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

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT (CCP) 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION 

PROGRAM FOR OAK RIDGE NATIONAL LABORATORY (ORNL): 

PRE-SETF PERIOD WASTES (APRIL 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 2010
 i 

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 Radiological Characterization 
 ii 

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 Technical 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 iodine 
 iii 

LLW low level waste 

LWR light water reactor 

MCNP5 Monte Carlo N-Particle 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 Engineering 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 technique 
 iv 

WCPIP Waste Characterization Program Implementation Plan 

WIPP Waste Isolation Pilot Plant 

WMP waste material parameters 

WSPF waste stream profile form 
 5 

1.0 EXECUTIVE SUMMARY 

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

of the addition of retrievably stored, remote-handled (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. Previously EPA approved wastes specific to two different radiological 

groupings belonging to this waste stream. The radiological groupings are: High Flux Isotope 

Reactor (HFIR) and Mark-42 wastes (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 responsible for characterizing 

this waste using the system of controls which 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 generated from November 1991 through February 

2007, and the SETF period wastes were generated 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 processes on site at ORNL to examine, EPA conducted 

a desktop evaluation during February and March 2010. This report presents the results of this T1 

evaluation. ORNL-CCP used the EPA-approved procedures and processes to characterize the 

Pre-SETF RH TRU wastes, and EPA inspectors determined them to be technically adequate. As 

part of this evaluation, EPA did not identify any Findings or Concerns. However, EPA 

determined that the non destructive 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 adequate to support characterization 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 Acceptable 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 authorized to evaluate and approve changes, if 

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

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

approval prior to implementation (T1), and those requiring post-implementation (Tier 2 or T2) 

notification, are identified in the site-specific 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 conduct a site inspection to observe first-hand the 

implementation of the change, or can opt to conduct 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, any 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 compliance inspections to evaluate implemented 

T2 changes to verify adequacy. 

2.0 PURPOSE OF TIER 1 EVALUATION 

Certain changes to the waste characterization activities from 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 regulations 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 baseline 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 site’s waste characterization program, based on the 

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

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

TRU wastes destined for disposal at the WIPP. 

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 shipment 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 baseline inspection or the July 2009 T1 inspection 

and which were identified as a T1 change in the ORNL-CCP baseline inspection report. A total 

of 155 casks of RH TRU materials were generated during the Pre-SETF period and these casks 

are the subject of this T1 evaluation. 

4.0 TIER 1 EVALUATION 

This evaluation included two waste characterization areas: acceptable knowledge (AK) and 

radiological characterization. Each of these is addressed in a separate 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. 
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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 information to determine whether the ORNL-CCP 

waste characterization program demonstrated compliance with the requirements of 40 CFR 194.8 

for the Pre-SETF component of OR-REDC-RH-HET. The added component includes 155 casks, 

for which six drums were included on the AK Tracking Spreadsheet available 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-CCP 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 determine whether the Pre-SETF waste belonged in 

waste stream OR-REDC-RH-HET. 

• Adequacy of AK documentation 

• Waste stream identification and definition, 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 sufficiency 
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• 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 the approval of the PreSETF component of Waste Stream OR-REDC-RH-HET (referred to hereafter at the Pre-SETF 

waste). The list of all AK documents provided to EPA is included in Attachment A. 

Waste Container and Batch Data Reports Reviewed

Typically, batch data reports (BDRs) 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 Waste 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 inventory will generate approximately 2,055 55-gallon 

drums (427.4 m3

) of RH and CH waste. Of these 263 casks, 155 were generated prior to 1978. 
 9 

ORNL-CCP determined that the overall REDC inventory can be characterized by three different 

radiological groupings: Mark-42 (which includes HFIR and Mark 42 fuel campaigns); SETF 

(which includes uranium and HFIR fuel campaigns); and the Pre-SETF (which includes HFIR 

campaigns, Pu-Al campaigns and Curium purification 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 portion of the waste stream under a T1 evaluation 

in October 2009, and this report addresses the Pre-SETF portion of the waste stream. See the 

discussion in (2), below. 

