DOCKET NO: A-98-49, II-A4-124

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION
OF THE CENTRAL CHARACTER IZATION PROJECT (CCP)
REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM FOR OAK RIDGE NAT IONAL LABORATORY (ORNL): PRE-SETF PERIOD WASTES (A PRIL 1972 – NOVEMBER 1978) February - March 2010

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

April 2010i TABLE OF CONTENTS

Section Page

Acronyms....................................................................................................................... ................. ii

1.0 Executive Summary............................................................................................................ 5

2.0 Purpose of Tier 1 Evaluation .............................................................................................. 6

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

4.0 Tier 1 Evaluation.............................................................................................................. ... 6

4.1 Acceptable Knowledge ........................................................................................... 7

4.2 Radiological Characterization............................................................................... 20

5.0 Findings or Concerns ........................................................................................................ 27

6.0 Conclusions.................................................................................................................... ... 27

Attachment A List of Documents Provided to EPA for AK and Radiol ogical Characterizationii ACRONYMS

AK acceptable knowledge

AKSR acceptable knowledge summary report

Al aluminum

Am americium

BDR batch data report

Bk berkelium

CBFO Carlsbad Field Office

CCP Central Characterization Project

Cf californium

CFR Code of Federal Regulations

CH contact-handled

Cm curium

CRR characterization reconciliation report

CSSF correlation and surrogate summary form

CTAC Carlsbad Technica l Assistance Contractor

CTP Confirmatory Test Plan

CTS central tracking system

DOE U.S. Department of Energy

DQO data quality objective

DRF discrepancy resolution form

DTC dose to curie

EPA U.S. Environmental Protection Agency

Es einsteinium

Eu eruopium

FFTF fast flux test facility

Fm fermium

gal gallon

HCV hand control valve

HFIR High Flux Isotope Reactor

HLW high level waste

I iodineiii LLW low level waste

LWR light water reactor

MCNP5 Monte Carlo N-Pa rticle Transport Code

Md mendelevium

MDA minimum detectable activity

MUA Chemical Makeup Area

nCi/g nanoCuries per gram

NCR non conformance report

NDA non destructive assay

NDE non destructive examination

ORNL Oak Ridge National Laboratory

Pre-SETF Pre-Solvent Extraction Test Facility

PTS project tracking system

Pu plutonium

QA quality assurance

QAO quality assurance objective

QAPD Quality Assurance Program Document

REDC Radiochemical Engine ering Development Center

RH remote-handled

RTR real-time radiography

SCG summary category group

SETF Solvent Extraction Test Facility

SNF spent nuclear fuel

SPM site project manager

SQAO site quality assurance officer

SRS Savannah River Site

SWSA solid waste storage area

T1 tier 1

T2 tier 2

TRU transuranic

TWPC TRU Waste Processing Center

VE visual examination

VET visual examination techniqueiv WCPIP Waste Characterization Program Implementation Plan

WIPP Waste Isolation Pilot Plant

WMP waste material parameters

WSPF waste stream profile form5 1.0 EXECUTIVE SUMMARY

This report supports the U.S. E nvironmental Protection Agency’s (EPA or the Agency) approval of the addition of retrievably stored, remote-h andled (RH) transuranic (TRU) debris (S5000) from the April 1972 – November 1978 time period [referred to as Pre-SETF (pre-Solvent Extraction Test Facility) 1 wastes] to waste stream OR-REDC- RH-HET as a Tier 1 (T1) change. This waste stream was generated over a 30-year period at ORNL requiring EPA to evaluate and issue separate approvals. Previ ously EPA approved wastes specifi c to two different radiological groupings belonging to this waste stream. The radiological groupings are: High Flux Isotope Reactor (HFIR) and Mark-42 wast es (approved in February 2009 as part of a Baseline approval) and SETF waste (approved in November 2009 as a T1 change). The wastes were generated at and packaged by the Oak Ridge National Laboratory (ORNL) for disposal at the Waste Isolation Pilot Plant (WIPP). The Central Characterization Project (CCP) is respons ible for characterizing this waste using the system of controls whic h EPA evaluated during the baseline inspection conducted in July 2008 and approved in February 2009 (see EPA Docket No. A-98-49, II-A4- 111). The HFIR and Mark-42 wastes were ge nerated from November 1991 through February 2007, and the SETF period wastes were gene rated from November 1978 through November
1991.

On August 28, 2009, Carlsbad Field Office (CBFO) requested that EPA review a proposed T1 change in the form of adding the Pre-SETF wastes, including HFIR, Pu-Al, and curium purification campaigns, to the ORNL-CCP approved waste stream OR-REDC-RH-HET. Because there was no new equipment or processe s on site at ORNL to examine, EPA conducted a desktop evaluation during February and March 2010. This report pres ents the results of this T1
evaluation. ORNL-CCP used th e EPA-approved procedures and processes to characterize the Pre-SETF RH TRU wastes, and EPA inspectors dete rmined them to be technically adequate. As part of this evaluation, EPA did not identif y any Findings or Conc erns. However, EPA
determined that the non destructiv e assay (NDA) sampling plan was not adequate in that it did not describe the sample selection and collection activities. EPA expects that CBFO will address sampling in a more comprehensive manner in the revisions of the Waste Characterization Program Implementation Plan (WCPIP) and this comprehensive approach will be implemented for all future RH waste characterization activities. EPA determined that the sample collection and analyses were technically ad equate to support characterizati on of the Pre-SETF wastes. EPA approves this T1 change.

The tiering table accompanying the February 2009 baseline approval remains unchanged. However, one of the Tier 1 items under Acceptabl e Knowledge (AK) requires some clarification. Namely, future revisions to the CCP-AK-ORNL-501 that add containers to the approved debris waste stream is a T1 change.

Following EPA’s baseline approval, EPA is author ized to evaluate and approve changes, if necessary, to the site’s approved waste char acterization 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 thos e requiring post-implementation (Tier 2 or T2) notification, are iden tified in the site-speci fic baseline inspection reports. When evaluating

1 SETF is the radiochemical facility at ORNL where these RH TRU wastes were generated.6 proposed T1 changes for approval, EPA may conduc t a site inspection to observe first-hand the implementation of the change, or can opt to condu ct a “desktop” review of information provided specific to a change. Department of Energy (DOE) may choose to characterize and dispose of, at risk of subsequent EPA disapproval, a ny previously approved TRU waste using processes/procedures/equipment implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may conduct continued co mpliance inspections to evaluate implemented T2 changes to verify adequacy.

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes to the waste characterization act ivities from the date of the site’s baseline inspection must be reported to and, if a pplicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulatio ns and incorporated in the ORNL-CCP RH Baseline Final Report cited above.

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, EPA must perform a single ba seline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the s ite’s waste characterization program, based on the demonstration that the program’s components, w ith applicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on
TRU wastes destined for di sposal at the WIPP.

3.0 SCOPE OF THE TIER 1 EVALUATION

Waste stream OR-REDC-RH-HET is composed of retrievably stored debris that ORNL-CCP plans to characterize and repackage for ship ment to WIPP. EPA’ s baseline approval and subsequent T1 approval of this waste stream applied only to RH TRU wastes generated between 1978 and 2007. The scope of this T1 evaluation broadens this approval to include RH TRU debris (S5000) wastes that were generated from 1972-1978, referred to as the Pre-SETF wastes
which were not examined at the ORNL-CCP ba seline inspection or the July 2009 T1 inspection and which were identified as a T1 change in th e ORNL-CCP baseline insp ection report. A total
of 155 casks of RH TRU material s were generated during the Pr e-SETF period and these casks are the subject of this T1 evaluation.

