLE96 onto the DTC assembly, and four 

measurements were made on the drum’s circumference (0°, 90°, 180° and 270°). All 

measurements were recorded on the container data sheet (CCP-TP-504, Revision 11, Attachment 

2), a copy of which was provided to EPA. Contact dose rates for all valid RH drums in the DTC 

BDR exceeded 200 mrem/hr, and in many cases, the 1-meter readings were greater than 200 

mrem/hr. All contact dose rate readings exceeded three times the measured background of 0.2 

milliroentgen per hour (mR/hr), and all measurements and accompanying parameters were 

acceptable. EPA received copies of the DTC and OSPREY measurement control reports and the 

DTC and OSPREY container data sheet for Drum No. ANLE96. INL-CCP provided the list of 

qualified individuals dated February 13, 2012, for DTC and OSPREY documenting that all DTC 

personnel were appropriately trained. 

EPA had no concerns regarding the execution and documentation of the DTC and OSPREY 

techniques. 

 

10 The OSPREY detector is a cerium-drifted lanthanum bromide crystal [La3Br(Ce)]. 
32 

(7) Radionuclide documentation in dose-to-curie batch data reports was assessed and found 

to be adequate. 

Only BDR No. INLRHDTC12002 was available at the time of the EPA inspection. This BDR 

contains characterization information for 20 drums. The EPA inspection team verified that this 

BDR included the following: 

• Site project manager (SPM) checklist, Attachment 8.

• BDR cover sheet, Attachment 4. 

• BDR table of contents, Attachment 5. 

• BDR narrative summary, Attachment 6. 

• Independent technical reviewer (ITR) review checklist, Attachment 7. 

• Measurement control report with all parameters acceptable, Attachment 1. 

• Container data sheets, Attachment 2. 

• Gamma spectroscopy daily checklist and measurement controls, Attachment 9. 

• Duplicate container data sheet, Attachment 10. 

• Relative percent difference determination documentation from duplicate drum 

measurement. 

• Waste container DTC conversion records with all required parameters. 

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

• Type of waste in each container on Attachment 3, organic and inorganic. 

• TRU determination for all containers on Attachment 3. 

• Correct revision of CCP-TP-504 (Revision 12). 

Some of the containers were rejected due to contact dose rates less than 200 mrem/hr, as 

discussed in Item (8) below. The DTC BRD was acceptable. 

(8) Remote-handled determinations were evaluated and found to be adequate. 

The determination that each container in the stream was RH (i.e., had a contact dose rate in 

excess of 200 mrem/hr) is based on measurements that are performed directly prior to shipment. 

Typically, a 1-meter dose rate is measured, and this value is then converted to a contact dose rate 

via application of a dose conversion factor (DCF). INL-CCP used DCF values from EDF-10217, 

which provided neutron and gamma values for debris (scrap), high-gamma fines, fuel-like pieces 

and nonrecoverable materials, as well as limits for their application. INL-CCP applied these 

factors to external neutron and gamma dose rate measurements that were taken during February 

and March 2012, as documented on radiological survey reports, Form 441.15, Revision 05. Each 

form stated the gamma and neutron DCFs that were applied to the 1-meter reading to produce a 
33 

contact dose rate. Several drums were rejected as RH because they had contact dose rates less 

than 200 mrem/hr. EPA had no concerns regarding the RH determinations for Lot 2 waste. 

(9) TRU determinations were evaluated and were found to be adequate. 

DTC BDR No. INLRHDTC12002 contained values and the associated uncertainties for the 10 

WIPP-tracked radionuclides plus other radionuclides, as appropriate. In all cases the TRU alpha 

concentration exceeded 100 nanocuries per gram. EPA had no concerns regarding the TRU 

determinations for Lot 2 waste. 

Summary of Radiological Characterization Findings and Concerns

The EPA evaluation team did not identify any radiological characterization findings or concerns 

relative to the inclusion of Lot 2 waste in Waste Stream ID-ANLE-S5000 during this T1 change 

evaluation. 