The WCPIP requires AK information used to characterize waste to be qualified by one of the 

techniques listed in Section 4.3 of the WCPIP; that is, Peer Review, Confirmatory Testing, or 

demonstration of an equivalent Quality Assurance (QA) Program. ORNL-CCP’s approach 

indicated that they intend to use confirmatory testing to qualify AK-based radiological 

characterization; physical properties of the waste will be determined by VE that will be 

performed during repackaging. The 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 counterpart with respect to waste generation and 

radiological content, with the exception 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 approval cited several requirements pertinent to 

the addition of the SETF or Pre-SETF time periods. During the baseline inspection, EPA noted 

that several AK documents were being expanded 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 provided at a later date, EPA 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 version of the pre-SETF AK 

Summary Report (AKSR) which has been revised 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 approval of wastes from the Pre-SETF time period. 

CCP-AK-ORNL-501, Revision 3, Appendix B states: “The radiological characterization 

described herein is applicable to the RH TRU debris waste that was generated in the REDC hot 

cells in the first grouping of campaigns, designated 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 were 
 10 

generated from the three types of campaigns over this period which are the subject of this 

characterization report.” 

The AKSR indicates that the waste stream consists of three campaign groupings called the PreSETF, SETF, and Mark-42 time periods. The Pre-SETF time period includes HFIR, Pu-Al, and 

Curium campaigns, with the HFIR being the 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 campaigns. 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 waste 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 distributions and quantities of 

the plutonium isotopes, both of which would require different scaling factors from 

those developed for HFIR campaigns only. The third grouping includes Mark-42 

fuel and even more Cs-137. The parts are designated by generation date as 

follows: 

• 1st Grouping – Pre-SETF, April 1972–November 1978 

• 2nd Grouping – SETF, December 1978–October 1991 

• 3rd 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 waste groupings based on generation dates, it is still a single waste stream. 

ORNL-CCP states that the waste generating processes were the same and the wastes also have 

similar radiological characteristics. With regard to the different radiological 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 generation....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 physical, chemical, or radiological 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 radiological 
 11 

properties.” EPA found that common process argument made by ORNL-CCP regarding a single 

waste stream could be interpreted differently, so EPA examined the physical, chemical, and 

radiological aspects of the waste stream definition to better support the assignment of these 

wastes to a single waste stream. 

With regard to waste generating processes, ORNL-CCP cites the repackaging process as the 

methodology for homogenizing the waste, but EPA questioned the degree of the waste stream’s 

homogeneity, particularly with respect to repackaging [see Item (7), below]. The AKSR states 

that the waste stream is composed of debris generated in chemical processing, 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 description 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 examining RTR from 255 drums and VE results from 

64 drums of CH waste generated through retrieval and/or repackaging of the SETF, Pre-SETF, 

and Mark-42 casks. ORNL-CCP concluded that: 

These results are comparable to the waste material parameters presented in 

Table 5-1 of the AK Summary report that shows a wide distribution expected 

within the containers, with iron based metal alloys, other inorganic materials, 

cellulosics, and plastics as the major contributors 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 logbooks, 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 waste stream description in the AK 

Summary report is representative for all the time periods described in CCP-AKORNL-501”. ORNL-CCP also elected to better define the physical characteristics 

of the waste stream as a whole in a freeze file revision to the CCP-TP-005 

(Attachment 6 Memorandum), which verified the commonality of physical waste 

composition for the three time periods. 

ORNL-CCP ultimately assigned three 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) and three different scaling factors. Therefore, these data implied that 

three distinct streams may be present. EPA questioned whether the radiological waste stream 

description presented in CCP-AK-ORNL-500 Revision 2 adequately identified and addressed 

radiological information presented in CCP-AK-ORNL-501 [see Item (7), below]. ORNL-CCP’s 

response was to provide revisions to CCP-AK-ORNL-500 as freeze file modifications, and a 

Revision 3 of CCP-AK-ORNL-501 that included more information 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 changes and expects CCP-AK-ORNL-500 to be updated 

to include the additional AK radiological 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 Correlation 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 waste, even though a significant portion of the 

inventory produced was CH-TRU waste. These references 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 lower dose rate waste that was generated from the laboratory and 

support areas. This indicates that there was no attempt to physically 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 repackaging is representative of the Pre-SETF RH 

wastes. 

To verify that the CH containers from the Pre-SETF time period were comparable to the overall 

RH waste stream as asserted by the CSSF, EPA examined the memorandum cited in Section (2) 

of this report, above, which compared the physical composition of Pre-SETF CH wastes against 

the overall physical composition of the RH waste stream as a whole. These data showed that the 

CH Pre-SETF streams fell within the broader physical composition of the RH waste stream. 

