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 P ROGRAM

FOR IDAHO NATIONAL LABORATORY:

ADDITION OF LOT 2 WASTE TO WASTE STREAM ID-ANLE-S50 00

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 2012ii 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 P rocesses Implemented by INL-CCP ........ 3

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

................................................... ............................. 7

Table 3. Characterization Methods for the Waste Str eam ............................................... ............. 12 Table 4. Shipment, Storage and Repackaging Traceabi lity Analysis for Canister No. ANLE33 19 Table 5. Correlation of Can and Repackaged Drum Con tents, Canister No. ANLE33 ................ 20 Table 6. AK Training Qualification Summary ........

................................................... .................. 21

TABLE OF FIGURES

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

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

................................................... .............. 25 Figure 2. Flow Diagram of the Characterization Proc ess: Recoverable and Nonrecoverable

Fissile Material from Debris Waste Stream ID-ANLE-S 5000 ...................................... 26

ATTACHMENTS

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

Attachment B: List of Documents Reviewed Attachment C: EPA Inspection Issue Tracking Formiii 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/cm 3 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 Cent eriv

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 C omputer 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 C ode

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 Solutionsv

WWIS WIPP Waste Information System

Y yttrium1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s or the Agency’s) Tier 1 (T1) approval of the radiological process fo r containers of retrievably stored, remotehandled (RH) high-gamma transuranic (TRU) fuel spec imens 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 Laborato ry (INL). These Lot 2 wastes are proposed for addition to INL Waste Stream ID-ANLE-S 5000. 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 radiogr aphy. The results of EPA’s evaluation confirm that Lot 2 waste packaged in 55-gallon drum s can be added to Waste Stream

ID-ANLE-S5000.

The Central Characterization Project (CCP) is respo nsible for characterizing the above wastes using the system of controls that EPA evaluated dur ing 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 wa ste 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 scal ing 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 rad iological characterization processes, including dose-to-curie (DTC), and the real-time ra diography (RTR) were inspected at INL near Idaho Falls, Idaho, on May 8–9, 2012; the AK inspec tion 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 proc ess for the Lot 2 waste from ANL-E as part of

INL Waste Stream ID-ANLE-S5000. The Lot 2 wastes ar e divided into high-gamma TRU waste, including irradiated fuel pin test specimens and sc raps, and trash debris associated with the processing of the high-gamma TRU waste. INL-CCP dev eloped one set of scaling factors for all containers of the Lot 2 debris, also sometimes call ed “scrap” in the INL-CCP documentation, and developed individual scaling factors for each c anister 1 containing high-gamma TRU waste, also sometimes called either “canister” or “high-ga mma” waste.

This approval applies only to Lot 2 waste character ized using the radionuclide scaling factors evaluated as part of this inspection. Addition of a ny other Lot 2 waste with a different pedigree and/or scaling factors to Waste Stream ID-ANLE-S500 0 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 t o eight cans, and each can will be repackaged into a 55-gallon dr um prior to characterization and shipment to the WI PP 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 appro vals since the baseline approval of January

2007.

This report discusses changes to specific INL-CCP d ocuments using the term “freeze file.” As discussed in previous EPA reports, CCP may be requi red to revise a document as a result of an inspection-related EPA issue. Once CCP makes the re quired changes, the modified document is provided to EPA as a freeze file to serve as object ive evidence that the changes are appropriate. EPA has agreed to accept a modified document as a f reeze file to expedite review while CCP’s document control process generates the official ver sion of the revised document and provides it

at a later date. EPA must receive CCP’s controlled version of all re vised 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 Sept ember 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 throu gh the EPA website and by emails to the WIPPNEWS list, in accordance with Title 40 of the C ode of Federal Regulations (40 CFR) 194.8(b)(3).3Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP(Based on June 12–16 and August 9 and 26, 2006, Baseline Inspection and Subsequent Tier 1 Evaluations,Updated July 2012)RH Waste CharacterizationProcess ElementsINL-CCP RH Waste Characterization Process – T1 ChangesINL-CCP RH Waste Characterization Process – T2 Changes*Acceptable Knowledge (AK)Addition of containers to approved waste streams ifnew or differentradionuclide scaling factors are requiredAny new waste streams not approved under this baselineSubstantive modification(s)*** to CCP-AK-INL-5X0 orCCP-AK-INL-5X2 that have the potential to affect thecharacterization processLoad management for any remote-handled (RH) waste streamNotification to EPA when updates to the following documents havebeen completed:•All future revisions of AK summary reports (AKSR),andcertification confirmation test plans (e.g., CCP-AK-INL-500and CCP-AK-INL-502)•AK accuracy reports (prepared annually, at a minimum)•Attachment 4 of CCP-TP-005 is generated to reflecttheupdated AKSR Source Document Reference List•Changes to AK documentation as a result of WasteCharacterization Program Implementation Plan revisions[e.g., characterization reconciliation report (CRR)]**•A correlation or surrogate summary form for each ofthe RHcontainers in this waste stream identified as contact-handled(CH), based upon measured dose rates that presentnondestructive assay results for assayed containers•The waste stream data package for debris waste stream andany modifications to the waste stream profile form,including the CRR and AKSR•Final DTC determination for RH containers numbers 728through 737, as identified in AK Reference P030Notification to EPA of the intention to add containers to anapproved waste stream, including the approximate number ofcontainers and volume(s) of waste, the timeframe for wastegeneration, characterization, and disposal and submission of anupdated AKSR documenting that the pedigree of the additionalcontainers is the same as those covered by the baseline and/orsubsequent T1 approvals†Submission of a list of fully characterized containers from apopulation of additional containers proposed as a T2 change, above†Radiological Characterization,including Dose-to-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501Use of any alternate radiological characterizationprocedure other thanDTC with established scaling factors as documentedin CCP-TP-504Notification to EPA when revisions of CCP-AK-INL-501 orCCP-TP-504 that require CBFO approval** are completeSubmission of an updated CCP-AK-INL-5X1 documentingthat theradiological characterization process(s) used for the additional4RH Waste CharacterizationProcess ElementsINL-CCP RH Waste Characterization Process – T1 ChangesINL-CCP RH Waste Characterization Process – T2 Changes*Substantive modification(s)*** to CCP-AK-INL-5X1 orCCP-TP-504that have the potential to affect the characterization processUse of any alternate gamma detector with the OSPREYTM systemcharacterization procedure other than the La3Br(Ce) detector observedin July 2010Any new waste stream not approved under the baseline and/orsubsequent T1 evaluations or addition of containersto an approvedwaste stream that requires changing the establishedradionuclidescaling factorscontainers is the same as those covered by the baseline and/orsubsequent T1 approvals†Submission of DTC batch data reports (BDRs) or calculationpackagesfor containers selected by EPA from a list of fullycharacterized containers provided by INL-CCP†Visual Examination of audio/videomedia (VE)Use of VE to characterize additional debris waste streams or wastefrom other Summary Waste CategoriesNotification to EPA when changes to VE procedure(s)that requireCBFO approval** are completeSubmission of VE BDRs for containers selected by EPA from a listof fully characterized containers provided by INL-CCP†Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 or wastesfrom an S3000 or S4000 waste streamNotification to EPA prior to addition of a new RTRunit(s)Notification to EPA when changes to RTR procedure(s) that requireCBFO approval** are completeSubmission of RTR BDRs for containers selected by EPA from alist of fully characterized containers provided byINL-CCP†WIPP Waste Data System (WDS)(previously known as WWIS)NoneChanges made to WDS procedure(s) that require CBFOapprovalNotes: 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 every3 months.** Excluding changes that are editorial in natureor are required to address administrative concerns.New references that are included as part of the document revision may berequested by EPA.***Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., theuse of an inherently different type ofmeasurement instrument or the use of the high-rangeprobe as described in CCP-TP-504 for radiologicalcharacterization.† INL-CCP will report this T2 change immediately.5

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes to the waste characterization activ ities 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 incorpor ated in the INL-CCP RH baseline approval report cited in Attachment A.