Changes to Tiering

Based on the results of this evaluation, there are no changes to the radiological characterization 

T1 or T2 designations as identified during the baseline inspection and subsequent T1 evaluations. 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the radiological characterization process 

for the Lot 2 waste. 

6.3 Real-Time Radiography 

EPA reviewed written and audiovisual RTR data, generated by INL-CCP, for waste drums 

reported in BDR No. INLRHRTR12002. The drums examined were generated during 

repackaging of the original waste containers prior to characterization. Two internal packaging 

configurations of 55-gallon drums were identified during RTR examination of Lot 2 containers. 

One waste configuration consisted of an internal 30-gallon metal drum containing “fines and 

MET-L-X” and scrap plastic; the second configuration consisted of a gallon paint can and 

general debris items contained within an internal 30-gallon metal drum. 

Prior to examination of the drums, RTR operators correctly verified the resolution of the RTR 

unit by performing a measurement control determination. This examination was reported on 

Attachment 1, CCP RTR Measurement Control Report, of Procedure CCP-TP-508, CCP RH 

Standard Real-Time Radiography Inspection. Required quality control examinations, in the form 

of an independent observation and replicate scan, had been performed on Lot 2 drums as 

required by the RTR procedure. RTR data were recorded on “Attachment 2, CCP Radiography 

Data Sheet,” by a trained operator at the time of the examinations. Operators are employed by 

CWI but trained to CCP procedures and have onsite access to experienced CCP RTR personnel 

in case of questions or difficulties encountered during examinations. Data were reviewed at the 
34 

data generation and SPM level; the reviews were recorded on the appropriate attachments from 

Procedure CCP-TP-508. No prohibited items were found in any of the BDR containers. 

On May 8, 2012, EPA inspectors observed the RTR examination of Drum No. ANLE9B, from 

this waste stream, during a visit to the INL INTEC facility. The operator performed the 

necessary equipment checks prior to EPA’s arrival. EPA observed the entire RTR examination of 

the drum, including generation of the written and audiovisual records. Waste items were 

identified by the operator on the audiovisual recording and entered electronically into RTR data 

sheets. The operator used Procedure CCP-TP-508 to guide the examination and record 

generation. This procedure includes detailed operational instructions and the required RTR forms 

used by operators. EPA inspectors determined the procedure to be adequate and effective for 

generation of compliant RTR data. EPA reviewed several lists of qualified individuals and 

determined that the operator performing the demonstrated RTR examination and those 

responsible for generation and review of BDR No. INLRHRTR12002 were properly qualified. 

The EPA inspectors reviewed training records, both written and audiovisual, for operators 

performing the RTR examinations identified above. A concern not requiring a response, INLCCP-RH-T1-Lot 2-RTR-01C (reproduced in full in Appendix C), was identified with regard to 

training of RTR operators, as follows: 

During the review of RTR at INL-CCP, EPA identified occurrences that indicate 

a potential issue with respect to the generation of RTR data and training 

procedures, as follows: 

(1) The RTR operator made errors in seven of the twenty containers reported in 

BDR No. INLRHRTR12002; the errors were identified and corrected by the 

RTR Independent Technical Reviewer (ITR). 

(2) The two training containers Nos. NDE-Training-12 and -17, which were 

constructed one year apart, contain the same items.

(3) The non-WAP [Waste Analysis Plan] items in the two training containers do 

not include “plastic” other than plastic bottles that are required by the WAP. 

EPA requests that INL-CCP/CBFO consider this concern and evaluate it with an eye 

towards ensuring that RTR remains compliant with 40 CFR 194 going forward. 

Summary of Real-Time Radiography Findings and Concerns

EPA determined that RTR data for Lot 2 of Waste Stream ID-ANLE-S5000 were generated in 

accordance with CCP, WCPIP and 40 CFR Part 194 requirements. No findings or concerns 

requiring a response were identified. 