4.0 TIER 1 EVALUATION

This evaluation included two waste characteriza tion areas: acceptable knowledge (AK) and radiological characterization. Each of these is addressed in a sepa rate section of this report. Personnel who participated in the T1 evaluation are listed in Table 1, along with each person’s affiliation and function during the evaluation.7 Table 1. T1 Evaluation Participants

Name Affiliation & Function Rajani Joglekar EPA Headquarters, Lead Inspector Ed Feltcorn EPA Headquarters, Inspector
Connie Walker SC&A, Technical Evaluator – AK Patrick Kelly SC&A, Technical Evaluator – Radiological Characterization
Amir Mobasheran SC&A, Technical Evaluator – Radiological Characterization Jim Holderness CCP, Technical Support – Radiological Characterization Irene Quintana CCP, AK Expert SPM Jene Vance CCP, Technical Support – Radiological Characterization Mike Seinsibaugh CCP, Management Support J.R. Stroble CBFO, NTP Manager

4.1 Acceptable Knowledge

AK Overview

EPA examined the AK process and associated in formation to determine whether the ORNL-CCP waste characterization program demonstrated co mpliance with the requirements of 40 CFR 194.8 for the Pre-SETF component of OR-REDC-RH-H ET. The added component includes 155 casks,
for which six drums were included on the AK Tracking Spreadsheet avai lable in January 2010. These drums of RH debris were generated at the Oak Ridge Site Radiochemical Engineering Development Center (REDC) facility.

Waste Characterization Element Description

As part of this evaluation, EPA reviewed documentation that ORNL-C CP had prepared to support the use of AK for characterizing the Pre- SETF wastes. This listing below includes combinations of analyses with the focus to de termine whether the Pre-SETF waste belonged in
waste stream OR-REDC-RH-HET.

• Adequacy of AK documentation

• Waste stream identification and defi nition, including physical description

• Radionuclide content of waste

• Sufficiency of AK Summary

• Drum data traceability

• Defense origin of waste

• Spent Nuclear Fuel (SNF) and High Level Waste (HLW) exclusion

• AK source document sufficiency8 • The Confirmatory Test Plan (CTP)

• The Waste Stream Profile Form (WSPF) and Characterization Reconciliation Report (CRR)

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

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

• AK accuracy

• Load management

Documents, Waste Containers, and Batch Data Reports Provided

EPA evaluated the documentation that ORNL-CCP prepared to support th e approval of the PreSETF component of Waste Str eam OR-REDC-RH-HET (referred to hereafter at the Pre-SETF waste). The list of all AK documents provi ded to EPA is included in Attachment A.

Waste Container and Batch Data Reports Reviewed

Typically, batch data reports (B DRs) containing the results of radiological and radiographic analysis (i.e., Real-Time Radiography or RTR) are reviewed as part of EPA’s traceability examination, as are historic data storage, transfer , and other records. This evaluation provides an understanding of the information available for drums as they were packaged and subsequently repackaged with visual examination (VE) and dose to curie (DTC) as part of the ORNL-CCP program. BDRs provided to EPA are listed in Table 2, below.

Table 2. ORNL-CCP DTC and VE BDRs Provided for EPA Review

Drum DTC BDR VE BDR No.
ORRH00018 ORRHDTC09009 RHORVE80009
ORRH00021 ORRHDTC09009 RHORVE80010
ORRH00022 ORRHDTC09009 RHORVE80010
ORRH00023 ORRHDTC09009 RHORVE80010
ORRH00025 ORRHDTC09009 RHORVE80007
ORRH00026 ORRHDTC09009 RHORVE80006

Waste Stream OR-REDC-RH-HET is composed of RH TRU debris waste originating from the REDC hot cell facility target fabrication and processing, analytical chemistry, and process development activities. The waste is currently stored in concrete casks, boxes, and drums at
ORNL that are transferred to the Transuranic Waste Processing Center (TWPC) hot cell in the Building 7880 for repackaging and certification. ORNL-CCP indicates that the current inventory of REDC waste to be repackaged from Wast e Stream OR-REDC-RH-HET is contained in 263 concrete casks, 8 55-gallon drums, and 1 B-88 box generated between April 1972 and February 2007. It is estimated that this i nventory will generate approximately 2,055 55-gallon drums (427.4 m 3 ) of RH and CH waste. Of these 263 casks, 155 were generated prior to 1978.9 ORNL-CCP determined that the overall REDC inve ntory can be characteri zed by three different radiological groupings: Mark-42 (which includes HFIR and Mark 42 fuel campaigns); SETF (which includes uranium and HFIR fuel campai gns); and the Pre-SETF (which includes HFIR campaigns, Pu-Al campaigns and Curium purifi cation Campaigns). The Pre-SETF waste was generated from March 6, 1972 to November 19, 1978. EPA’s baseline approval addressed only the Mark-42 waste, EPA approved the SETF porti on of the waste stream under a T1 evaluation in October 2009, and this report addresses the Pr e-SETF portion of the waste stream. See the discussion in (2), below.

The WCPIP requires AK information used to char acterize waste to be qualified by one of the techniques listed in Section 4.3 of the WCPIP; th at is, Peer Review, Confirmatory Testing, or demonstration of an equivalent Quality Assu rance (QA) Program. ORNL-CCP’s approach indicated that they intend to use confirmatory testing to qualify AK-based radiological characterization; physical propert ies of the waste will be dete rmined by VE that will be performed during repackaging. Th e confirmatory testing is a comparison of AK-based scaling factors against data obtained through assay of contact-handled (CH) TRU waste that has been
documented to be identical to its RH counter part with respect to waste generation and radiological content, with the ex ception of external dose rates.

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) Adequacy of AK documentation and their compliance with EPA requirements were assessed and were determined to be adequate.

At the baseline inspection, ORNL-CCP did not provide sufficient AK documentation for the PreSETF time period. As a result, EPA’s baseline ap proval cited several requ irements pertinent to the addition of the SETF or Pre-SETF time peri ods. During the baseline inspection, EPA noted that several AK documents were being expande d to cover a broader time period of waste generated at ORNL. Based on EPA’s analysis for the baseline and SETF T1 reviews, and evaluation of the Pre-SETF documents provide d at a later date, EP A found that the AK documentation was adequate, based on the freeze-file changes that EPA received from ORNLCCP. When they are available, EPA expects to receive the next vers ion of the pre-SETF AK Summary Report (AKSR) which has been revise d to incorporate freeze files addressing EPA questions for review.

(2) The scope of the T1 and the waste stream definition were examined for Waste Stream OR-REDC-RH-HET, and were found to be adequate.

The scope of this T1 evaluation was the approva l of wastes from the Pre-SETF time period. CCP-AK-ORNL-501, Revision 3, Appendix B states : “The radiologi cal characterization described herein is applicable to the RH TRU debris waste thatwas generated in the REDC hot cells in the first grouping of campaigns, designate d as the Pre-SETF period. This period spanned the time period from March 6, 1972 to November 19, 1978. A total of 155 RH TRU casks were10 generated from the three types of campaigns ove r this period which are the subject of this characterization report.”

The AKSR indicates that the waste stream consis ts of three campaign gr oupings called the PreSETF, SETF, and Mark-42 time periods. The Pr e-SETF time period includes HFIR, Pu-Al, and Curium campaigns, with the HFIR being th e common campaign type throughout the entire waste-stream generation time period. That is, the SETF, Pre-SETF and Mark-42 time periods all contain waste generated from HFIR campa igns. CCP-AK-ORNL-502, Revision 3, Draft A implies that every time period has a common HFIR component, therefore all REDC wastes generated from 1972 to 2007 are a single wast e stream. CCP-AK- ORNL-502, Revision 3,
Draft A states:

The first grouping is predominately target fabrication and separations waste from targets exposed in the High Flux Isotope Reactor (HFIR) (Pre-Solvent Extraction Test Facility [Pre-SETF]). The second grouping included light water reactor (LWR) fuel and fuel from the Fast Flux Test Facility ( FFTF) reactor; and therefore, larger quantities of Cs- 137 (SETF). In addition, the LWR and FFTF fuel introduced the uranium isotopes and different distributio ns and quantities of the plutonium isotopes, both of which woul d require different scaling factors from those developed for HFIR campaigns onl y. The third grouping includes Mark-42 fuel and even more Cs-137. The parts ar e designated by generation date as follows:

• 1 st Grouping – Pre-SETF, April 1972–November 1978
• 2 nd Grouping – SETF, December 1978–October 1991
• 3 rd Grouping – Mark-42, November 1991–February 2007

CCP-AK-ORNL-502, Revision 3, Draft A also states that although the waste stream has three radiologically distinct wa ste groupings based on generation dates, it is still a single waste stream.
ORNL-CCP states that the waste generating processes were the sa me and the wastes also have similar radiological characteristics. With regard to the different radiolog ical characteristics of the various time periods, CCP-AK-ORNL -502, Revision 3, Draft A states that:

CCP will be able to refine the radiological characterization of the waste on a cask-by-cask basis using the time of gene ration....The ability to generate isotopic ratios to apply cask-by-cask is no different than the use of a segmented gamma system that also provides a unique set of isotopics for each drum assayed

.