Under the changes to 40 CFR 194.8 promulgated in th e Federal Register on July 16, 2004 (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1) and those req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspec tion to observe at first hand the implementation of the change, or it can opt to cond uct a desktop review of information provided specific to a change. DOE may choose to characteriz e and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU waste usin g processes, procedures or equipment implemented as T2 changes. EPA reviews T2 changes o n a quarterly basis and may conduct continued compliance inspections to evaluate implem ented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to implement the radiological characterization process for the Lot 2 waste packag ed in 55-gallon drums in Waste Stream ID-ANLE-S5000, as described in CCP-AK-INL-501, Revi sion 5. This report presents the technical basis of EPA’s approval decision regardin g 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 anno unce 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 evalua tion 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 88221-30906

4.0 SCOPE OF THE TIER 1 EVALUATION

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

Lot 2 waste from ANL-E in Waste Stream ID-ANLE-S500 0. CBFO and INL-CCP determined that the drums containing Lot 2 waste are of the sa me pedigree as the previously approved

ANL-E debris containers stored at INL. Based on cri teria 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; I I-A4-145, March 24, 2011), a T1 request is required for characterization of any waste using ne w or different scaling factors. Therefore, the scope of this T1 request is evaluation of the radio logical characterization approach for the Lot 2 waste in Waste Stream ID-ANLE-S5000, as specified i n CCP-AK-INL-501, Revision 5, Appendices A and B.

EPA has evaluated Waste Stream ID-ANLE-S5000 severa l times; however, as part of this review, EPA also confirmed that the Lot 2 waste des cribed 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 f acility.

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 wast e 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 i nterviews and met on site at INL with INLCCP personnel in several disciplines. The EPA evalu ation team members and the personnel contacted are listed in Table 2, with their affilia tions 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, 2011.7Table 2. Tier 1 Evaluation PersonnelPersonnel NameAffiliationArea of Expertise, FunctionConferenceCallsaINL SiteVisitbInteractive Meeting,AlbuquerquecEd Feltcorn EPA ORIA T1 Evaluation Lead InspectorRajani Joglekar EPA ORIA T1 Evaluation InspectorLindsey Bender EPA ORIA ObserverKathleen Economy EPA ORIA ObserverConnie Walker SC&A AK, InspectorRose Gogliotti SC&A Radiological Characterization,InspectorAmir Mobasheran SC&A Radiological Characterization,InspectorPatrick Kelly SC&A Radiological Characterization, InspectorDorothy Gill SC&A RTR, InspectorScott Smith CCP AKEJene VancedCCP Radiological Characterization, Technical ExpertDerek Ott WTS-CCP Radiological Characterization, Technical ExpertJoe Harvill CTAC Radiological Characterization, Technical ExpertMichael Sensibaugh WTS-CCP CCP ManagerIrene Quintana WTS-CCP RH Project ManagerMarcus Pinzel DOE-CBFO CBFO RH ManagerD.K. Ploetz WTS-CCP RCT ManagerRhett Bradford CTAC CBFO QA ObserverTom Morgan CBFO NTP CCP ManagerRon Reeves WTS-CCP ObserverJames Malmo DOE-Idaho ObserverGreg Smith WTS-CCP INL-CCP Vendor Project ManagerFred Oney CCP RTR OperatorCorey Boland CCP DTC OperatorBruce LaRue ID DEQ INL OP ObserverBen Roberts DOE-Idaho Idaho RH-TRU Project ManagerTom Clements CH2M-WG Idaho, LLC TRU Program, ManagerRaj Bhatt CH2M-WG Idaho, LLC TRU Program, ScientistJoe Wachter Canberra ObserverPatsy Gilbert LANL Interactive Meeting CoordinatoraSeveral conference calls were held during May andJune 2012 to discuss technical aspects of AK and radiological characterization.bOnsite evaluation of DTC and RTR at INL on May 8–9,2012.cInteractive meeting to evaluate radiological characterization calculations in Albuquerque, NM, on June21, 2012; most participants were present inAlbuquerque; Rose Gogliotti and Amir Mobasheran participated by telephone.dJene Vance is listed because he prepared many of the technical reports that support this evaluation,even though he did not actively participate in anytelephone call or meeting.8

6.0 TECHNICAL EVALUATION

Waste-Generating Activities

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

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

reactor fuel materials and associated hot cell acti vities. These wastes were transferred to INL for storage and characterization prior to emplacement i n 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 ana lysis, macrophotography and profilometry. The repair of in-cell equipment, cell maintenance and w aste management also generated debris waste, including portions of fuel sections, fines and rela ted materials (References C066, C108, C1031 and U001).

Beginning in 1975, ANL-E sorted TRU waste from fiss ile 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. M aterials 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 p in cladding).

Filled canisters were shipped to INL from 1975 to 1 984, where they were stored as high-gamma

TRU material. A total of 51 canisters that were ori ginally considered recoverable were subsequently defined as waste. This T1 report addre sses 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 pr epared to support the inclusion of the Lot 2 waste in Waste Stream ID-ANLE-S5000, specific ally, CCP-AK-INL-500, Revision 10, CCP-AK-INL-502, Revision 5, and CCP-AK-INL-501, Rev ision 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 conclus ion of this T1 evaluation. Attachment B is

a list of all documentation that EPA reviewed in su pport 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 radiologi cal characterization process. To address this,9

EPA selected a random sample of canisters and reque sted that INL-CCP personnel reproduce specific calculations that were deemed to be the mo st important to the development of radionuclide-specific scaling factors. EPA requeste d 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-CC P personnel created the requested documents and presented them to EPA using an intera ctive format at a meeting in Albuquerque, NM, subsequent to the evaluation at INL. The intera ctive meeting allowed EPA technical personnel to complete their assessment of the radio logical characterization process. Following this meeting, there were several rounds of email co rrespondence to clarify or correct minor discrepancies and to complete EPA’s evaluation of t his T1 change.

6.1 Programmatic Requirements and Acceptable Knowledge

EPA examined the programmatic requirements and AK p rocess and associated information to determine whether INL-CCP demonstrated compliance w ith 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 follow ing with respect to programmatic requirements and the use of AK for RH waste charact erization:

• Inspection scope and waste stream identification.

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

• Adequacy of the certification plan and other WCPIP documentation.

• Adequacy of the WCPIP waste characterization pathwa y.

• Adequacy of training.

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

• Adequacy of nonconformance and discrepancy resoluti on (DR) documentation.

• Waste stream definition, including radiological and physical characteristics.