Changes to Tiering

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

identified during the baseline inspection and subsequent T1 evaluations. 
35 

Real-Time Radiography Approval

Based on the results of this evaluation, EPA approves the process of RTR for determining the 

physical contents of the Lot 2 waste portion of Waste Stream ID-ANLE-S5000. 

7.0 CONCLUSIONS 

EPA concluded that the waste characterization processes of AK, radiological characterization 

and RTR used to characterize RH TRU Lot 2 waste as part of INL Waste Stream 

ID-ANLE-S5000 are adequate, as evidenced by the records evaluated. There are no open issues 

relative to this T1 evaluation.

EPA is accepting the use of freeze files to serve as objective evidence that the revisions to 

documents are appropriate for this T1 approval. CBFO must provide the formal, approved 

version of all revised documents to EPA no later than the end of the calendar quarter. All freeze 

files that support EPA’s approval of this T1 evaluation must be provided to EPA no later than 

September 30, 2012. 

Summary of Findings and Concerns

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

characterization or RTR. EPA identified one concern during the inspection related to RTR, 

which did not require a response. The concern is discussed above, and a copy of the EPA 

Inspection Issue Tracking Form recording this issue is provided in Attachment C. The concern 

was adequately addressed and there are no open concerns resulting from this T1 evaluation. 

Tiering Changes

Based on this evaluation, EPA has not added any new AK, radiological characterization or RTR 

T1 or T2 change requirements. However, EPA has revised Table 1 to be consistent with more 

recent tiering changes resulting from T1 approvals since the baseline approval of January 2007. 

Approval

This T1 change consisted of the evaluation radiological characterization technique for the Lot 2 

waste as part of INL Waste Stream ID-ANLE-S5000, along with a review of AK and RTR. 

Based on the results of this evaluation, EPA approves this T1 change for Lot 2 of Waste Stream 

ID-ANLE-S5000, consistent with the limitations specified in this report. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP 

REMOTE-HANDLED WASTE CHARACTERIZATION PROGRAM 

Specific INL RH Approval Date EPA Docket Number 

INL RH Baseline Approval January 2007 A-98-49; II-A4-72 

Tier 1 Change – Approval of Visual Examination January 2007 A-98-49; II-A4-75 

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

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

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

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

Tier 1 Change – Addition of Twelve Containers to Waste Stream 

ID-ANLE-S5000 and Addition of Waste Stream ID-HFEF-S5400-RH January 2010 A-98-49; II-A4-122 

Tier 1 Change – Approval of Waste Stream ID-MFC-S5400-RH June 2010 A-98-49; II-A4-126 

Tier 1 Change – Approval of Waste Stream ID-INTEC-S5400-RH August 2010 A-98-49; II-A4-130 

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

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

Tier 1 Change – Approval of Waste Stream IN-ID-NRF-153 November 2010 A-98-49; II-A4-135 

Tier 1 Change – Approval of Waste Stream ID-RTC-S3000 November 2010 A-98-49; II-A4-137 

Tier 1 Change – Addition of Lot 4A to Waste Stream 

ID-HFEF-S5400-RH March 2011 A-98-49; II-A4-145 

Tier 1 Change – Approval of Waste Stream IN-ID-NRF-SPC March 2012 A-98-49; II-A4-159 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED FOR THIS EVALUATION 

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

for Remote-Handled Transuranic Debris Waste from Argonne National Laboratory-East Stored 

at the Idaho National Laboratory, Waste Stream: ID-ANLE-S5000, Revision 10, March 23, 

2012, and Revision 11, Draft Markup, May 3, 2012 

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

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from Idaho 

National Laboratory, Revision 5, November 4, 2011, and Revision 6, In preparation 

CCP-AK-INL-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance for INL RH Waste Stream: ID-ANLE-S5000, Revision 5, 

November 9, 2011 

CCP-TP-002, Revision 19, CCP Reconciliation of DQOs and Reporting Characterization Data, 

Attachment 2 – CCP Waste Stream Profile Form, December 22, 2006 

CCP-TP-002, Revision 24, CCP Reconciliation of DQOs and Reporting Characterization Data, 