ORNL-CCP did not cite common ph ysical, chemical, or radiologica l properties as the basis for the waste stream. Instead, CCP-AK-ORNL-502, Revision 3 Draft A states: “Based on the multiple use of process equipment across campaigns, the common use of the laboratory facilities, and the ongoing maintenance activities, this material is considered a single process or activity and therefore is a single waste stream.”

The WCPIP, Section 2.3, states: “A waste stream is defined as waste material generated from a single process or activity, or as waste with similar physical , chemical, and radiological11 properties.” EPA found that common process ar gument made by ORNL-CCP regarding a single waste stream could be interpreted differentl y, so EPA examined the physical, chemical, and radiological aspects of the waste stream defin ition to better support the assignment of these wastes to a single waste stream.

With regard to waste generating processes, OR NL-CCP cites the repackaging process as the methodology for homogenizing the wa ste, but EPA questioned the degree of the waste stream’s homogeneity, particularly with respect to repack aging [see Item (7), below]. The AKSR states that the waste stream is composed of debris ge nerated in chemical pro cessing, target fabrication, analytical laboratory and process development, which have diverse physical compositions and descriptions. At the time of the baseline inspection, ORNL-CCP had not evaluated inventory data for the Pre-SETF time period to determine whether the physical characteristics of the PreSETF component agreed with the physical de scription in the AKSR. ORNL-CCP provided a revised memorandum dated August 19, 2009, that included a re-evaluation of the physical composition of the stream achieved by examini ng RTR from 255 drums and VE results from 64 drums of CH waste generated through retrieva l and/or repackaging of the SETF, Pre-SETF,
and Mark-42 casks. ORNL-CCP concluded that:

These results are comparable to the wa ste material parameters presented in Table 5-1 of the AK Summary report t hat shows a wide distribution expected within the containers, with iron based metal alloys, other inorganic materials, cellulosics, and plastics as the major contri butors to the debris in waste stream OR-REDC-CH-HET....Additionally, 64 CH drums have been repackaged in the TWCP from seven (7) of the Pre-SETF casks...an evaluation of the cask documentation, historic generator lo gbooks, and the TWPC Contact Handled Waste Repackaging Data From for each daughter drum was reviewed...This information further supports the assertion that the TRU waste contained in the casks to be repackaged in waste stream OR-REDC-RH-HET is physically similar over the generation time period and the wa ste stream description in the AK Summary report is representative for all the time periods described in CCP-AKORNL-501”. ORNL-CCP also elected to be tter define the physical characteristics of the waste stream as a whole in a freeze file revisi on to the CCP-TP-005 (Attachment 6 Memorandum), which veri fied the commonality of physical waste composition for the three time periods.

ORNL-CCP ultimately assigned thre e distinct scaling factors to groupings within the SETF time period, implying that the wastes are sufficiently distinct to apply both cask-by-cask partition factors (see Section 4.2) a nd three different scaling factors. Therefore, these data implied that three distinct streams may be pr esent. EPA questioned whether the radiological waste stream description presented in CCP- AK-ORNL-500 Revision 2 adequate ly identified and addressed radiological information presen ted in CCP-AK-ORNL-501 [see Item (7), below]. ORNL-CCP’s response was to provide revisi ons to CCP-AK-ORNL-500 as free ze file modifications, and a
Revision 3 of CCP-AK-ORNL-501 that included more informa tion about the radiological
characteristics of the waste stream.12 Upon examination of this information, EPA determined that the physical composition and radiological data adequately supported the physical and radiological similarities of the various campaign groupings. EPA recognizes that the radiological compositions based on campaign input information supported the choice to use three different scaling factors. In the case of this waste stream, EPA accepts the explanation that various scaling factors are used to define individual cask/drum radiological components much like a radioassay of a CH drum, because the radiological characterization is well supported and explained in CCP-AK-ORNL-501 and related documents. EPA accepts the freeze file change s and expects CCP-AK-ORNL-500 to be updated
to include the additional AK ra diological information found in CCP-AK-ORNL-501, Revision 3 for the Pre-SETF time period.

(3) The Correlation and Surrogate Summary Form was examined and was found to be adequate.

ORNL-CCP prepared a Correlati on and Surrogate Summary Form (CSSF) included as Reference C601, and which was repeated in a second CSSF provided to EPA in January 2010 specific to the Pre-SETF portion of the waste stream. The CCSFs document that prior to 1978, Building 7920 solid wastes were managed as RH-TRU wa ste, even though a signi ficant portion of the inventory produced was CH-TRU waste. These re ferences state that most of the Pre-SETF wastes would have been placed into concrete casks called “floor casks” and that this waste would contain significant amounts of lo wer dose rate waste that was ge nerated from the laboratory and support areas. This indicates that there was no attempt to phys ically segregate RH from CH waste during the Pre-SETF time period, so using NDA data from the later-segregated CH waste streams that were generated during recent repack aging is representative of the Pre-SETF RH

wastes.

To verify that the CH containers from the Pr e-SETF time period were comparable to the overall
RH waste stream as asserted by the CSSF, EPA examined the me morandum cited in Section (2) of this report, above, which compared the physic al composition of Pre-SETF CH wastes against the overall physical composition of the RH waste str eam as a whole. These data showed that the
CH Pre-SETF streams fell within the broader physical composition of th e RH waste stream.

Unlike the SETF drums wherein historical CH radi ological data were available for comparison to the RH stream, all Pre-SETF CH drums were ge nerated through segregation of the waste during repackaging. ORNL-CCP representatives stated that there is no physic al or radiological
distinction between the RH and CH components other than external dose rate, so the radiological composition of the segregated CH drums should be comparable to the RH drums generated from the same casks. This information suggests that the physical and radiological compositions of the
Pre-SETF CH drums are not outside that anticipated for the RH Pr e-SETF drums, so the CH and RH waste streams are comparable.

(4) Traceability of wastes was examined and was found to be adequate.

ORNL-CCP had not characterized individual cont ainers from the Pre-SETF time period using DTC at the time of the EPA baseline inspection. Additionally, none of the original Pre-SETF13 time period containers had undergon e repackaging at the time of EP A’s baseline, so BDRs from VE or visual examination technique (VET) were not available for EPA review.

More recently, ORNL-CCP has repackaged RH casks from the Pre-SETF time period, so traceability of drums originati ng from this repackaging was performed. ORNL-CCP provided
data for six drums that are listed in Table 3, below:

Table 3. Drum and Cask Info rmation Provided by ORNL-CCP

Drum ID Number Original Cask Number
ORRH00018 X10C0402945
ORRH00021 X10C0402945
ORRH00022 X10C0402970
ORRH00023 X10C0402970
ORRH00025 X10C0402925
ORRH00026 X10C0402925

Historical data for casks included the following:

• Authorization for Storage of Radi oactive-Contaminated Solid Waste

• Data/Manifest Package Change Log

• TRU (waste in) Trenches in solid waste storage area (SWSA)

• SWSA 5N Cask Overpack Data Package

• Cask Traveler Documentation

• Non destructive examination (NDE) Report (related to fabrication)

• Waste Item Movement History Report

• Repackage Activity Report

In addition to the above, an Add Contai ner Memo for Cask Nos. X10C0402945 and
X10C0402970 was examined that showed how ORNL -CCP evaluated the traceability for Drum Nos. ORRH00018, ORRH00021, ORRH00022, and ORRH00023 to ensure that they belong in the HET waste stream. This memorandum is prepar ed whenever a cask or waste is added to a stream and it documents the evaluation process us ed by ORNL-CCP to ensure that the casks are assigned to the appropriate waste stream. This memorandum states:

This evaluation included the review of exi sting AK for the casks, in addition to review of the VE BDRs ge nerated for these drums during packaging. It should be noted that evaluations of CH drums gene rated from these casks were performed,
and these containers were included in the corresponding CH waste stream ORREDC-CH-HET (CH Evaluations date d 1/20/2009, 1/26/2009, and 1/29/2009; see AK Sources M138, M139, and M140).