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

• Verification that the subject waste is of defense o rigin and is not high-level waste (HLW), low-level waste, or spent nuclear fuel (SNF)

.

• Adequacy of AK procedure and procedure implementati on.

• Adequacy of the AKSR and associated source document s.

• AK data traceability.

• Attainment of data quality objectives (DQOs).10

Technical Evaluation

(1) The scope of the Tier 1 request and the waste s tream determination were examined for Waste Stream ID-ANLE-S5000 and found to be adequate

.

Argonne National Laboratory (ANL)-CCP stated that W aste 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 AGHC F and M-Wing facilities. This T1 request proposes to add 48 RH waste canisters. Sour ce 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 o f sodium and the subsequent need to remediate them. These remaining remediated canister s from Lot 2 can be added to Waste Stream

ID-ANLE-S5000 if ANL-CCP can demonstrate that the r adiological characterization processes discussed in section 6.2 of this report are applica ble. 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, physi cal form, and radiological properties.” Based on this definition, EPA examined the AKSR, source docu ments 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 metallurg ical research on fuel pins and associated nuclear materials was performed. Both destructive a nd nondestructive sectioning and

examination of irradiated and unirradiated fuels we re 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%). Unirrad iated fuels were also examined (7.7%). Fuels were identified by fuel pin identification nu mbers and alpha/gamma (A/G) numbers, and ANL-E kept detailed records that correlated specifi c fuels sectioned to waste generated. The

waste stream includes waste from Lot 2 and Waste St ream 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 trans ferred 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 s hare a process with Waste Stream ID-ANLES5000, which was previously addressed in EPA’s base line approval.

The Lot 2 and Waste Stream ID-ANLE-S5000 wastes con sist of combustible and noncombustible debris. However, the Lot 2 wastes al so 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 (R eferences U3900 and C3660). The physical composition of this waste is well understood based on packaging information and supports the11

inclusion of the Lot 2 waste in Waste Stream ID-ANL E-S5000 (References C3464, C3698, P3089, P3115 and P3182). See Item (7) for additiona l 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-S500 0 (see Tables 6 and 7 in the AKSR) (References C3660, P058, P063, U3552, U3900 and U39 01). 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 veri fy that the wastes share common fuel pin sources and, therefore, have similar radiological s ignatures (References U4042 and INL-CCP 2006). Based on data used by INL-CCP to generate sc aling factors, EPA found that Waste Stream ID-ANLE-S5000 and Lot 2 waste share approxim ately 33% of their A/G numbers, indicating that the radiological compositions of th e 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 an d Waste Stream ID-ANLE-S5000 contain radionuclides from similar fuel types, and the pres ence of some common A/G numbers is

sufficient to include the Lot 2 waste in Waste Stre am ID-ANLE-S5000. See Item (7) for additional information about the radiological compo sition of the waste stream.

(2) The certification plan, as revised to include a des cription of the waste characterization process, was examined and found to be complete.

The WCPIP requires that the certification plan desc ribe the process for certification of the waste stream, including a description of the following:

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

the selection of the methods.

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

• Characterization and testing methods not included i n the WCPIP in sufficient detail to allow for CBFO approval prior to implementation.

• Summary of the program documents to be prepared dur ing 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 2.2 3 modeling to determine scaling factors for DTC. The certification plan states that the ORIGEN 2.2 output was adjusted using factors de veloped for Los Alamos National Laboratory (LANL) RH canisters that were verified b y 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 Dep letion Code.12

approval remains applicable because the Lot 2 canis ters contain radionuclides from the same type of fuel pins as at LANL. That is, the same met hod 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 tha t 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 th e 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 pathw ay as presented in the revised certification plan and radiological characterization technical re port.

Table 3. Characterization Methods for the Waste Str eam

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, exclu de HLW and SNF, verify the defense status of the waste stream and support isotopic com positions. The physical composition of the waste stream, including the absence of prohibited i tems, was determined using radiography. The characterization pathway was adequately identified.

(4) Examples of nonconformance and discrepancy resoluti on documentation were examined and found to be adequate.

INL-CCP did not provide a nonconformance report (NC R) 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 rel evant DRs (References DR11, DR12 and DR14 through DR22). INL-CCP demonstrated adequate i mplementation of the NCR and DR

processes.13

(5) The acceptable knowledge procedure and related atta chments 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 sub sequently revised Revision 22 as part of the resolution of CBFO CAR11-043 (Revision 23) a nd 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 creat ed under Revision 23 or previous revisions, depending on the date the document was p repared. EPA found that CCP-TP-005, Revision 24, reflected all applicable WCPIP require ments 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 inte rview 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 Documen t Summary” summarizes source document contents. An Attachment 3 is prepar ed for each source document, and all Attachment 3s are considered to be CCP QA recor ds. 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 Documen t Information List” was updated March 23, 2012, to include new references s upporting the additional T1 canisters of high-gamma waste.

• “Attachment 5 – Hazardous Constituents” addresses h azardous waste numbers. This attachment is not applicable and EPA did not review it.

• “Attachment 6 – Waste Form, Waste Material Paramete rs, 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 Docume nt 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 Surr ogate Summary Form” was provided, but EPA did not review it because the for m 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. Thi s is acceptable because implementation of the AK process for this waste stream spanned many gener ations 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 cont act-handled wastes.

• “Attachment 9 – Waste Characterization Data Cross-R eference” 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 completi on and, therefore, has not yet been prepared. This is acceptable, given the timing of t he evaluation.

EPA found that CCP-TP-005 was adequately implemente d.

(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 i n 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 f ile 4 ). The AKSR provides necessary information presented in CCP-TP-005, Attachment 12, and was adequately revised to address deficiencies identified by EPA during the evaluatio n.

(7) The overall radiological and physical properties of the waste stream were examined and found to be adequately described based on acceptabl e knowledge.

Physical Properties : Waste Stream ID-ANLE-S5000 is composed of approxima tely 210 cubic meters of debris waste (1,466 repackaged 30-gallon drums overpacked into 5 5-gallon drums), including the highgamma waste (References C3660, U3552 and U3900). IN L-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 fo r 123 30-gallon Waste Stream ID-ANLE-

4 See the discussion of freeze files in the executiv e summary.15

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

canister data.

AK documentation indicates that Lot 2 combustible w aste is composed of grinding papers, rags, tissue-type wiping materials, and other similar mat erials and that noncombustible Lot 2 waste is composed of bottled and unbottled fuel fines, bonde d clad material, pipe nipple containers,

irradiated structural materials and waste related t o fuel specimen sectioning and preparation (e.g., fragments, granules, metallurgical mounts [hereafte r referred to as “met mounts”], fuel impregnated with epoxy, sweeps and fines) (Referenc es 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 gene rated through cell operations and decontamination and decommissioning. However, the A KSR (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 e stimates.” 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 t hat show the Lot 2 wastes consist of approximately 33% combustible and 69% noncombustibl e material based on historical waste loading documentation. EPA verified that the overal l 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 wi ll be repackaged and remediated to remove liquids, as necessary, so the resulting waste conte nt 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 d estructive and nondestructive

examination of irradiated and unirradiated reactor fuel materials and associated hot cell support activities. AKSR Table 6 indicates that plutonium-2 39 ( 239 Pu) and uranium-235 ( 235 U) are the predominant radionuclides by mass in Waste Stream I D-ANLE-S5000, and cesium-137 ( 137 Cs) and iron-55 are the predominant radionuclides by ac tivity, noting that mixed fission products also constitute a significant contribution to the t otal curie content. EPA previously evaluated the radiological composition of AGHCF Waste Stream ID-A NLE-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 a dequate calculation of AKSR Table 6.