Unlike the SETF drums wherein historical CH radiological data were available for comparison to 

the RH stream, all Pre-SETF CH drums were generated through segregation of the waste during 

repackaging. ORNL-CCP representatives stated that there is no physical 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 Pre-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 containers from the Pre-SETF time period using 

DTC at the time of the EPA baseline inspection. Additionally, none of the original Pre-SETF 
 13 

time period containers had undergone repackaging at the time of EPA’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 originating from this repackaging was performed. ORNL-CCP provided 

data for six drums that are listed in Table 3, below: 

Table 3. Drum and Cask Information 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 Radioactive-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 Container 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 prepared whenever a cask or waste is added to a 

stream and it documents the evaluation process used by ORNL-CCP to ensure that the casks are 

assigned to the appropriate waste stream. This memorandum states: 

This evaluation included the review of existing AK for the casks, in addition to 

review of the VE BDRs generated for these drums during packaging. It should be 

noted that evaluations of CH drums generated from these casks were performed, 

and these containers were included in the corresponding CH waste stream ORREDC-CH-HET (CH Evaluations dated 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 containing non-burnable cubicle waste. The 

container documentation in U100 identifies that the cask is full of 63 heat-sealed 
 14 

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 documentation for cask X1 OC0402970 performed 

8/22/2008), the cask was loaded during the 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 analytical equipment. The cask 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 review of VE BDR Nos. RHORVE080009 and 

RHORVE090010 that were generated during packaging 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) printouts were provided to demonstrate 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 versus LLW, and SNF as part 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 presented in the baseline inspection and subsequent 

T1 evaluation apply to this waste stream, wherein 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 evaluated and was found to be adequate. 

CCP-AK-ORNL-500 (AKSR), Revision 1 states that a formal defense determination was 

approved by CBFO in April 2006. ORNL-CCP states: 
 15 

This determination concluded that the wastes generated by operations in the 

REDC are irretrievably commingled with materials generated, in part, by the 

following atomic energy defense activities (Reference M023): 

• Naval reactors development 

• Defense nuclear materials production 

• Defense nuclear waste and by-products management 

• Defense research and development activities

ORNL-CCP states that the HFIR target campaigns that produced 252Cf that was fabricated into 

neutron sources and included in the Pre-SETF time period waste had defense-related 

applications. The AKSR also states that the waste generated from SETF and Mark-42 

campaigns have not been segregated from waste 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 EPA 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 with respect to specific assumptions and data. 

EPA addressed this shortcoming in its SETF Tier 1 approval, recognizing that ORNL-CCP 

rectified the issues through freeze file modifications. 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 incorporated 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 Related Document Tracking were evaluated 

with respect to completeness and found to be adequate. 

ORNL-CCP expends significant effort to identify and acquire AK Support Documents. 

CCP-TP-005, Revision 18, Attachments 1 and 4 present the references for the waste stream and 

overall support documents, respectively, and these forms are typically 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 reference 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 documents 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 states 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 the waste characterization data quality objectives (DQOs) and 

quality assurance objectives (QAOs) that will be satisfied with the data being qualified 

• A description of the DQOs and QAOs that will 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 subject to confirmatory testing 

• A description of how the tested subpopulation will be representative of the waste stream 

or waste stream lot 

• Quantitative acceptance criteria for determining that the AK information in question can 

be qualified as characterization information 

The CTP provides a description of the waste stream, DQOs/QAOs, and a general description of 

the characterization program, but does not adequately address the characterization process with 

respect to the Pre-SETF time period, 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 clearly describe this process. ORNL-CCP prepared a freeze file 

change that addressed the Pre-SETF 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 adequacy of the Waste Stream Profile Form and associated 

Characterization Reconciliation Report were evaluated and were found to be acceptable. 

ORNL-CCP provided a Waste Stream Profile Form (WSPF) and related Characterization 

Reconciliation Report (CRR) for waste stream OR-REDC-RH-HET, which was signed by the 

site project manager (SPM), Irene Quintana, 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, and Pre-SETF). The CRR examined during the 

baseline inspection addressed only casks from the Mark-42 time period, as SETF and Pre-SETF 

wastes had yet to be repackaged. In the baseline approval, EPA stated that revisions to the 

WSPF are T1 changes when associated with identification of new scaling factors and wastes 

outside those presented in CCP-AK-ORNL-500, Revision 0, while other revisions are T2 

changes. This requirement has not been violated, because the WSPF does not specifically 

identify the SETF/Pre-SETF wastes, but EPA expects to be notified of all CRRs, which are 

completed on a lot basis. No revised WSPF, Change Notices, or revised 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 the 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 137Cs and 154Eu are the 

dominant contributors to the gamma dose rate, and a 154Eu/137Cs 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 154Eu/137Cs ratio was then used 

with the measured dose rate to determine the concentrations of 137Cs and 154Eu. From the 

derived 137Cs concentration, scaling factors were developed from modeling of the 

contamination deposition on waste materials to derive the concentrations of the 

remainder of the radionuclides that are required to be reported. 