Based on the evaluation of the documentation for cask X1 OC0402945 (performed 8/22/2008), the cask was loaded during the 2/1/77-3/10/77 timeframe. U502 discusses the packaging and transfer of poly buckets to the 6-inch concrete cask during this time frame contai ning non-burnable cubicle waste. The container documentation in U100 identifies that the cask is full of 63 heat-sealed14 poly buckets sealed on 3/10/77. The waste is described as "misc. waste materials from cubicles, re., plastic tubing, bottles, manipulator boots, glass sample bottles, and discarded equipment parts in metal 1-gal cans.”

Based on the evaluation of the documen tation for cask X1 OC0402970 performed 8/22/2008), the cask was loaded during th e 3/21/78-3/23/77 timeframe. U503 discusses the packaging and transfer of the T-4 bags from Cubicles 1 and 9 to the 6-inch concrete cask during this time frame and loading the other waste items into the cask (3/23/78) containing non- burnable cubicle waste. The bags contain paint cans and discarded anal ytical equipment. The ca sk also contains 3 fiber drums, 2 plastic bags, bottom section of T-1 bag from the cold loading station, a discarded vacuum pump from M&C leak detector, and hand control valves (HCVs) from the Chemical Makeup Area (MUA) panel.

Based on the cask documentation and a re view of VE BDR Nos. RHORVE080009 and RHORVE090010 that were generated during packag ing of these drums, the containers are bounded by the current revision of the AKSR for the following attributes:

• Waste generation location and process

• Time period of generation

• Physical form compared to the assigned waste material parameters (WMPs)

• Chemical content

• Prohibited items

• Radionuclides

Additionally, the AK Tracking Spreadsheets, BDRS , and control tracking system /project tracking system (CTS/PTS) printo uts were provided to demonstr ate how the repackaged drums were tracked, identified, and characterized. All of this information served as objective evidence that ORNL-CCP demonstrated traceability of the Pre-SETF drums.

(5) The identification of HLW, TRU versus low level waste (LLW), and SNF was examined and was found to be adequate in the revised CCP-AK-ORNL-500.

EPA examined the identification of HLW, TRU ve rsus LLW, and SNF as pa rt of its baseline and
SETF Tier 1 evaluations. Because the Pre-SETF wastes were demonstrated to be appropriately assigned to the waste stream, the arguments presen ted in the baseline inspection and subsequent T1 evaluation apply to this waste stream, wherei n DOE concluded that the information in source
documents indicate that SNL and HLW are not present in this waste stream.

(6) Waste defense determination was eval uated and was found to be adequate.

CCP-AK-ORNL-500 (AKSR), Revision 1 states th at a formal defense determination was approved by CBFO in April 2006. ORNL-CCP states:15 This determination conclude d that the wastes generate d by operations in the REDC are irretrievably commingled with ma terials generated, in part, by the following atomic energy defense activities (Reference M023):

• Naval reactors development • Defense nuclear materials production • Defense nuclear waste a nd by-products management • Defense research and development activities

ORNL-CCP states that the HFIR target campaigns that produced 252 Cf that was fabricated into
neutron sources and included in the Pre-S ETF time period waste had defense-related applications. The AKSR also states that the waste generated fr om SETF and Mark-42 campaigns have not been segregated from wast e generated by the HFIR target campaigns, and accordingly all are defense-related due to the inseparable commingling of waste.

(7) The AKSR was evaluated and it was determined to be sufficient with incorporation of freeze file changes.

Revision 1 of the AKSR that was provided for EP A review had not been revised to address the
Pre-SETF waste stream. EPA’s review of the document in concert with CCP-AK-ORNL-501, Revision 1 revealed shortcomings in the AKSR w ith respect to specific assumptions and data. EPA addressed this shortcoming in its SETF Tier 1 approval, rec ognizing that ORNL-CCP rectified the issues through freeze file modifica tions. Since then, ORNL-CCP has also proposed additional freeze file changes as recently as October 2009. The proposed freeze file changes are adequate and all of these revisions will be inco rporated into the AKSR, including any additional
modifications ORNL-CCP initiates to include radionuclide AK information presented in the CCP-AK-ORNL-501 that is missing from the AKSR.

(8) Sufficiency of AK Support Documents and Re lated Document Tracking were evaluated with respect to completeness and found to be adequate.

ORNL-CCP expends significant effort to id entify and acquire AK Support Documents. CCP-TP-005, Revision 18, Attachment s 1 and 4 present the referen ces for the waste stream and overall support documents, respect ively, and these forms are typica lly complete and adequately
cross-referenced. The reference list in the AKSR was incomplete and some of the references in CCP-AK-ORNL-501, Revision 3 were absent from the AKSR. Additionally, not all references cited in the body of CCP-AK-ORNL -501 are included in the refere nce list, which is expected because the documents are updated continually, and reference lists are often in flux. EPA expects that the next revisions of these docum ents will contain all appropriate references.

(9) Content and technical adequacy of the Conformation Test Plan were evaluated and were found to be adequate after revision.

The Conformation Test Plan (CTP) is included in the Waste Certification Plan (CCP-AK-ORNL502, Revision 3, Draft A). The WCPIP st ates that the CTP must include:16 • A description of the waste stream or waste stream lots to which the plan applies

• An explicit description of th e waste characterization data quality objectiv es (DQOs) and quality assurance objectives (QAOs) that will be satisfied with the da ta being qualified

• A description of the DQOs and QAOs that wi ll not be confirmed with the data being qualified and an explanation of how compliance with those DQOs and QAOs will be
demonstrated

• A description of the confirmatory testing proposed, including the percentage of waste containers that will be subj ect to confirmatory testing

• A description of how the tested subpopulation will be represen tative of the waste stream
or waste stream lot

• Quantitative acceptance criteria for determini ng that the AK information in question can be qualified as characterization information

The CTP provides a description of the waste st ream, DQOs/QAOs, and a ge neral description of the characterization program, but does not adequa tely address the characterization process with respect to the Pre-SETF time peri od, particularly with respect to radiological characterization. Through review of source documents and the revised CCP-AK-ORNL-501 and other information, it can be determined that ORNL- CCP chose to characterize the Pre-SETF waste using campaign-specific scaling factors that were qualified by comparison of modeling results against NDA from analogous CH waste drums assayed using an EPA-approved system. However, the CTP did not clearl y describe this process. OR NL-CCP prepared a freeze file change that addressed the Pre-S ETF wastes, and text revisions to clarify the characterization approach. The freeze file changes were adequate and, when integrated, will clarify the CTP.

(10) Content and technical adequ acy of the Waste Stream Pr ofile Form and associated
Characterization Reconciliation Report were evaluated and we re found to be acceptable.

ORNL-CCP provided a Waste St ream Profile Form (WSPF) a nd related Characterization Reconciliation Report (CRR) for waste stream OR-REDC-RH-HET, which was signed by the site project manager (SPM), Irene Quinta na, on February 18, 2009. The WSPF did not distinguish between the different radiological subsets of the waste stream, and included the entire anticipated cask population (Mark-42, SETF, a nd Pre-SETF). The CRR examined during the baseline inspection addressed only casks from th e Mark-42 time period, as SETF and Pre-SETF wastes had yet to be repackage d. In the baseline approval, EP A stated that revisions to the WSPF are T1 changes when associated with iden tification of new scali ng factors and wastes outside those presented in CCP-AK-ORNL-500, Revision 0, while other revisions are T2 changes. This requirement has not been vi olated, because the WSPF does not specifically identify the SETF/Pre-SETF wastes, but EPA e xpects to be notified of all CRRs, which are completed on a lot basis. No revised WSPF, Ch ange Notices, or revise d CRRs were available
for the Pre-SETF wastes.