The Lot 2 waste contains portions of the actual fue l pins that were sectioned and tested in the facility, and the radiological composition of the L ot 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 dat a irradiated high-level gamma TRU scrap material forms (Form SPM-50), nuclear material tran saction reports (Form AEC-741) and shipment—special source (SS) material forms (Form S PM-43) (References C3660, P058, P063, U3552, U3900 and U3901). These data indicate that 235 U and 238 U are the predominant radionuclides by weight in the Lot 2 canister subpo pulation. Mixed fission products (MFP) constitute the vast majority (over 94%) of total ac tivity in the Lot 2 canisters, with cerium-144 ( 144 Ce) the second largest contributor to the total cur ie content.16

EPA observed that the overall distribution within W aste 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 t he same (or nearly the same) fuel pin populations. EPA also compared the fuel pin data as sociated with Waste Stream ID-ANLES5000 and Lot 2 canister waste used by INL-CCP to c alculate 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-S50 00 radiological compositions are expected, as shown in AKSR Tables 6 and 7 (Referenc es U4042 and INL-CCP 2006). INL-CCP explained the difference between AKSR Tables 6 and 7 as follows:

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

in the radionuclide contents of Waste Stream ID-ANL E-S5000 and Lot 2, as well as the level of detail reported by the waste generators. F or 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). A lso, the calculated 238 U composition in Lot 2 waste is calculated by weight (mass) whereas Waste Stream IDANLES5000 reports 238 U by activity. Due to its low specific activity, th e mass or activity

values for the same amount of 238 U differ considerably. If 238 U is excluded, the weight percent distributions of the two populations are co mparable (References C3660, U3552, U3607, U3900 and U3901).

• The scaling factor calculations for Lot 2 include a pproximately 80 additional fuel pins that were obtained through ongoing AK data acquisit ion. This means that the Lot 2- specific AK data used to develop Table 7 may includ e different or additional fuel pins

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

The different radiological signatures for Waste Str eam 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 ad ditional information about the fuel material populations associated with both waste typ es. The radiological composition of the Lot 2 waste is adequately described and explained.

(8) The waste stream information was examined and indic ates 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 th at SNF is “fuel that has been withdrawn from a nuclear reactor following irradiation, the c onstituent elements of which have not been separated by reprocessing.” DOE M 435.1-1 5 expands on this definition and states that “test specimens of fissionable material irradiated for re search 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 technical ly 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 radi oactive material resulting from the

5 DOE M 435.1-1 is DOE’s “Radioactive Waste Manageme nt Manual,” Revision 1, issued June 2001.17

reprocessing of spent nuclear fuel, including liqui d waste produced directly in reprocessing and any solid material derived from such liquid waste t hat contains fission products in sufficient concentrations, and other highly radioactive materi al 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 no t 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 indic ates that the waste stream is defense in origin.

RH TRU waste is eligible for disposal at the WIPP i f it was generated in whole or in part by one of the atomic energy defense activities listed in S ection 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 n uclear power, fuel and weapons development.

DOE test and research reactors that contributed fue l elements to DOE’s overall defense program include the Experimental Breeder Reactor-II, Zero P ower Plutonium (Physics) Reactor, Advanced Test Reactor (ATR), Transient Reactor Test Facility, and Hanford Fast Flux Testing Facility, some of which also contributed fuels to t he AGHCF program. AK documentation verifies the ongoing receipt and examination of mix ed oxides, carbide and alloy fuels at the AGHCF (References C046, C074, C124, C330, P002, P58 5, 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 cond ucted at the AGHCF (References C006, C011, C068, C092, C103, C124, C152, C305, P028, P320, P58 5, 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 progr ams 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 activit ies (naval reactor development and defense nuclear materials security).

Wastes from all programs were combined during testi ng. Subsequent waste generation practices resulted in the comingling of defense and nondefens e waste materials. Separation of waste material from different fuel pins and other destruc tively 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, U0 01, U013, U1003, P001, P002 and18

P025). Based on the extent of waste comingling, Was te Stream ID-ANLE-S5000, including the Lot 2 waste that is the subject of this T1 evaluati on, contains defense-related waste.

(10) The draft waste stream profile form and characteriz ation reconciliation report were examined and found to be adequate.

With implementation of the WCPIP, INL-CCP elected t o generate a single WSPF that satisfied both the WCPIP and the New Mexico Environment Depar tment permit. INL-CCP originally provided a draft WSPF that included only the canist ers in the T1 request, implying that the canisters were considered to be a separate waste st ream. Upon EPA’s request for clarification, INL-CCP provided a revised WSPF that included total s 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 provide d. 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 dat a reconciliation shows that the new data do not match the WSPF description. Revision 24 requ ires revision of the WSPF, if mandated by new information, and is satisfactory. The draft rev ised WSPF is acceptable, and a final WSPF will be prepared in the future. Also, the draft cha racterization reconciliation report associated with the WSPF is acceptable.

(11) Drum data are traceable and are in the acceptable k nowledge 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 diffe rent types of waste. EPA did not review the traceability of AK fuel pin data to INL-CCP’s can o r canister designation because this was successfully demonstrated at that time. Instead, EP A evaluated the following steps of canister movement from loading at ANL-E through INL-CCP char acterization:

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 des ignated 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, catho de-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 repac kaging 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 t o WIPP.

Table 4 presents the source documents reviewed and information obtained for Canister No. ANLE33. It is important to determine whether re packaged drums are associated with the correct canister and that drum contents are appropr iately identified to ensure that the appropriate scaling factor is applied. Table 5 presents the ori ginal contents of the cans in Canister No. ANLE33, the repackaged drum contents, and waste typ e 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 t hat the original cans’ contents are reflected in repackaged drums and that CCP adequate ly 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 Con tents, 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 obtai n traceability information. The Sealion

database is an INL searchable database that include s 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, transfe r, repackaging and CCP characterization.

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

The WCPIP requires preparation of an AK accuracy re port that assesses accuracy based on the percentage of waste containers that required reassi gnment to a new summary category group or new waste stream, based on AK reevaluation of measu rement 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 charac terize waste, AK accuracy based on comparing the results of measurement (e.g., DTC) an d AK is not meaningful because this simply compares AK data, rather than verifying the accurac y of AK through actual measurement. The AK accuracy report was revised to recognize this co ndition. The AK accuracy report included 20 of the Lot 2 canisters and presented the AK accurac y to be 100% based on the above broad criteria. The revised AK accuracy report is adequat e.21

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

The WCPIP indicates that characterization program p ersonnel responsible for compiling AK, characterizing RH TRU waste streams using the AK pr ocess, 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 indiv idual containers.