Attachment 2 – CCP Waste Stream Profile Form (Example) Revision, Draft Revision 1, April 4, 

2012, and Draft Revision 2, May 4, 2012 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 22, April 21, 2011, 

Revision 23, June 30, 2011, and Revision 24, November 28, 2011 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 5 – 

Hazardous Constituents, November 16, 2006 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, November 16, 2006 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, June 30, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers, June 30, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, November 28, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, November 28, 2011 
B-2 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, November 28, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, November 28, 2011 

CCP-TP-504, Revision 12, CCP Dose-to-Curie Survey Procedure for Remote-Handled 

Transuranic Waste, Attachment 1, Measurement Control Report, May 8, 2012 

CCP-TP-506, Draft Characterization Reconciliation Report, Revision 1, [undated], and 

Revision 2, [undated] 

CCP Operator Aid: RH-DM-INL-003, Revision 0, May 25, 2010 

CCP Operator Aid: RH-DM-INL-002, Revision 15, April 9, 2012 

C001, Fax to Larry Neimark Re: Defense Versus Non-Defense Waste, Gary Marshall, January 

21, 1997 

C006, Interview with Larry Neimark Re: AGHCF Samples, Applicable Programs, Defense 

Relationship to Materials, and Commingling of Waste, Cheryl Schultz, Record of 

Communication: ROC-C6, July 17, 2001 

C011, Intra-Laboratory Memo to D.A. Donahue, MCT, Re: Work Plan for the Examination of 

LILY-1 and LILY-1A Specimens, L.A. Neimark, MCT, November 28, 1988 

C036, Letter to Sheldon Meyers, Deputy Assistant Secretary for Nuclear Waste Management, 

Re: Disposition of TRU from LWR Program: Documentation of Agreements Reached in August 

15, 1980 Meeting, Robert H. Bauer, Manager/Regional Representative, September 9, 1980 

C046, Intra-Laboratory Memo to D.D. Parzyck Re: DOE Request for Information Regarding 

Materials Not Classified as Waste, Aubrey C. Smith, MCT/MSD Environmental Compliance, 

March 13, 1991 

C066, Record of Communication with Bill Kettman and Dennis Donahue, AGHCF, Re: AGHCF 

Operations and Waste Packaging, J. Whitworth and M. Wyco, August 7, 2001 

C068, Correspondence to Craig R. Tyler, Lockheed Martin Idaho Technologies Co., Re: ANL 

Transuranic Waste – Definition as Defense Waste, D.S. Kirschner, Manager, Radiation, Fire and 

Safety, April 16, 1997 

C074, Letter to Mr. Hilary Rauch, Manager, U. S. Department of Energy Re: “TREAT 

Experiment Program,” R. Avery, Director, Reactor Analysis and Safety Division, 2694, April 4, 

1985 
B-3 

C092, Intra-Laboratory Memo to J.L. Hooper, DOE (ARG), Re: Experimental Fuel Segments in 

the AGHCF, L.A. Neimark, ANL (ET), June 7, 1996 

C103, Intra-Laboratory Memo to C.A. DeLorenzo, OOS, Re: Safety Analysis for Handling 

Tritium-Containing Compounds in the AGHCF, L.A. Neimark, MST, May 30, 1984 

C108, Correspondence to Mr. J.T. Case, U.S. Department of Energy, Idaho Field Office, Re: 

Strategy Plan for Long-Term Management and Storage of Remote-Handled (RH) Transuranic 

(TRU) Waste – TLC-224-92, T.L. Clements, Jr., Manager Transuranic Waste Programs, TLC224-92, November 30, 1992 

C124, Fax to Mark Wyco and Larry Neimark, ANL-E, Re: Request for ANL-E to Identify Items 

of ANL-W Origin, Julia Whitworth, IT Corporation, February 21, 2002 

C125, Intra-Laboratory Memo to Steve Gehl, MSD, Re: Burnup on LWR Samples, 

E.R. Ebersole, AL-AW, October 22, 1975 

C152, Intra-Laboratory Memo to D.A. Donahue, MCT/IPS, Re: Work Plan for the Examination 

of LILAC Target NO. 19 for Battelle Pacific Northwest Laboratories, L.A. Neimark, MCT/IPS, 