(11) Radiological characterization of the Pre-SETF waste was evaluated to determine the use and appropriate qualification of AK for th e Pre-SETF wastes, both of which were acceptable.17 CCP-AK-ORNL-501, Revision 3, Attachment B provides a description of the radionuclides and the processes that produced them for each of the three components of
waste stream OR-REDC-RH-HET. ORNL-CCP indicated that 137 Cs and 154 Eu are the
dominant contributors to the gamma dose rate, and a 154 Eu/ 137 Cs scaling factor was calculated based on the direct assay data of CH drums filled with the same waste as those of the Pre-SETF portion of the REDC waste stream. The 154 Eu/ 137 Cs ratio was then used
with the measured dose rate to determine the concentrations of 137 Cs and 154 Eu. From the
derived 137 Cs concentration, scaling factors we re developed from modeling of the contamination deposition on waste materials to derive the concentrations of the
remainder of the radionuclides th at are required to be reported.

Based on this information, the original processi ng campaign data for the Pre-SETF campaigns were used to develop mass ratios. Since AK was th e source of the mass ratios that ultimately fed into the scaling factor development, the AK re quired qualification by peer review, confirmatory testing, or qualification by an equivalent QA pr ogram. ORNL-CCP stated that: “all of the campaign inventory information derived from the REDC process control data is qualified by the confirmatory swipe sample and direct assay m easurement data of CH drums from the Mark-42 time period.” Similarly, the Pre-SETF modeling was confirmed by the direct assay measurement
data of CH waste drums from the Pre-SETF period. ORNL-CCP developed an NDA Sampling Plan, documented in CCP-AK-ORL-505A, to guide selection of the CH drums for assay,
wherein a minimum number of drums was defi ned. The NDA Sampling Plan indicated that
seven casks of RH TRU waste generated during the Pre-SETF time period were selected for assay; specifically, a cask from the April-Ma y 1972 time period and a cask from the AugustNovember 1973 time period were selected to re present the Curium purification campaigns.
Casks were selected from each of the remaini ng years (1974-1978) to generate drums from the HFIR campaigns. The NDA Sampling Plan indicat es that 135 casks were generated from the HFIR/Pu-Al campaigns, and 23 casks were genera ted from the Curium campaigns. ORNL-CCP
assumed a drum-to-drum variance of 120 -170% to calculate the minimum number of assays to be performed, which was thirty.

EPA examined the NDA Sampling Plan for compliance with the WCPIP and general sampling requirements and found that it did not include deta iled information required in the WCPIP. EPA determined that the sampling plan was not ade quate in that it did not describe the sample selection and collection activities. EPA exp ects that CBFO will address sampling in a more comprehensive manner in the revisions of the WCPIP and this comprehensive approach will be implemented for all future RH waste characte rization activities. Although the NDA Sampling Plan did not detail how the campaigns were select ed for evaluation and justification of the total drum-to-drum variation (which accounted for the required number of samples to be collected), ultimately, the number of drums selected for as say far exceeded the calculated value, thus accounting for any uncertainties rega rding the number of samples selected. Specifically, ORNLCCP generated 63 drums for assay, well above th e 30 required in the sampling plan. Of the 63 drums, 20 were from the curium campaign cas ks, which again obtained data from a campaign
series that was not included in previous CH assays (i.e., SETF in cluded HFIR assays, so there are additional assay data for this portion of the Pr e-SETF wastes). The number of samples was apparently intentionally weighted to obtain samples from the curium campaign because previous18 Mark-42/SETF activities included HFIR assays and samples, which was appropriate. General results of the NDA Sampling Plan implementa tion are presented in the CCP-AK-ORNL-501, Revision 3, and related references and calculation packages.

ORNL-CCP stated that the direct assay resu lts were obtained using an EPA approved assay system, which was verified by EPA through examin ation of the BDRs. ORNL-CCP entered the data from the radioassay summary data sheets into an EXCEL spreadsheet and compared the
measured 241 Am/ 137 Cs and 241 Am/ 137 Cs scaling factors against the predicted scaling factors. ORNL-CCP stated: “Of the 63 drums assayed, four drums had no 243 Am-243 reported. They were eliminated from the database, leaving a to tal of 59 to be included in the analysis. The
radionuclides of 241 Am and 243 Am were reported in 49 and 59 dr ums, respectively. A slightly smaller number of drums reported the curium isotopes. ORNL-CCP noted that 244 Cm was reported in 44 out of 63 measurements, 245 Cm was reported in 43 out of 63 measurements, and about one third of the drums assayed had 244 Cm and 245 Cm activity quantities less than the MDA of the assay device. 154 Eu was reported in 62 out of a total of 63 drums. ORNL-CCP concluded
that the 243 Am/ 137 Cs scaling factors from the measurements were the most reliable to compare against the predicted scali ng factors. The measured 241 Am/ 137 Cs scaling factors were also compared. ORNL-CCP concluded that: “the comparison shows that the average measured scaling factors differ from the predicted scali ng factors by a factor of approximately 4 and 29 percent for 241 Am and 243 Am, respectively. ORNL-CCP also compared the 241 Cm-244 and

241 Cm-245 data to the predicted values, and concl uded that the comparison between the predicted and measured values was acceptable. ORNL-CCP stated that: “Because of this excellent agreement between the 243 Am scaling factors, it is concluded that the 137 Cs partitioning factor and scaling factor modeling are reasonable, and that the derived scaling factors will provide a
reasonable estimate of the actinide content of th e RH TRU drums in the DTC procedure.” EPA accepted the agreement.

EPA examined the data within the Sampli ng Plan (CCP-AK-ORL-505a), source documents, BDRs, and other material, and concluded that the AK data used in the scaling factor developments were adequately described in term s of how AK data were used, and the AK data was appropriately qualified. The AK data asse mbly and evaluation process used by ORNL-CCP was comparable to that already reviewed a nd approved by EPA for the Mark-42 and SETF time periods.

(12) Data limitations, NCRs and Discrepancy Resolution Forms (DRFs) were examined and were found to be adequate.

ORNL-CCP personnel indicated that NCRs for th e Pre-SETF portion of the waste stream were not available. ORNL-CCP provided DR 009, DR003, and DR004 as examples of AK-AK discrepancy resolutions, although th ese were not directly applicab le to the Pre-SETF waste. EPA expects that DRFs will be generated as char acterization of the Pre-SETF waste progresses.

(13) AK accuracy was assessed and was found to be adequate after revisions were made to
address EPA’s concern.

The WCPIP requires the following with respect to AK accuracy:19 The SQAO, consistent with the requireme nts of Section 4.1.1.2 of the WCPIP, will review the AK Summary Report, conf irmatory test data and identified AK discrepancies, and prepare an AK Accuracy Re port. This report will identify the percentage of containers that have been assigned to another SCG. It will also identify the percentage of containers fo r which there are significant discrepancies in radionuclide informati on between the AK record and measured values. What constitutes a significant discrepancy will depend on site- and waste streamspecific considerations. The AK Accura cy Report will be updated annually. If AK accuracy falls below 90%, the site shall document this as a significant condition adverse to quality as defined by the C BFO QAPD. The site s hall notify the CBFO of this condition and implement appropriate corrective actions before proceeding with further characterization activitie s on the affected waste stream(s).

ORNL-CCP provided an AK Accuracy Report for Lot 1 of the Mark-42 time period wastes.

(14) Load Management was assessed and was found to not apply to ORNL-CCP at this time.

During the baseline inspection, ORNL-CCP repr esentatives indicated that any containers generated during repackaging that contained less than 100 nCi/g of TRU radionuclides would be segregated and would not be subject to load management. ORNL-CCP representatives stated that this had not changed. Therefore, EPA understands that load ma nagement will not be performed for the Pre-SETF portion of Waste Stream OR-REDC-RH-HET.

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team did not identify any findings related to AK. There are no open
concerns related to AK result ing from this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to AK except for restating text for the T1 items given previous SETF approval and this pre-SETF approval.20 4.2 Radiological Characterization

RH Waste Overview

Waste Stream OR-REDC-RH-HET c ontains mixtures of radionucli des from the commingling of HFIR campaigns, Pu-Al campaigns, and curium purification campaigns conducted within the REDC from March 6, 1972, to N ovember 19, 1978, referred to as the Pre-SETF period. The HFIR campaigns involved the proc essing of curium targets that ha d been irradiated in the HFIR
reactor and allowed to cool for decay of short-lived fission produc ts before being processed in the REDC. The targets typical ly contain americium (mostly 243 Am), all of the curium isotopes except 242 Cm and 243 Cm, the transcurium elements of californium (Cf), berkelium (Bk), einsteinium (Es), and fermium (Fm), and a sma ll amount of plutonium impurity contributed by the targets and the decay of 242 Cm and 244 Cm. The transcurium elements represent the end products that are produced, removed, and purif ied in the REDC, and by design, trace amounts remain in the wastes post-processing. Due to the relatively small amounts of 239 Pu in these samples, scaling factors were developed for Am, Pu, Cm, and Europium (Eu) isotopes, which are
referred to as actinides in ORNL-C CP documents and in this report.