The WCPIP also states that the “RH TRU characteriza tion program is responsible for maintaining records of the training provided to per sonnel responsible for compiling AK” (page 33). Table 6 presents the training received b y 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 requ est with up-to-date training documentation for all AK personnel that includes pe riodic briefings and training to keep AK personnel abreast of AK documents and WCPIP revisio ns. EPA will rely on inspection interviews to determine whether AK Experts are fami liar 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 b e addressed:

Defense Waste, HLW and SNF Determination (Regulator y 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-IN L-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 TR U isotopes per gram of waste.

• RH Waste Determination : Surface dose rate must be equal to or greater tha n 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 addre ssed 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 Certific ation of the WIPP) :

• Liquids : The absence of liquids in excess of 1% of the con tainer 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 suppo rt that all DQOs were achieved either through AK, radiography or the radiological charact erization process. EPA also determined that the waste stream was appropriately identified based on process, radiological and physical information, and that the appropriate WCPIP element s were adequately addressed.

Summary of Acceptable Knowledge Findings and Concer ns

The EPA evaluation team did not identify any AK-rel ated 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 subse quent 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 criteri on for RH determination is expressed in terms of a dose rate in rem, which, while technically incorrect, is commonl y used. In this report, the terms dose and dose rat e are used in place of the technically correct terms “dose equiva lent” or “dose equivalent rate.” The actual differe nce among these values for the purpose of this report is negligible

.23

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA approv es 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 dev eloped 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 an alyses 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 d ocuments, procedures and controls, and the knowledge and understanding of the personnel involv ed in the RH waste characterization program. During this RH inspection, the EPA inspect ion team evaluated the following:

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

• Development of the DTC correlation for 55-gallon dr ums using waste densities ranging from 0.01 grams per cubic centimeter (g/cm 3 ) to 2.0 g/cm 3 based on MicroShield ®
modeling of the drum’s gamma dose rate using a one- curie source of 137 Cs for debris (scrap) waste.

• Development of the DTC correlation for 55-gallon dr ums using MCNP modeling of the drum’s gamma dose rate for high-gamma (canister) wa ste, including an internal 1-gallon paint can, when applicable.

• Scaling factors developed based on ORIGEN 2.2 model ing.

Documents Reviewed

All INL-CCP RH radiological characterization docume nts 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 versi ons are shown in Attachment B.

Technical Evaluation

The EPA inspection team evaluated the following:

(1) The overall radiological characterization process a nd its documentation were evaluated and found to be adequate.24

The radiological characterization process for the L ot 2 waste was comparable to the processes observed at previous RH TRU sites. The main technic al components consisted of the following: determining isotopic distributions to develop radio nuclide-specific scaling factors, measuring each drum’s external exposure (dose) rate, and comp uter modeling to correlate the waste

container’s dose rate and radionuclide concentratio n. Each of these components is discussed in subsequent items in this section. Members of the EP A 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 r adionuclide scaling factors or the use of a different radiological characterization process fro m 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 Proc ess: Scrap Materials from Debris

Waste Stream ID-ANLE-S5000 Determine Scaling Factors: Determine DTC Conversion Factors:

Execute DTC to Determine Drum’s 137 Cs 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 137 Cs-based scaling factors for the reportable radionuclides by dividing the total activity of each radionuclide by the total activity of 137 Cs Use MicroShield ® to model the gamma dose rate at one meter from the drum surface, based on a 1-Ci source of 137 Cs

Find the mean gamma dose rate based on four measure ments
at one meter from the surface of the drum

Divide the 137 Cs mean dose rate by the DTC conversion

factor to find the 137 Cs activity in curies

Multiply the 137 Cs 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 137 Cs contained in the drum to the dose rate measured, using gamma spectrometry an d finding the contribution of 60 Co to the dose rate measured Develop DTC conversion factor (mR/hr/Ci)-density relationship for 137 Cs for the geometry of a 30-gallon drum, containing a can loaded with scrap materials and ov erpacked with a 55-gallon drum26

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

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

Fissile Material from Debris Waste Stream ID-ANLE-S 5000 Determine Canister-Based Scaling Factors: Determine DTC Conversion Factors:

Execute DTC to Determine Drum’s 137 Cs 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) 137 Cs-based scaling factors for the reportable radionuclides for each canister by dividing the total curies of each radionuclide by the total curies of

137 Cs contained in the canister Consider the following geometries:

• A can of recoverable fissile material in a wire bas ket, loaded into a 30-gallon drum overpacked in a 55-gal lon drum with the can centered vertically in the drum

• A can of nonrecoverable fissile material, spread ac ross the bottom of a 30-gallon drum overpacked in a 55-gallo n drum

Find the mean gamma dose rate based on four measure ments
at 1 meter from the surface of the drum

Divide the 137 Cs mean dose rate by the DTC conversion

factor to find the 137 Cs activity in curies

Multiply the 137 Cs 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 137 Cs to the dose rate measured, using gamma spectrometry to find the contribution o f 60 Co to

the dose rate measured Use MCNP5 to model the gamma dose rate at 1 meter f rom the drum surface, based on a 1-Ci source of 137 Cs, 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 p rogram, a scaling factor is the ratio of the activity of a typically difficult-to-measure radion uclide, e.g., 239 Pu, to an easily measured radionuclide, in this case 137 Cs. Assuming that the container-specific measured d ose rate is attributable essentially to 137 Cs, the container’s dose rate and 137 Cs concentration can be correlated. Using radionuclide-specific scaling fac tors, 238 Pu, 240 Pu, 233 U, 234 U and other radionuclides are quantified by scaling them to the 137 Cs content, i.e., the container’s measured dose rate. This allows the determination of multipl e radionuclides by virtue of a single measurement of the container’s dose rate. Scaling f actors for the high-gamma and scrap wastes

were calculated as discussed below.

High-Gamma Wastes : Each canister received its own set of 137 Cs-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 i dentified and correlated with the ORIGEN 2.2-generated data for each segment. Fast reactor f uel pins were adjusted to account for observed discrepancies between ORIGEN 2.2 results and measur ed values in fast reactor fuel (i.e., benchmark adjustment). Results were further adjuste d to account for the fuel segment heavy metal ratio divided by 10 6 . The activities of each radionuclide in a canister were summed and divided by the calculated 137 Cs 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 proces s. 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 recr eate 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 calcula tions that were deemed to be the most important to the development of radionuclide-specif ic scaling factors. EPA requested that these calculations be provided in a workable Excel spread sheet 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 co nfirming the technical adequacy of the calculations. Specifically, EPA selected the calcul ation 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; additiona lly, 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 calcu lations supporting the characterization of

the two canisters and debris in three Excel files d uring an interactive Web conference on June 21, 2012.28

From this presentation, EPA determined that the sca ling 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 calculati on. This was found to be an isolated instance affecting only Canister No. 36. As a result, CBFO a greed to amend all documentation to reflect this change to Canister No. 36.

Scrap (Debris) Wastes : A single set of 137 Cs-based scaling factors was developed for all Lot 2 scrap (debris) waste. Because comingling did occur, no single canister ca n 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 mat erials. 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. Bec ause 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 c alculation 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 requiri ng that CBFO regenerate the population of 602 ORIGEN 2.2 runs. The fuel pin segments were ide ntified 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 fu el plates were adjusted by a factor of 1/8.6

to account for their size relative to the other fue l pins. Radionuclide results were then adjusted to account for benchmark analysis and the activities o f each radionuclide were summed and divided by the calculated 137 Cs activity to produce the set of debris scaling fa ctors.