Based on this information, the original processing campaign data for the Pre-SETF campaigns 

were used to develop mass ratios. Since AK was the source of the mass ratios that ultimately fed 

into the scaling factor development, the AK required qualification by peer review, confirmatory 

testing, or qualification by an equivalent QA program. 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 measurement 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 defined. 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-May 1972 time period and a cask from the AugustNovember 1973 time period were selected to represent the Curium purification campaigns. 

Casks were selected from each of the remaining years (1974-1978) to generate drums from the 

HFIR campaigns. The NDA Sampling Plan indicates that 135 casks were generated from the 

HFIR/Pu-Al campaigns, and 23 casks were generated 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 detailed information required in the WCPIP. EPA 

determined that the 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 WCPIP and this comprehensive approach will be 

implemented for all future RH waste characterization activities. Although the NDA Sampling 

Plan did not detail how the campaigns were selected 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 assay far exceeded the calculated value, thus 

accounting for any uncertainties regarding the number of samples selected. Specifically, ORNLCCP generated 63 drums for assay, well above the 30 required in the sampling plan. Of the 

63 drums, 20 were from the curium campaign casks, which again obtained data from a campaign 

series that was not included in previous CH assays (i.e., SETF included HFIR assays, so there are 

additional assay data for this portion of the Pre-SETF wastes). The number of samples was 

apparently intentionally weighted to obtain samples from the curium campaign because previous 
 18 

Mark-42/SETF activities included HFIR assays and samples, which was appropriate. General 

results of the NDA Sampling Plan implementation are presented in the CCP-AK-ORNL-501, 

Revision 3, and related references and calculation packages. 

ORNL-CCP stated that the direct assay results were obtained using an EPA approved assay 

system, which was verified by EPA through examination of the BDRs. ORNL-CCP entered the 

data from the radioassay summary data sheets into an EXCEL spreadsheet and compared the 

measured 241Am/137Cs and 241Am/137Cs scaling factors against the predicted scaling factors. 

ORNL-CCP stated: “Of the 63 drums assayed, four drums had no 243Am-243 reported. They 

were eliminated from the database, leaving a total of 59 to be included in the analysis. The 

radionuclides of 241Am and 243Am were reported in 49 and 59 drums, 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, 245Cm was reported in 43 out of 63 measurements, and 

about one third of the drums assayed had 244 Cm and 245Cm activity quantities less than the MDA 

of the assay device. 154Eu was reported in 62 out of a total of 63 drums. ORNL-CCP concluded 

that the 243Am/137Cs scaling factors from the measurements were the most reliable to compare 

against the predicted scaling factors. The measured 241Am/137Cs scaling factors were also 

compared. ORNL-CCP concluded that: “the comparison shows that the average measured 

scaling factors differ from the predicted scaling factors by a factor of approximately 4 and 29 

percent for 241Am and 243Am, respectively. ORNL-CCP also compared the 241Cm-244 and 

241Cm-245 data to the predicted values, and concluded that the comparison between the predicted 

and measured values was acceptable. ORNL-CCP stated that: “Because of this excellent 

agreement between the 243Am scaling factors, it is concluded that the 137Cs partitioning factor 

and scaling factor modeling are reasonable, and that the derived scaling factors will provide a 

reasonable estimate of the actinide content of the RH TRU drums in the DTC procedure.” EPA 

accepted the agreement. 

EPA examined the data within the Sampling 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 terms of how AK data were used, and the AK data 

was appropriately qualified. The AK data assembly and evaluation process used by ORNL-CCP 

was comparable to that already reviewed and 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 the Pre-SETF portion of the waste stream were 

not available. ORNL-CCP provided DR009, DR003, and DR004 as examples of AK-AK 

discrepancy resolutions, although these were not directly applicable to the Pre-SETF waste. 