The Pu-Al tube campaigns involved the processing of targets that had been irradiated at SRS. These targets contained mixtures of Pu, Am, an d Cm isotopes like those contained in the HFIR targets.

The curium purification and preparation campai gns involved subjecting th e recovered materials from the above two campaigns to additional purif ication steps to produce fresh targets for HFIR.

A total of 155 casks of RH TRU wastes were generated over the Pre-SETF time period and these casks are the subject of this T1 evaluation.

Radiological Characterization Overview

The nature of RH TRU wastes presents difficulties with resp ect to obtaining meaningful
measurement data. As has been the case at th e six RH TRU waste characterization sites that EPA has previously approved, RH radiological ch aracterization relies on the development of scaling factors that correlate an easily measur ed parameter like a waste container’s external exposure (dose) rate with isotopic distri butions for specific TRU radionuclides. The development of radionuclide scali ng factors for Pre-SETF wastes was essentially the same as what EPA evaluated and approved during the ORNL -CCP baseline inspection. The development
of the 137 Cs scaling factors was supported by the following three sources of information:

• REDC records of the HFIR processing of relevant campaigns, including measurement results from the process control samples that were available for each processing campaign. This information was used to develop the inventory ratios for these campaigns.

• Radiochemical sample results from a smear sampling campaign conducted in 1995 and 1996 to support the radiological characterization of the RH TRU waste generated in the21 REDC hot cells. This sample information wa s used in combination with the inventory information to develop the 137 Cs partition factors.

• NDA results from the same CH TRU debris waste stream generated in the REDC hot
cells were used to confirm the model a nd support the overall radionuclide uncertainty estimate. This approach is unique compared to other RH characterizations as actual CH radiological data were used to confirm the model.

The characterization methods used for the ORNL- CCP Pre-SETF RH wastes were evaluated in terms of the technical adequ acy of the approach as suppor ted by the program’s documents, procedures, and controls, and th e knowledge and understanding of the personnel involved in the RH waste characterization progr am. During this T1 evaluation, EPA examined the following elements of the ONRL-CCP radiolog ical characterization program:

• Development of DTC relationships as a func tion of waste density using Monte Carlo NParticle Transport Code (MCNP5) based on each drum’s measured external exposure (dose) rate, assuming the main contri butors to the extern al exposure were 137 Cs and 154 Eu

• Development of partitioning factors to adju st the ratio of the TRU radionuclides of
interest to 137 Cs and 154 Eu, as appropriate

• Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked radionuclides as supported by calculation packag es and the destructive assay of swipe samples from 1995–1996

Documents and Data Reports Provided

EPA evaluated the documentation that ORNL-CCP prepared to support th e approval of the PreSETF waste. The list of all radiological charac terization-related documents provided to EPA is
included in Attachment A.

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) The technical adequacy and documenta tion of the correlation of the Pre-SETF radionuclide inventory values to the 137 Cs and 154 Eu concentrations in Pre-SETF wastes were evaluated and were found to be adequate.

The basic assumption for the radiol ogical characterization of Pre- SETF wastes is that scaling
factors are correlated to the RE DC inventory values for the radionuclides of interest and 137 Cs
that are introduced into the hot cells at the start of each proc essing campaign. This had been evaluated and found to be adequate during the baseline inspection and this aspect had not changed for the Pre-SETF wastes. There were no concerns regard ing the technical adequacy and
documentation of the correlation of the Pre- SETF radionuclide inve ntory values to the 137 Cs and

154 Eu concentrations for the Pre-SETF pe riod in Waste Stream OR-REDC-RH-HET.22 (2) The development of radionuclide scaling fact ors and partition fact ors was evaluated and both were found to be technically ad equate and appropr iately documented.

A radionuclide scaling factor provides a tech nically sound method of deriving a value for
radionuclides that are difficult to measure on the basis of an easily measurable attribute like external dose rate, assuming the measured dose rate can be correlated to a known constituent, i.e., the fission products 137 Cs and 154 Eu, considered as the domina nt contributors to the gamma dose rate, in the case of Pre-SETF wastes. The scaling factor 154 Eu/ 137 Cs is needed to determine
the contribution of each of the tw o radionuclides to the average gamma dose rate measured at a
distance of one meter from the mid section of the waste drum. The 154 Eu/ 137 Cs scaling factor was derived from the direct assay data of CH drum filled with the Pre-SETF waste, having characteristically lowe r surface dose rate. The 137 Cs and 154 Eu dose contributions, when used in conjunction with the waste density and the DTC co rrelation, would lead to the determination of
the concentrations of 137 Cs and 154 Eu, and finally to the determination of the activities of the reportable radionuclides, using their 137 Cs-based scaling factors.

The modeling used for the Pre-SETF time peri od was based on an extension to the basic modeling used for the Mark-42/HIFR time peri od. The modeling for the Mark-42/HFIR time period, described in the main body of the Technical Report CCP-AK-ORNL-501, Revision 3, was based on swipe sampling of hot cell waste and surfaces, radionuclide inventory information from processing campaigns, and direct assay results of CH wastes. The extended model used for the Pre-SETF time period involved the development of a relationship between two ratios for each processing campaign: the mass ratios of the actinides to 137 Cs introduced into the hot cell at the start of a processing campaign ( 137 Cs Inventory Ratios) and the mass ratios of actinides to 137 Cs corresponding to the waste ( 137 Cs Waste Ratios). The ratio of each 137 Cs Inventory Ratio to its corresponding 137 Cs Waste Ratio was labeled as a 137 Cs Partition Factor. For the Pre-SETF time period, the campaign-specific parti tion factors were developed empi rically based on an extension of the modeling completed for the Mark-42 Peri od. The empirical deve lopment of partition factors for the Pre-SETF time period was the same as what was used for the SETF time period. The partition factors developed for the Mark-42 M5 campaign and the HFIR-69 campaign were
based on the 244 Cm/ 137 Cs activity ratios in the campaign inve ntories and the ratios measured on the waste samples. 244 Cm was chosen as representative of the actinides; it was the dominant radionuclide by activity.

The 137 Cs Partition Factors, which vary from campaign to campaign, were applied to the 137 Cs Inventory Ratios for their correspond ing campaigns to determine the 137 Cs-based scaling factors. A single set of scaling factors was determined fo r the characterization of all the waste generated in the Pre-SETF time period due to the similariti es in the commingled ra dionuclide distributions for the mixtures of the HFIR, Pu-Al, and curium purification campaigns. The scaling factors are shown in Table 4, below.

Table 4. ORNL RH TRU Scaling Fact ors for the Pre-SETF Time Period

in Units of Curies of Specific Radionuclide/Curies 137 Cs (Ci/Ci 137 Cs)

Radionuclides All Campaigns
Pu-238 1.35E-01
Pu-239 6.91E-05
Pu-240 2.96E+0023 Pu-241 3.38E-01
Pu-242 7.52E-04
Am-241 4.95E-01
Am-243 1.97E-01
Cm-244 3.55E+02
Cm-245 3.91E-02
Cm-246 2.75E+00

Sr-90 1.73E+01
Eu-154 4.30E-02

EPA evaluated the following aspects:

• Activity values derived from modeling and sta tistical metrics, namely mean and standard
deviation values for each measured radionuclide

• The appropriateness of the choice of physic al constants and radionuclide-specific attributes (specific activity, phys ical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technica l correctness of the values assigned to each
attribute

• Isotopic activity values are correlated to the radionuclid es whose physical half-lives possibly contribute to the meas ured external dose rate, i.e., 137 Cs and 154 Eu

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

• Appropriate decay correction according to ORNL-CCP procedure (CCP-TP-504) of all radionuclide values for purposes of model de velopment and routine assays performed via
DTC

• The calculated results used to develop the scaling factors and convert the measured
external dose rates obtained via DT C to radionuclide activity levels

• Activity and uncertainty values determin ed for the ten WIPP-Tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs and 90 Sr)

• The determination of the contribution of a ll radionuclides to the radiological hazard 2

• Shielding and other calculati ons supporting the scaling fa ctors performed using MCNP5 3 to derive the appropriate DT C relationships as a function of waste density for the geometry appropriate to the Pre-SETF wast e following repackaging (55-gallon drum)

There are no issues rela ted to the technical ad equacy or documentation of radionuclide scaling factors or partition factors for the Pre-SETF portion of waste stream OR-REDC-RH-HET.