IPS-46-00-00, May 3, 1991 

C305, Memo from R.J. Page and A. Miron to T.S. Bray, Subject: Inventory and Dose Estimates 

for Radionuclides Stored in the Alpha-Gamma Hot Cells Facility, Report Attached, R.J. Page 

and A. Miron, May 2, 2003 

C330, Memorandum to Ines Triay, Acting Manager, CBFO: Determination and Findings, 

Defense Origin of Nuclear Waste, Kerr-McGee Waste, F. Marcinowski, April 15, 2005 

C332, Memorandum to CCP Records: Assessment of Waste Material Parameters for Waste 

Stream ID-ANLE-S5000, B. Becker, [undated] 

C348, Evaluation of Generator Reported Radionuclides for Waste Stream ID-ANLE-S5000, 

S. Schafer, September 19, 2007 

C381, Results of Document Review Relating to the AK Available for RH TRU Waste 

Containers Generated in the Building 200 K-Cells at ANLE, K. Peters, October 23, 2007 

C1031, K.J. Peters, Summary of AK Research for 12 Drums Generated in the Building 200 M 

Wing to Be Included in Waste Stream ID-ANLE-S5000, July 10, 2009 

C3464, Email to Mike Papp Re: HFEF Repackaging Operations, Keith Farmer and Tom 

Clements, March 3, 2009 

C3660, Evaluation of 51 ANL-E High Gamma TRU Waste Containers Stored at the MFC 

Radioactive Scrap and Waste Facility to Be Added to Waste Stream ID-ANLE-S5000, S. Smith, 

September 30, 2009 
B-4 

C3698, Email to Tom Clements Re: Operation of CCP-666, Gerald G. Streier, July 28, 2009 

Calibration Certificate, Source 100 mCi Cs-137, Amersham X.8 Capsule, S.N. 8435 GM, 

J.L. Shepherd & Associates Series 10 Beam Portable Calibrator, S.N. 11025, April 4, 1984, and 

Radioactive Source Calculation Worksheet, Source ID No. 98007, November 26, 2007 

Central Characterization Project, Real-Time Radiography (RTR) Operator/Independent 

Technical Reviewer (ITR) for Remote-Handled (RH) Waste at Idaho National Laboratory (INL) 

Qualification Card, RH-RTR-01, Revision 3, April 27, 2011, for two individuals, Badge Nos. 

52699 and 71653 

Certificate of Calibration Gamma Standard Source, No. 1181-164, IND ID: CP7CS001, Isotope 

Products Laboratories, March 22, 2006 

Characterization Information Summary, WSPF # ID-ANLE-S5000, Lot 31, Draft, [undated] 

Documentation of Calculations: Canister No. 19, Canister No. 36 and Debris Waste, Three Excel 

Files for Web Presentation, D. Ott, June 21, 2012 

DTC BDR No. INLRHDTC12002 

Engineering Calculations and Analysis Report, TEM-10200-1, Revision 0, ECAR No. 89, 

Calibration Verification of INTEC-980017 100-mCi Cs-137 RAM Calibration Source, 

November 26, 2007 

INL-CCP, 2006, INL Fuel Pin, Master Spreadsheet, Revision 4, provided to EPA during the INL 

RH Baseline Inspection, 2006 

INL-RH-AKTSS [AK Tracking Spreadsheet], downloaded April 25, 2012 

Inter-Office Correspondence from Irene Quintana to CCP Records Custodian, Acceptable 

Knowledge Accuracy Report: Idaho National Laboratory ID-ANLE-S5000, Lot 31, 

March 23, 2012 

List of Qualified Individuals, RH Program – INL, February 13, 2012, March 1, 2012, May 2, 