EPA expects that DRFs will be generated as characterization 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 requirements of Section 4.1.1.2 of the WCPIP, will 

review the AK Summary Report, confirmatory test data and identified AK 

discrepancies, and prepare an AK Accuracy Report. This report will identify the 

percentage of containers that have been assigned to another SCG. It will also 

identify the percentage of containers for which there are significant discrepancies 

in radionuclide information between the AK record and measured values. What 

constitutes a significant discrepancy will depend on site- and waste streamspecific considerations. The AK Accuracy 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 CBFO QAPD. The site shall notify the CBFO 

of this condition and implement appropriate corrective actions before proceeding 

with further characterization activities 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 representatives 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 management 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 resulting from this T1 evaluation. 

Tiering Changes

Based on the results of this T1 evaluation, there 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 contains mixtures of radionuclides from the commingling of 

HFIR campaigns, Pu-Al campaigns, and curium purification campaigns conducted within the 

REDC from March 6, 1972, to November 19, 1978, referred to as the Pre-SETF period. The 

HFIR campaigns involved the processing of curium targets that had been irradiated in the HFIR 

reactor and allowed to cool for decay of short-lived fission products before being processed in 

the REDC. The targets typically contain americium (mostly 243Am), all of the curium isotopes 

except 242Cm and 243Cm, the transcurium elements of californium (Cf), berkelium (Bk), 

einsteinium (Es), and fermium (Fm), and a small amount of plutonium impurity contributed by 

the targets and the decay of 242Cm and 244Cm. The transcurium elements represent the end 

products that are produced, removed, and purified in the REDC, and by design, trace amounts 

remain in the wastes post-processing. Due to the relatively small amounts of 239Pu in these 

samples, scaling factors were developed for Am, Pu, Cm, and Europium (Eu) isotopes, which are 

referred to as actinides in ORNL-CCP 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, and Cm isotopes like those contained in the HFIR 

targets. 

The curium purification and preparation campaigns involved subjecting the recovered materials 

from the above two campaigns to additional purification 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 respect to obtaining meaningful 

measurement data. As has been the case at the six RH TRU waste characterization sites that 

EPA has previously approved, RH radiological characterization relies on the development of 

scaling factors that correlate an easily measured parameter like a waste container’s external 

exposure (dose) rate with isotopic distributions for specific TRU radionuclides. The 

development of radionuclide scaling 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 137Cs 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 the 
 21 

REDC hot cells. This sample information was used in combination with the inventory 

information to develop the 137Cs partition factors. 

• NDA results from the same CH TRU debris waste stream generated in the REDC hot 

cells were used to confirm the model and 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 adequacy of the approach as supported by the program’s documents, 

procedures, and controls, and the knowledge and understanding of the personnel involved in the 

RH waste characterization program. During this T1 evaluation, EPA examined the following 

elements of the ONRL-CCP radiological characterization program: 

• Development of DTC relationships as a function of waste density using Monte Carlo NParticle Transport Code (MCNP5) based on each drum’s measured external exposure 

(dose) rate, assuming the main contributors to the external exposure were 137Cs and 154Eu 

• Development of partitioning factors to adjust the ratio of the TRU radionuclides of 

interest to 137Cs and 154Eu, as appropriate 

• Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked 

radionuclides as supported by calculation packages 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 the approval of the PreSETF waste. The list of all radiological characterization-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 documentation of the correlation of the Pre-SETF 

radionuclide inventory values to the 137Cs and 154Eu concentrations in Pre-SETF wastes 

were evaluated and were found to be adequate.

The basic assumption for the radiological characterization of Pre-SETF wastes is that scaling 

factors are correlated to the REDC inventory values for the radionuclides of interest and 137Cs 

that are introduced into the hot cells at the start of each processing 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 regarding the technical adequacy and 

documentation of the correlation of the Pre-SETF radionuclide inventory values to the 137Cs and 

154Eu concentrations for the Pre-SETF period in Waste Stream OR-REDC-RH-HET. 
 22 

(2) The development of radionuclide scaling factors and partition factors was evaluated and 

both were found to be technically adequate and appropriately documented. 