Upon receipt of documentation indicating that all m inor corrections had been made, EPA determined that the process of scaling factor devel opment was technically adequate and correctly documented for both the high-gamma and debris (scra p) wastes.

(3) Computer modeling to develop the dose-to-curie corr elation was evaluated and was found to be adequate.

Separate modeling was done for the high-gamma and d ebris wastes to accurately model both waste configurations.

High-Gamma Wastes : One-gallon cans of high-gamma waste contain discret e pieces or segments of fuel pins and are not commingled, allowing scaling factors to be deve loped for each individual canister. Modeling

the dose rate correlation to the drum content was d one 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 dru m, overpacked in a 55-gallon drum. The wire29

basket is assumed to be 4 centimeters high in the p aint can, though the actual waste height does not have significant impact on the calculation. Thi s geometry of waste was assumed to have a DTC value of 53.44 milliroentgen per hour per curie 137 Cs (mR/hr/Ci) at 1 meter.

The nonrecoverable fissile materials geometry (eith er 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 ma terial 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/cm 3 ; the met mounts are typically mounted in epoxy, so their density is assumed to be 1.0 g/cm 3 . For this geometry, the DTC correlation value at 1 meter
was found to be 145.5 mR/hr/Ci 137 Cs for fines with Met-L-X and 147.9 mR/hr/Ci 137 Cs for met mounts. Because the difference is minimal, INL-CCP used the average of these two values (146.7 mR/hr/Ci 137 Cs) 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 137 Cs was uniformly distributed within the drum and th at the only significant gamma emitter in the drum was 137 Cs. Adjustments for the presence of cobalt-60 ( 60 Co) are based on actual measurements taken during DTC using the OSPREY system 7 and are recorded

on the “Waste Container Dose-to-Curie Conversion Re cord” 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 137 Cs content for waste densities from 0.01 g/cm 3 to 2.0 g/cm 3 . Based on the measured 1-meter dose rates, a least-squares curve-fitting routine was us ed to derive a function relating waste density

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

Y = 25.625x 2 – 116.29x + 184.05 when R 2 = 0.9993

Figure B5-1 of CCP-AK-INL-501, Revision 5, shows th e graphical representation of the 137 Cs correlation, and Reference U4045 details the develo pment of the DTC calculation.

EPA had no concerns regarding the modeling to devel op the dose-to-curie correlation for highgamma and debris waste. The use of any alternate sc aling factors other than those documented in CCP-AK-INL-501, Revision 5, remains a T1 change. (S ee Table 1.)

(4) Correlation of radionuclide values to the 137 Cs concentration for each drum was evaluated and was found to be technically adequate and approp riately documented.

INL-CCP applied the DTC correlation factor to deter mine the 137 Cs concentration in each drum using the arithmetic mean of four 1-meter dose meas urements, 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 refe r to the OSPREY gamma system that provides the

contribution of 60 Co 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 measuremen ts with radionuclide-specific scaling factors to quantify the following radionuclides : 233 U, 234 U, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu,

242 Pu, americium-241 ( 241 Am), 137 Cs, barium-137m ( 137m Ba, 137 Cs progeny), strontium-90 ( 90 Sr), and yttrium-90 ( 90 Y, 90 Sr progeny). This list goes beyond the 10 WIPP-trac ked radionuclides

because all radionuclides that contribute to at lea st 95% of the radionuclide hazard, at least 95% of the thermal loading, and any radionuclide that c ontributes greater than 1% of the total must be reported, which includes 137m Ba and 90 Y. 8 Additionally, the 235 U value must be considered for criticality purposes. The determination of radionuc lide activities by INL-CCP for Lot 2 is technically adequate and correctly documented.

(5) The technical basis and documentation of total meas urement uncertainty were evaluated and found to be adequate.

The development of total measurement uncertainty (T MU) for Lot 2 is based on the propagation of uncertainties present in the determination of th e 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 fol lowing:

• 137 Cs DTC correlation (for debris waste) – MicroShield ® code, MicroShield® modeling, and waste density uncertainties.

• 137 Cs DTC correlation (for high-gamma waste) – MCNP5 c ode, MCNP5 modeling, and waste density uncertainties.

• 137 Cs activity measurement – dose rate measurement unc ertainty and uncertainty due to the contribution of other gamma-emitting radionucli des.

• Scaling factor uncertainty – sample data uncertaint y (except 233 U and 242 Pu), isotopic fractions uncertainty ( 239 Pu and 240 Pu).

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

between drums.

A general treatment of TMU is presented in CCP-AK-I NL-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 packag e 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 spreads heets that documented the detailed calculation of uncertainties for randomly chosen Ca nister Nos. 19 and 36 and a subset of the

8 Transportation is not within EPA’s regulatory purv iew; however, this information may be useful in understanding a container’s radionuclide compositio n.

9 Adding in quadrature is a standard statistical tec hnique that allows one to combine the square root o f the sum of each contributor to uncertainty squared, res ulting in a lower value than what would be obtained if the values were simply added.31

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

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

calculation of TMU for the canisters based on this demonstration.

(6) Execution and documentation of the dose-to-curie an d 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 lis ted on the current list of qualified individuals (see below). DTC personnel began by per forming 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 inspector s but was documented appropriately in the logbook. The operator weighed the drums and recorde d 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 Therm o 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 backg round 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 op erational logbook. DTC personnel consulted “CCP Operator Aid: RH-DM-INL-002, Revisio n 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 oper ators also performed a source check for the

OSPREY LaBr 10 Probe No. 13000014 using 137 Cs 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 sh eet (CCP-TP-504, Revision 11, Attachment 2), a copy of which was provided to EPA. Contact do se 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 th ree times the measured background of 0.2 milliroentgen per hour (mR/hr), and all measurement s and accompanying parameters were acceptable. EPA received copies of the DTC and OSPR EY measurement control reports and the

DTC and OSPREY container data sheet for Drum No. AN LE96. 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 doc umentation of the DTC and OSPREY techniques.

10 The OSPREY detector is a cerium-drifted lanthanum bromide crystal [La 3 Br(Ce)].32

(7) Radionuclide documentation in dose-to-curie batch d ata reports was assessed and found to be adequate.

Only BDR No. INLRHDTC12002 was available at the tim e 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 checkli st, Attachment 7.

• Measurement control report with all parameters acce ptable, 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 documenta tion from duplicate drum

measurement.

• Waste container DTC conversion records with all req uired parameters.

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

• Type of waste in each container on Attachment 3, or ganic 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 accept able.

(8) Remote-handled determinations were evaluated and fo und 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 tha t are performed directly prior to shipment. Typically, a 1-meter dose rate is measured, and thi s 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 mea surements that were taken during February and March 2012, as documented on radiological surve y reports, Form 441.15, Revision 05. Each form stated the gamma and neutron DCFs that were ap plied to the 1-meter reading to produce a33

contact dose rate. Several drums were rejected as R H 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 a nd Concerns

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

relative to the inclusion of Lot 2 waste in Waste S tream 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 base line inspection and subsequent T1 evaluations.

Radiological Characterization Approval

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

for the Lot 2 waste.