2012 

Neutron and Gamma-Ray Dose Conversion Factors from 1-Meter to Contact for ANL-E 

Canisters (Lot 2) Repackaged Waste, Idaho Cleanup Project, EDF-10217, Revision 0, March 19, 

2012 

P001, AGHCF Operations Manual, Argonne National Laboratory, IPS-2-00-00, Revision 0, 

June 20, 1989, Revision 1, March 29, 1990, and Revision 2, September 10, 1990 

P002, Central Characterization Project Acceptable Knowledge Summary Report for Argonne 

National Laboratory-East Contact-Handled TRU Waste Facility Maintenance and Laboratory 
B-5 

Operations, Central Characterization Project (CCP), CCP-AK-ANLE-001, Revision 11, 

December 31, 2003 

P006, W.D. Jackson, Alpha-Gamma Hot Cell Facility, Materials Science Division, Argonne 

National Laboratory, Safety Analysis for Twenty Year Retrievable Storage of Intermediate 

Gamma Level Transuranic Waste, June 1, 1976 

P009, TRU-RH Waste Certification Plan for Waste Management Operations, Ralph W. Ditch 

and Gary E. Griffin, J0306-0033-SA, Revision 2, November 10, 1986, and Revision 4, 

April 16, 1991 

P018, Certification and Venting Plan for Remote-Handled Transuranic Waste Stored at the Idaho 

National Engineering Laboratory, H.D. Welch, AGG-WM-PD-92-010, September 1, 1992 

P025, Argonne National Laboratory-East, Transuranic Waste Acceptable Knowledge Report, 

Benchmark Environmental Corporation, A ThermoRetec Company, WMO-AK/WIPP-001.0, 

September 29, 2000 

P028, Presentation to DO Office of Nuclear Safety Re: Alpha-Gamma Hot Cell Facility 

(AFHCF), Argonne Illinois Site, July 19, 1993 

P032, Procedure for Sorting Remote-Handled TRU Waste (30-Gallon Intermediate-Level 

Waste), Alpha-Gamma-Hot Cell Facility Irradiation Performance Section Materials and 

Components Technology Division, January 7, 1987 

P058, AGHCF Operations Manual: 15.0 Nuclear Materials Management, IPS-2-00-00, Revision 

1, March 26, 1990 

P063, SPM Procedure for High Gamma Transuranic Waste Handling from Alpha Gamma Hot 

Cell Facility (AGHCF) Building 212, MSD, ANL-E, January 20, 1975 

P067, Procedure for High Gamma Level Transuranic Waste Handling at the AGHCF, MSD, 

ANL-E, M1002-0047-SP-00, December 30, 1974 

P320, Management Plan for Irradiation Performance Section Facilities, Energy Technology 

Division, H. Drucker, IPS-417-00-00, Revision 0, October 14, 2002 

P585, Safety Issues at the DOE Test and Research Reactors, A Report to the U.S. Department of 

Energy, National Academy Press, 1988 

P586, Report to Congress – The Liquid Metal Fast Breeder Reactor Program – Past, Present, and 

Future, ERDA, RED-75-352, April 28, 1975 

P599, The Defense Programs Origin of Transuranic Waste at Argonne National LaboratoryWest, H.F. McFarlane, ANL-NT-192, November 2011 
B-6 

P835, Chemical Engineering Division Annual Technical Report for 1980, L. Burris, D.S. 

Webster, D.L. Barney, F.A. Cafasso, and M.J. Steindler, ANL-81-38, June 1981 

P1001, From Test Tube to Pilot Plant; A 50 Year History of the Chemical Technology Division 

at Argonne National Laboratory, R.K. Steunenberg and L. Burris, ANL-00/16, August 2000 

P2040, Idaho National Laboratory, Radioactive Scrap and Waste Facility Storage Liner System, 

Document ID: SDD-225, Revision 0, Effective Date June 16, 2008 

P3089, AK Summary Documentation RH TRU Packaging, RPT-456, October 2007, 

November 2007 

P3115, Decontamination Cell Operation in CPP-659, Idaho Cleanup Project, TPR-7298, 