2 Although the determination of a waste container’s radiolog ical hazard is not an EPA requirement, this information may be useful in understanding other aspects of a container’s radiological characterization.

3 MCNP5 is Monte Carlo N-Particle Transport Code that has been developed by LANL.24 (3) The technical basis of the DTC correlati on and its documentation were evaluated and found to be unchanged from what EPA had in spected and approved previously, and both aspects were acceptable.

The DTC correlation was based on the following assumptions:

• The waste drum 100 percent full with waste

• The radionuclides of interest disp ersed uniformly throughout the waste

• The waste matrix’s density to be unity (one), because photon attenuation is more influenced by material density, as opposed to specific composition or atomic number

• Waste densities range from 0.1 g/cc to 2.1 g/cm 3

Using MCNP5, ORNL-CCP developed a DTC corre lation for an ORNL drum filled with RH
TRU waste in terms of mR/h r for a 1-curie source of 137 Cs and 154 Eu. Figure B6-1 in
CCP

- AK

- ORNL

- 501, Revision 3 shows a plot of dose rate as a function of waste density at a
distance of 1 meter for 137 Cs and 154 Eu. A DTC spreadsheet similar to the DTC spreadsheet that EPA evaluated during the baseline inspection is used for Pre-SETF wastes as well, involving the Pre-SETF scaling factors. The spreadsheet cont ained the required info rmation, specifically: cask identification number; container gross weight; estimated fill percentage; and results of the
four dose rate measurements that are obtai ned via the application of DTC procedure CCP-TP-504. An example Waste Drum DTC Conversion Record (s preadsheet) is included as Table B6-1 in CCP-AK-ORNL-501, Revision 3. There were no con cerns regarding the technical
basis of the DTC correlation and its documen tation for the ORNL-CCP Pre-SETF wastes.

(4) Technical aspects and docu mentation of the radiological characterization process were evaluated and found to be acceptable.

CCP-AK-ORNL-501, Revision 3 is the main doc ument that describes the radiological characterization process that ORNL-CCP used for the Pre-SETF wastes. This document is supported by a series of calculation packages, five of which were reviewed in the process of evaluating the Pre-SETF wastes. These packages had been prepared an d reviewed by several CCP radiological char acterization team members who suppor ted the ORNL-CCP RH baseline effort. Many of them had been since revised to incorporate the Pre-SETF wastes, as listed above. These packages documented the following:

• Application and verifi cation of MicroShield ®

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

• Decay correction to an assumed reference date of January 1, 2009

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

• Potential sources of uncerta inty for Pre-SETF wastes

• Information input checks for Pre-SETF wastes

• Technical development of scaling factors and 137 Cs partitioning factors25 • Technical derivation of the DTC approach and documentation of the DTC spreadsheet

The EPA evaluation team review ed these packages and Revi sion 3 of CCP-AK-ORNL-501 in advance of the formal T1 evaluation meeting at EPA headquarters. Several documents had been revised more recently and these revisions were evaluated during the meeting as they were provided by ORNL-CCP. During these discus sions, the EPA evaluation team had the opportunity to discuss all tech nical concerns and apparent discrepancies with ORNL-CCP personnel and to question ORNL-CCP personnel regarding a variety of technical as pects related
to the Pre-SETF wastes. None of the calculati on packages required serious modifications. The
EPA evaluation team found that CCP-AK-ORNL -501 adequately documented the radiological characterization process for Pre-SETF wastes , and the calculation packages cited above adequately supported the activit ies upon which the radiological characterization of Pre-SETF
wastes was based. There were no issues related to the documentation of technical aspects of the ORNL-CCP radiological characterizati on approach for Pre-SETF wastes.

(5) The technical basis and derivation of To tal Measurement Uncertainty (TMU) were evaluated and were found to be adequate.

The development of TMU for Waste Stream OR -REDC-RH-HET is based on the propagation of uncertainties present in all aspects of the determ ination of the radiologica l constituents of RH TRU waste. These aspects are assumed to be in dependent, which allows them to be added in quadrature. The TMU determination in cluded contributions of the following:

• Drum weight measurement

• Measurement uncertainty

• Scaling factor uncertainty

• MCNP5 code and modeling issues

• Contributions of other gamma emitters

• Drum-to-drum variation within each campaign

• Uncertainty in reported campaign inventories

The treatment of TMU is presented in CCP -AK-ORNL-501 and Calculation Package No. ORNL-RH-32. The principal sour ces of uncertainty in the 137 Cs scaling factors result from: variations in the campaign-to-campaign scaling factors; variations in the 137 Cs partition factors;
and variations in the waste content from drum-t o-drum. The largest single contributor to the overall uncertainty is the scaling f actor, as shown in Table 5, below.26 Table 5. Overall Uncertainty Listed by Radionuclide for Pre-SETF Wastes at a Density of 0.3 g/cm 3

Radionuclide 137 Cs Activity Uncertainty Scaling Factor Uncertainty Total Uncertainty

Pu-238 37.0% 122.9% 128.3%

Pu-239 37.0% 96.4% 103.3%

Pu-240 37.0% 101.8% 108.4%

Pu-241 37.0% 175.8% 179.7%

Pu-242 37.0% 164.9% 169.0%

Am-241 37.0% 109.5% 115.6%

Am-243 37.0% 113.5% 119.4%

Cm-244 37.0% 100.4% 107.0%

Cm-245 37.0% 113.7% 119.6%

Cm-246 37.0% 100.5% 107.1%

Sr-90 37.0% 30.0% 47.6%

Cs-137 37.0%

- 37.0%

There were no concerns regarding the technical derivation and documentation of TMU for the
ORNL-CCP Pre-SETF RH wastes.

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

The determination that the RH containers meet the definition of TRU wa ste and RH waste were examined during the baseline insp ection. Both of these aspects are directly involved with the
DTC measurement at the Transuranic Waste Pro cessing Center (TWPC), as was observed during the baseline inspection. These were not assessed directly during this T1 evaluation but EPA did verify that no aspects of these two determina tions had changed. There were no technical or documentation-related concerns regarding the TR U and RH determinations for ORNL Pre-SETF

wastes.

Summary of Radiological Characterization Findings and Concerns

The EPA inspection team did not identify any fi ndings or concerns related to radiological characterization. There are no open concerns rela ted to radiological char acterization resulting
from this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to radiological characteri zation during the baseline approval.27 5.0 FINDINGS OR CONCERNS

Summary of Findings and Concerns

The EPA inspection team did not id entify any findings or concerns related to AK or radiological characterization. There are no open concerns re lated to AK or radiological characterization resulting from this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations that had been assigned to AK or radiological ch aracterization during the baseline approval except the updated text for AK T1 changes reflecting th e SETF waste approval and this approval since the baseline approval decision.

6.0 CONCLUSIONS

EPA concluded that the waste ch aracterization processes of AK a nd radiological characterization proposed for use to characterize RH TRU wastes from the Pre-SETF period are adequate, as evidenced by the records produced in ch aracterizing ORNL RH TRU Waste Stream
OR-REDC-RH-HET.