6.3 Real-Time Radiography

EPA reviewed written and audiovisual RTR data, gene rated by INL-CCP, for waste drums reported in BDR No. INLRHRTR12002. The drums examin ed were generated during repackaging of the original waste containers prior to characterization. Two internal packaging configurations of 55-gallon drums were identified d uring 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 configuratio n consisted of a gallon paint can and general debris items contained within an internal 3 0-gallon metal drum.

Prior to examination of the drums, RTR operators co rrectly verified the resolution of the RTR unit by performing a measurement control determinat ion. This examination was reported on Attachment 1, CCP RTR Measurement Control Report, o f 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, h ad been performed on Lot 2 drums as required by the RTR procedure. RTR data were record ed on “Attachment 2, CCP Radiography Data Sheet,” by a trained operator at the time of t he examinations. Operators are employed by CWI but trained to CCP procedures and have onsite a ccess to experienced CCP RTR personnel in case of questions or difficulties encountered du ring examinations. Data were reviewed at the34

data generation and SPM level; the reviews were rec orded on the appropriate attachments from Procedure CCP-TP-508. No prohibited items were foun d in any of the BDR containers.

On May 8, 2012, EPA inspectors observed the RTR exa mination 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 a udiovisual records. Waste items were identified by the operator on the audiovisual recor ding and entered electronically into RTR data sheets. The operator used Procedure CCP-TP-508 to g uide the examination and record generation. This procedure includes detailed operat ional instructions and the required RTR forms used by operators. EPA inspectors determined the pr ocedure to be adequate and effective for generation of compliant RTR data. EPA reviewed seve ral lists of qualified individuals and determined that the operator performing the demonst rated RTR examination and those responsible for generation and review of BDR No. IN LRHRTR12002 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 Appe ndix 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 a nd corrected by the RTR Independent Technical Reviewer (ITR).

(2) The two training containers Nos. NDE-Training-12 an d -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 th at are required by the WAP.

EPA requests that INL-CCP/CBFO consider this concer n 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 Conce rns

EPA determined that RTR data for Lot 2 of Waste Str eam ID-ANLE-S5000 were generated in accordance with CCP, WCPIP and 40 CFR Part 194 requ irements. 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 subse quent T1 evaluations.35

Real-Time Radiography Approval

Based on the results of this evaluation, EPA approv es the process of RTR for determining the physical contents of the Lot 2 waste portion of Was te Stream ID-ANLE-S5000.

7.0 CONCLUSIONS

EPA concluded that the waste characterization proce sses 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 rec ords evaluated. There are no open issues

relative to this T1 evaluation.

EPA is accepting the use of freeze files to serve a s 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 th an the end of the calendar quarter. All freeze files that support EPA’s approval of this T1 evalua tion must be provided to EPA no later than September 30, 2012.

S ummary of Findings and Concerns

The EPA inspection team did not identify any findin gs 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 di scussed 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 conc erns 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 revi sed 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 radiolog ical characterization technique for the Lot 2 waste as part of INL Waste Stream ID-ANLE-S5000, al ong with a review of AK and RTR. Based on the results of this evaluation, EPA approv es this T1 change for Lot 2 of Waste Stream ID-ANLE-S5000, consistent with the limitations spec ified 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 Janu ary 2007 A-98-49; II-A4-75

Tier 1 Change – Approval of Real-Time Radiography F ebruary 2007 A-98-49; II-A4-80

Tier 1 Change – Approval of K Cell Wastes January 2 008 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 Tech nique September 2009 A-98-49; II-A4-118

Tier 1 Change – Addition of Twelve Containers to Wa ste 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-S54 00-RH June 2010 A-98-49; II-A4-126

Tier 1 Change – Approval of Waste Stream ID-INTEC-S 5400-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-S30 00 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-A4-159B-1 ATTACHMENT B

LIST OF DOCUMENTS REVIEWED FOR THIS EVALUATION

CCP-AK-INL-500, Central Characterization Project Ac ceptable Knowledge Summary Report

for Remote-Handled Transuranic Debris Waste from Ar gonne 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 Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d 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, Decem ber 22, 2006

CCP-TP-002, Revision 24, CCP Reconciliation of DQOs and Reporting Characterization Data, Attachment 2 – CCP Waste Stream Profile Form (Examp le) 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, Novemb er 28, 2011

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 5 – Hazardous Constituents, November 16, 2006

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 10 – Acceptable Knowledge Re-evaluation Checklist, Novem ber 16, 2006

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, June 30, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers, June 30, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, Novem ber 28, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 4 – Acceptable Knowledge Source Document Information Li st, November 28, 2011B-2

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers List, November 28, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP Waste Stream Characterization Checklist – Example F orm, November 28, 2011

CCP-TP-504, Revision 12, CCP Dose-to-Curie Survey P rocedure for Remote-Handled Transuranic Waste, Attachment 1, Measurement Contro l Report, May 8, 2012

CCP-TP-506, Draft Characterization Reconciliation R eport, 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-D efense Waste, Gary Marshall, January 21, 1997

C006, Interview with Larry Neimark Re: AGHCF Sample s, 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, R e: Work Plan for the Examination of LILY-1 and LILY-1A Specimens, L.A. Neimark, MCT, No vember 28, 1988

C036, Letter to Sheldon Meyers, Deputy Assistant Se cretary for Nuclear Waste Management, Re: Disposition of TRU from LWR Program: Documentat ion 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 Ma rtin 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. De partment of Energy Re: “TREAT Experiment Program,” R. Avery, Director, Reactor An alysis and Safety Division, 2694, April 4,

1985B-3

C092, Intra-Laboratory Memo to J.L. Hooper, DOE (AR G), 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. Nei mark, MST, May 30, 1984

C108, Correspondence to Mr. J.T. Case, U.S. Departm ent 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., Manag er 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, F ebruary 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/IP S, Re: Work Plan for the Examination of LILAC Target NO. 19 for Battelle Pacific Northwe st 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 Cel ls Facility, Report Attached, R.J. Page and A. Miron, May 2, 2003

C330, Memorandum to Ines Triay, Acting Manager, CBF O: Determination and Findings, Defense Origin of Nuclear Waste, Kerr-McGee Waste, F. Marcinowski, April 15, 2005

C332, Memorandum to CCP Records: Assessment of Wast e Material Parameters for Waste Stream ID-ANLE-S5000, B. Becker, [undated]

C348, Evaluation of Generator Reported Radionuclide s 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 D rums 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 Oper ations, 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, 2009B-4

C3698, Email to Tom Clements Re: Operation of CCP-6 66, Gerald G. Streier, July 28, 2009

Calibration Certificate, Source 100 mCi Cs-137, Ame rsham 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 Radiogr aphy (RTR) Operator/Independent Technical Reviewer (ITR) for Remote-Handled (RH) Wa ste 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, N o. 1181-164, IND ID: CP7CS001, Isotope Products Laboratories, March 22, 2006

Characterization Information Summary, WSPF # ID-ANL E-S5000, Lot 31, Draft, [undated]

Documentation of Calculations: Canister No. 19, Can ister 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-1 0200-1, 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, Re vision 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 Laborator y ID-ANLE-S5000, Lot 31, March 23, 2012

List of Qualified Individuals, RH Program – INL, Fe bruary 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 P roject, EDF-10217, Revision 0, March 19,