Revision 7, June 4, 2008, and Revision 14, June 16, 2009 

P3182, Packing Configurations for Repacked TRA and ANL-E RH-TRU Waste, Greg Hulet, 

EDF-8860, Revision 0, August 18, 2008 

P3657, Radioactive Scrap and Waste Facility – Liner Characterization Stage 2, B. Welty, PLN3209, Revision 0, June 30, 2009 

P4119, Engineering Design File, Argon Repackaging Station (ARS) Process Description, 

March Sherick, EDF-10025, Revision 0, May 23, 2011, and Revision 1, June 8, 2011 

Radiological Survey Reports, Revision 5, for Drum Nos. ANLE29A, ANLE29B, ANLE29C, 

ANLE29D, ANLE29E, ANLE30C, ANLE30E, ANLE32A, ANLE32B, ANLE32C, ANLE32D1, ANLE32E, ANLE32F, ANLE32G, ANLE32H, ANLE33A, ANLE33B, ANLE33C, 

ANLE33D, ANLE33F, ANLE33G, ANLE33H, and ANLE33I, dates ranging from February 27, 

2012, to March 5, 2012 

Remote-Handled Dose to Curie Operational Logbook 2012, CCP-INL-RH-DTC-007, Idaho 

National Laboratory, INTECT CPP-659 

Remote Handled (RH) Mixed Heterogeneous Debris Waste from the Argonne National 

Laboratory-East (ID-ANLE-S5000) Change Notice #1 Update for WIPP Operating Record, 

Revision 0, July 16, 2007 

RH TRU Waste Correlation and Surrogate Summary Form, Argonne National Laboratory 

Generated RH TRU Waste Stored at Idaho National Laboratory, Waste Stream ID-ANLES5000, [undated] 

RTR BDR No. INLRHRTR12002 

U001, AGHCF Position Statement Regarding Defense Versus Non-Defense TRU Waste, 

April 7, 2000 
B-7 

U002, Draft Proposal for: Alpha-Gamma Hot Cell Facility Waste Management Plan, [undated] 

U007, Material Control Sheets for A/G Numbers 1 through 510 and Some Attached Paperwork, 

[undated] 

U009, Transuranic Waste at Argonne National Laboratory-West: Meeting the Waste Acceptance 

Criteria for the TRU Repository, August 10, 2001 

U013, Waste Stream Fissile Content, March 23, 1990 

U015, RH-TRU 1995, Drums 798 to 809, January 1, 1995 

U017, RH-TRU 1994, Book 8, Drums 778 to 797, [undated] 

U023, Fuel Shipments into AGHCF 1993-1995, July 8, 1997 

U040, Spreadsheet Correlating Number Quota with Quota Title and Number Project, July 31, 

2001 

U045, Material Receipt and SPM Data for AG# 285, W.P. Kenney and D. Garcia, January 4, 

1985 

U076, AGHCF Fissile Inventory Management System Database, [various dates] 

U307, Report 105 – Custodian Batch Balance (Pure), Report 105, December 1, 2004 

U342, SAREF Safety Program Environmental Impact Assessment, 1975 

U1003, Argonne Special Material Receipt and Transfer Documentation by A/G Number (A/G 1-

535), ANLE, 1964–1997 

U3552, Compilation of MFC Liner Documents, various dates 

U3607, Excel Spreadsheet: Information for 108 MFC RH-TRU Liners, Reese Gannon, February 

11, 2009 

U3900, Collection of Retrievable Storage Canister Data, Irradiated Hi-Level Gamma 

Transuranic Scrap Material Forms (SPM-50), Argonne National Laboratory-East, Kent R. Zeich, 

Robert F. Gronemeyer, C.R. Rutkowski, E.J. Kasmar, and H.J. Howard, March 6, 1975, through 

November 1, 1984, not inclusive 

U3901, Collection of Handwritten Retrievable Storage Canister Data Irradiated Hi-Level 