Approval

The T1 change that was evaluated consisted of the waste characterization techniques of AK and radiological characterization as applied to Pre-SETF RH TRU wa stes at ORNL-CCP. Based on the results of this evaluation, EPA approves th is T1 change. ORNL -CCP is approved to characterize the Pre-SETF RH TRU wastes, consis tent with the limitations specified in this report.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to AK or radiological characterization during the base line approval except the updated text for AK T1 changes reflecting the SETF wast e approval and this appr oval since the baseline approval decision.A-1 Appendix A List of AK and Radiological Characte rization Documents Provided to EPA

• C601, RH TRU Waste Correlation and Surroga te Summary Form for OR-REDC-RH-HET Waste Stream, K. Peters, July 1, 2008

• DR003, Discrepancy Resolution: Generation Loca tion Discrepancies, Jeff Harrison, June 27,
2008

• DR004, Discrepancy Resolution re: Radiologica l Discrepancies, Jeff Harrison, January 12,
2009

• DR009, Discrepancy Resolution for: Waste Inci dental to Reprocessi ng re: REDC CH and RH Waste in Building 7920, Je ff Harrison, October 2, 2008

• M023, Defense Determination for REDC Hete rogeneous Debris, B. Humphrey, April 25,
2005

• M13B, CCP-AK-ORNL-002 Drum Addition Memo for OR-REDC-CH-HET, J. Harrison, January 20, 2009

• M139, CCP-AK-ORNL-002 Drum Additions for OR-REDC-CH-HET, K. Peters, January 26, 2009

• M140, Add Container Memo from January 29, 2009 for Cask Repack Additions for REDC (OR-REDC-CH-HET), K. Peters, January 29, 2009

• P1115, Solid Waste Storage Area 5 North Tran suranic Waste Engineering Study for the 22-Trench Area at Oak Ridge National La boratory, Bechtel Jacobs, August 2001

• U090, Mark 42 Period -HFIR-ORNL RH TRU Da ta Extracted from Process Information Package for Radiological Characterizati on for Campaigns 68, 69, 70, 71, 72, 73 and M1,
ORNL

• U093, Pre SETF: ORNL RH TRU Data Extracted from REDC Process Information Package for Radiological Characteriza tion for Campaigns 33-55, ORNL

• U501, Logbook: G. A. West; C. E. Roberts; H. C. Thompson; January 4, 1972; Bldg 7920 Waste Logbook, G. A. West; C. E. Roberts; H. C. Thompson, Revision 0, January 2, 1975 – August 31, 1976

• U502, Logbook: TRU Log (Maintenance & Waste); G. A. West; C. E. Roberts; H. C. Thompson; Bldg 7920, G. A. West, Revision 0, September 1, 1976 – November 30, 1977A-2 • U503, Logbook: TRU Maintenance & Waste Disposal; Building 7920; December 1, 1977 – February 2, 1979; West; Roberts; Thompson, G. A. West; C. E. Roberts; H. C. Thompson, Revision 0, December 1, 1977 – February 2, 1979

• U624, CCP Calculation Package - Pre-SETF Info rmation Input Check, J. Vance, Revision 0, June 1, 2009

• U650, CCP Calculation Package - Uncertainty An alysis for the Pre-SETF Time Period, J. Vance, Revision 0, June 1, 2009

• U652, CCP Calculation Package - DTC Spreadsheet for Pre-SETF Period, J. Vance, Revision 0, May 26, 2009

• U653, CCP Calculation Package - Scaling Factor Development for Pre-SETF Time Period, J. Vance, Revision 0, June 11, 2009

• U655, CCP Calculation Package - Determination of Reportable Isotopes, Pre-SETF Period, J. Vance, Revision 0, June 11, 2009

• U658, CCP Calculation Package - Direct Assa y Information Input Check, Pre-SETF, J. Vance, Revision 0, June 1, 2009

• U660, CCP Calculation Package - Direct Assa y Data Analysis, Pre-SETF, J. Vance, Revision 0, June 1, 2009

• U661, CCP Calculation Package - Residual Cs-1 37 Activity in HFIR Campaigns, J. Vance, Revision 0, June 1, 2009

• U663, CCP Calculation Package - Typical Cs-137 Activity in HFIR Targets for Missing Inventory Values, J. Vance, Revision 0, April 6, 2009

• U667, CCP Calculation Package - Alternative Scaling Factor Models Using Regression Analysis, J. Vance, Revision 0, April 6, 2009

• U668, CCP Calculation Package - Mark 42 A lternative Scaling Factor Method Using Campaign Partition Factors, J. Vance, Revision 0, April 6, 2009

• CCP-AK-ORNL-500, Central Characterization Project Acceptable Knowledge Summary Report for Oak Ridge National Laboratory Radi ochemical Engineering Development Center, Remote-Handled Transuranic Waste, Wa ste Stream OR-REDC- RH-HET, Revision 1, October 3, 2008 (AKSR)

• CCP-AK-ORNL-501, Central Characterization Project, Remote-Handled Transuranic Radiological Characterization, Technical Report For Remote -Handled Transuranic Waste From Oak Ridge National Laboratory Radioc hemical Engineering Development Center, Waste Stream: OR-REDC-RH-HET Revision 3, August 13, 2009A-3 • CCP-AK-ORNL-502, Central Characterization Proj ect RH TRU Waste Cert ification Plan for 40 CFR Part 194 Compliance and Confirmati on Test Plan for Oak Ridge National Laboratory REDC RH Waste Stream: OR-REDC-RH-HET, Revision 3, August 19, 2009 (CTP)

• CCP-AK-ORNL-503, Central Characterization Project Oak Ridge National Laboratory Quality Assurance Equivalency Report and Procedure Matrix For Remote-Handled Transuranic Debris Waste, Revision 1, February 13, 2009

• CCP-AK-ORNL-505A, Central Characterizatio n Project Nondestruc tive Assay Sampling Plan for Oak Ridge National Laboratory Radi ochemical Engineering Development Center Remote-Handled Transuranic Waste (P re-SETF), Revision 0, December 31, 2008

• CCP-AK-ORL-505B, Central Characterization Pr oject Nondestructive Assay Sampling Plan for Oak Ridge National Labor atory Radiochemical Engine ering Development Center
Remote-Handled Transuranic Wa ste (SETF), Revision 0, May 21, 2009

• CCP-TP-005, Revision 18: Att achment 4, Acceptable Knowledge Source Document Reference List for OR-REDC-RH-HET, provi ded November 13, 2009; Attachment 6, Waste Form, Waste Material Parameters, Prohibite d Items, and Packaging, Oak Ridge National Laboratory REDC RH Debris Waste from Hot Cells, provided November 13, 2009; and Attachment 8, OR-REDC-RH-HET, Waste C ontainer List, provided December 8, 2009

• DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, Revision 6.3, U.S. Department of Ener gy Carlsbad Field Office, February 5, 2009

• Historic Data Sheets, CH Drums X10C9311909, X10C9312455, including 2109 forms, Data/manifest packaging logs, or iginal CH assay (2004), Reques t for Storage Disposal Forms and Tracking Update Forms (various dates, 1981–1993)

• Inter-Office Correspondence, from J.E. Hoff to Distribution, Transmittal of Washington TRU Solutions LLC Audit Report E08-11, September 5, 2008

• Interoffice Correspondence, C. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Wast e Stream Number OR-REDC-HET, Lot 1, June 15, 2009

• Memorandum, from S. Shafer to CCP Records, RE: Waste Material Parameter Estimates for Waste Stream OR-REDC-RH-HET, Oak Ri dge National Laboratory Radiochemical Engineering Development Center, Mixed Hete rogeneous Debris Waste (does not include SETF waste), April 24, 2008

• Pre-SETF Feed Inventory Spreadsh eet, provided November 13, 2009

• Remote Handled TRU Waste Characterizati on Program Implementation Plan, Revision 0d, (Subject to Approval), U.S. Department of Energy Carlsbad Field Office, October 30, 2003A-4 • RH CRR Container Data Work Sheets (e xamples only, OR-REDC-RH-HET Stream, 1991- 2007 time period waste), provided July 8, 2009

• Waste Stream Profile Form for OR-REDC-RH -HET, at the Oak Ridge National Laboratory (WSPF), (does not include SETF waste), incl uding Characterization Reconciliation Report (CRR), June 3, 2009

• 2109 Forms to Support Traceability fo r Cask Nos. X10C0402925, X10C0402945, X10C0402970, provided to EPA on December 8, 2009

• Add Container Memoranda, K. Peters to H. Neely, RE: Addition of Container Nos. ORRH00018, ORRH00021, ORRH00022, and ORRH 00023 to Waste Stream OR-REDCRH-HE