2012

P001, AGHCF Operations Manual, Argonne National Lab oratory, IPS-2-00-00, Revision 0, June 20, 1989, Revision 1, March 29, 1990, and Revi sion 2, September 10, 1990

P002, Central Characterization Project Acceptable K nowledge Summary Report for Argonne National Laboratory-East Contact-Handled TRU Waste Facility Maintenance and LaboratoryB-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 Yea r Retrievable Storage of Intermediate Gamma Level Transuranic Waste, June 1, 1976

P009, TRU-RH Waste Certification Plan for Waste Man agement Operations, Ralph W. Ditch and Gary E. Griffin, J0306-0033-SA, Revision 2, Nov ember 10, 1986, and Revision 4, April 16, 1991

P018, Certification and Venting Plan for Remote-Han dled 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 R e: Alpha-Gamma Hot Cell Facility (AFHCF), Argonne Illinois Site, July 19, 1993

P032, Procedure for Sorting Remote-Handled TRU Wast e (30-Gallon Intermediate-Level Waste), Alpha-Gamma-Hot Cell Facility Irradiation P erformance Section Materials and Components Technology Division, January 7, 1987

P058, AGHCF Operations Manual: 15.0 Nuclear Materia ls Management, IPS-2-00-00, Revision 1, March 26, 1990

P063, SPM Procedure for High Gamma Transuranic Wast e Handling from Alpha Gamma Hot Cell Facility (AGHCF) Building 212, MSD, ANL-E, Jan uary 20, 1975

P067, Procedure for High Gamma Level Transuranic Wa ste Handling at the AGHCF, MSD, ANL-E, M1002-0047-SP-00, December 30, 1974

P320, Management Plan for Irradiation Performance S ection Facilities, Energy Technology Division, H. Drucker, IPS-417-00-00, Revision 0, Oc tober 14, 2002

P585, Safety Issues at the DOE Test and Research Re actors, A Report to the U.S. Department of Energy, National Academy Press, 1988

P586, Report to Congress – The Liquid Metal Fast Br eeder Reactor Program – Past, Present, and Future, ERDA, RED-75-352, April 28, 1975

P599, The Defense Programs Origin of Transuranic Wa ste at Argonne National LaboratoryWest, H.F. McFarlane, ANL-NT-192, November 2011B-6

P835, Chemical Engineering Division Annual Technica l Report for 1980, L. Burris, D.S. Webster, D.L. Barney, F.A. Cafasso, and M.J. Steind ler, ANL-81-38, June 1981

P1001, From Test Tube to Pilot Plant; A 50 Year His tory of the Chemical Technology Division at Argonne National Laboratory, R.K. Steunenberg an d 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 Ju ne 16, 2008

P3089, AK Summary Documentation RH TRU Packaging, R PT-456, October 2007,

November 2007

P3115, Decontamination Cell Operation in CPP-659, I daho 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 – LinerCharacterization Stage 2, B. Welty, PLN3209, Revision 0, June 30, 2009

P4119, Engineering Design File, Argon Repackaging S tation (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 N os. ANLE29A, ANLE29B, ANLE29C, ANLE29D, ANLE29E, ANLE30C, ANLE30E, ANLE32A, ANLE32 B, ANLE32C, ANLE32D1, ANLE32E, ANLE32F, ANLE32G, ANLE32H, ANLE33A, ANL E33B, ANLE33C, ANLE33D, ANLE33F, ANLE33G, ANLE33H, and ANLE33I, da tes ranging from February 27, 2012, to March 5, 2012

Remote-Handled Dose to Curie Operational Logbook 20 12, CCP-INL-RH-DTC-007, Idaho National Laboratory, INTECT CPP-659

Remote Handled (RH) Mixed Heterogeneous Debris Wast e from the Argonne National Laboratory-East (ID-ANLE-S5000) Change Notice #1 Up date 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 Lab oratory, Waste Stream ID-ANLES5000, [undated]

RTR BDR No. INLRHRTR12002

U001, AGHCF Position Statement Regarding Defense Ve rsus Non-Defense TRU Waste, April 7, 2000B-7

U002, Draft Proposal for: Alpha-Gamma Hot Cell Faci lity Waste Management Plan, [undated]

U007, Material Control Sheets for A/G Numbers 1 thr ough 510 and Some Attached Paperwork, [undated]

U009, Transuranic Waste at Argonne National Laborat ory-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, 199 5

U017, RH-TRU 1994, Book 8, Drums 778 to 797, [undat ed]

U023, Fuel Shipments into AGHCF 1993-1995, July 8, 1997

U040, Spreadsheet Correlating Number Quota with Quo ta 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 Dat abase, [various dates]

U307, Report 105 – Custodian Batch Balance (Pure), Report 105, December 1, 2004

U342, SAREF Safety Program Environmental Impact Ass essment, 1975

U1003, Argonne Special Material Receipt and Transfe r 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 R H-TRU Liners, Reese Gannon, February 11, 2009

U3900, Collection of Retrievable Storage Canister D ata, 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 Storag e Canister Data Irradiated Hi-Level Gamma Transuranic Scrap Material Sheets and Associa ted Paperwork, various authors, February 6, 1975, through October 18, 1991, not inclusiveB-8

U4025, CCP Calculation Package: Determination of Re portable 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 Informati on 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, Octob er 25, 2011

U4044, CCP Calculation Package: HFEF Lot 2 Debris W aste Scaling Factors, J. Holderness, INL-RH-115, Revision 0, October 25, 2011

U4045, CCP Calculation Package: HFEF Lot 2 Debris C s-137 DTC Correlation, J. Holderness, INL-RH-116, Revision 0, October 25, 2011

U4046, CCP Calculation Package: HFEF Lot 2 Debris U ncertainty, J. Holderness, INL-RH-117, Revision 0, October 25, 2011

U4047, CCP Calculation Package: DTC Spreadsheet HFE F Lot 2 Debris Waste, J. Holderness, INL-RH-118, Revision 2, March 20, 2012

U4048, CCP Calculation Package: HFEF Lot 2 Fuel Seg ment Mass Input Check, J. Holderness, INL-RH-108, Revision 0, October 25, 2011

U4049-1, CCP Calculation Package: HFEF Lot 2 High G amma TRU Uncertainty – Canister 1, J. Holderness, INL-RH-113-1, Revision 0, June 27, 2 012

U4051, CCP Calculation Package: HFEF Lot 2 High Gam ma TRU Waste Scaling Factors, J. Holderness, INL-RH-112, Revision 0, October 25, 2011

U4052, CCP Calculation Package: DTC Spreadsheet HFE F Lot 2 High Gamma TRU Waste Scaling Factors, J. Holderness, INL-RH-114, Revisio n 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, 2011C-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 Num ber: 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 identifie d 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 tw enty containers reported in BDR No. INLRHRTR12002; the errors were identified and corre cted by the RTR Independent Technical Reviewer (ITR).

(2) The two training containers Nos. NDE-Training-1 2 and 17, which were constructed one year apart,

contain the same items.

(3) The non-WAP items in the two training container s do not include "plastic" other than plastic bottl es that are required by the WAP.

EPA Requests that INL-CCP/CBFO consider this concer n and evaluate it with an eye towards ensuring that RTR remains compliant with 40 CFR 194 going fo rward.

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