Gamma Transuranic Scrap Material Sheets and Associated Paperwork, various authors, February 

6, 1975, through October 18, 1991, not inclusive 
B-8 

U4025, CCP Calculation Package: Determination of Reportable Radionuclides – HFEF Lot 2, 

J. Holderness, INL-RH-110, Revision 0, October 25, 2011 

U4032, RH TRU Container Repackaging Datasheets for ANLE Canisters in Waste Stream IDANLE-S5000, INL CWI, FRM-880, various dates 

U4042, CCP Calculation Package: HFEF Fuel Information Input Check, J. Vance, INL-RH-107, 

Revision 0, October 25, 2011 

U4043, CCP Calculation Package: ORIGEN2.2 Analysis of HFEF Lot 2 High Gamma TRU 

Waste, J. Holderness, INL-RH-109, Revision 0, October 25, 2011 

U4044, CCP Calculation Package: HFEF Lot 2 Debris Waste Scaling Factors, J. Holderness, 

INL-RH-115, Revision 0, October 25, 2011 

U4045, CCP Calculation Package: HFEF Lot 2 Debris Cs-137 DTC Correlation, J. Holderness, 

INL-RH-116, Revision 0, October 25, 2011 

U4046, CCP Calculation Package: HFEF Lot 2 Debris Uncertainty, J. Holderness, INL-RH-117, 

Revision 0, October 25, 2011 

U4047, CCP Calculation Package: DTC Spreadsheet HFEF Lot 2 Debris Waste, J. Holderness, 

INL-RH-118, Revision 2, March 20, 2012 

U4048, CCP Calculation Package: HFEF Lot 2 Fuel Segment Mass Input Check, J. Holderness, 

INL-RH-108, Revision 0, October 25, 2011 

U4049-1, CCP Calculation Package: HFEF Lot 2 High Gamma TRU Uncertainty – Canister 1, 

J. Holderness, INL-RH-113-1, Revision 0, June 27, 2012 

U4051, CCP Calculation Package: HFEF Lot 2 High Gamma TRU Waste Scaling Factors, 

J. Holderness, INL-RH-112, Revision 0, October 25, 2011 

U4052, CCP Calculation Package: DTC Spreadsheet HFEF Lot 2 High Gamma TRU Waste 

Scaling Factors, J. Holderness, INL-RH-114, Revision 2, March 20, 2012 

U4053, CCP Calculation Package: DTC Values for Met Mounts and Fines, J. Holderness, INLRH-119, Revision 0, November 6, 2011 

U4054, CCP Calculation Package: DTC Values for Fuel Segments in Centered Containers, 

J. Holderness, INL-RH-120, Revision 0, November 6, 2011 
C-1 

ATTACHMENT C 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. 

INL-CCP-RH-RTR-2012-01C, FINAL 

Inspection No. INL-RH-T1-Lot 2 Issue Number: INL-CCP-RH-T1-Lot 2-RTR-01C 

Date: May 9, 2012 

Inspector: D. Gill 

Attachments? YES NO 

Sample Size: 1 BDR (20 Containers) 

Population size (if known): 1 BDR (20 Containers) 

Description of Issue: During the review of RTR at INL-CCP, EPA identified occurences that indicate 

a potential issue with respect to the generation of RTR data and training procedures, as follows: 

(1) The RTR operator made errors in seven of the twenty containers reported in BDR No. 

INLRHRTR12002; the errors were identified and corrected by the RTR Independent Technical 

Reviewer (ITR). 

(2) The two training containers Nos. NDE-Training-12 and 17, which were constructed one year apart, 

contain the same items. 

(3) The non-WAP items in the two training containers do not include "plastic" other than plastic bottles 

that are required by the WAP. 

EPA Requests that INL-CCP/CBFO consider this concern and evaluate it with an eye towards ensuring 

that RTR remains compliant with 40 CFR 194 going forward. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: I. Quintana, M. Pinzel, M. Sensibaugh 

E. Additional Comments: None

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Not applicable