A radionuclide scaling factor provides a technically 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 137Cs and 154Eu, considered as the dominant contributors to the gamma 

dose rate, in the case of Pre-SETF wastes. The scaling factor 154Eu/137Cs is needed to determine 

the contribution of each of the two radionuclides to the average gamma dose rate measured at a 

distance of one meter from the mid section of the waste drum. The 154Eu/137Cs scaling factor 

was derived from the direct assay data of CH drum filled with the Pre-SETF waste, having 

characteristically lower surface dose rate. The 137Cs and 154Eu dose contributions, when used in 

conjunction with the waste density and the DTC correlation, would lead to the determination of 

the concentrations of 137Cs and 154Eu, and finally to the determination of the activities of the 

reportable radionuclides, using their 137Cs-based scaling factors. 

The modeling used for the Pre-SETF time period was based on an extension to the basic 

modeling used for the Mark-42/HIFR time period. 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 137Cs introduced into the hot cell at the 

start of a processing campaign (137Cs Inventory Ratios) and the mass ratios of actinides to 137Cs 

corresponding to the waste (137Cs Waste Ratios). The ratio of each 137Cs Inventory Ratio to its 

corresponding 137Cs Waste Ratio was labeled as a 137Cs Partition Factor. For the Pre-SETF time 

period, the campaign-specific partition factors were developed empirically based on an extension 

of the modeling completed for the Mark-42 Period. The empirical development 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 244Cm/137Cs activity ratios in the campaign inventories and the ratios measured on 

the waste samples. 244Cm was chosen as representative of the actinides; it was the dominant 

radionuclide by activity. 

The 137Cs Partition Factors, which vary from campaign to campaign, were applied to the 137Cs 

Inventory Ratios for their corresponding campaigns to determine the 137Cs-based scaling factors. 

A single set of scaling factors was determined for the characterization of all the waste generated 

in the Pre-SETF time period due to the similarities in the commingled radionuclide 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 Factors for the Pre-SETF Time Period 

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

Radionuclides All Campaigns

Pu-238 1.35E-01

Pu-239 6.91E-05

Pu-240 2.96E+00
 23 

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 statistical metrics, namely mean and standard 

deviation values for each measured radionuclide 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 

• Isotopic activity values are correlated to the radionuclides whose physical half-lives 

possibly contribute to the measured external dose rate, i.e., 137Cs and 154Eu 

• Contributions of the short-lived radionuclides 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 development and routine assays performed via 

DTC 

• The calculated results used to develop the scaling factors and convert the measured 

external dose rates obtained via DTC to radionuclide activity levels 

• Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides 

(

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs and 90Sr) 

• The determination of the contribution of all radionuclides to the radiological hazard2

• Shielding and other calculations supporting the scaling factors performed using MCNP53 

to derive the appropriate DTC relationships as a function of waste density for the 

geometry appropriate to the Pre-SETF waste following repackaging (55-gallon drum) 

There are no issues related to the technical adequacy 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 radiological 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 correlation and its documentation were evaluated and 

found to be unchanged from what EPA had inspected 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 dispersed 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/cm3

Using MCNP5, ORNL-CCP developed a DTC correlation for an ORNL drum filled with RH 

TRU waste in terms of mR/hr for a 1-curie source of 137Cs and 154Eu. 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 137Cs and 154Eu. 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 contained the required information, specifically: 

cask identification number; container gross weight; estimated fill percentage; and results of the 

four dose rate measurements that are obtained via the application of DTC procedure 

CCP-TP-504. An example Waste Drum DTC Conversion Record (spreadsheet) is included as 

Table B6-1 in CCP-AK-ORNL-501, Revision 3. There were no concerns regarding the technical 

basis of the DTC correlation and its documentation for the ORNL-CCP Pre-SETF wastes. 

(4) Technical aspects and documentation of the radiological characterization process were 

evaluated and found to be acceptable. 

CCP-AK-ORNL-501, Revision 3 is the main document 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 and reviewed by several 

CCP radiological characterization team members who supported 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 verification of MicroShield®

• Evaluation of all potential contributors 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 uncertainty for Pre-SETF wastes 

• Information input checks for Pre-SETF wastes 

• Technical development of scaling factors and 137Cs partitioning factors 
 25 

• Technical derivation of the DTC approach and documentation of the DTC spreadsheet 

The EPA evaluation team reviewed these packages and Revision 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 discussions, the EPA evaluation team had the 

opportunity to discuss all technical concerns and apparent discrepancies with ORNL-CCP 

personnel and to question ORNL-CCP personnel regarding a variety of technical aspects related 

to the Pre-SETF wastes. None of the calculation 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 activities 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 characterization approach for Pre-SETF wastes. 

(5) The technical basis and derivation of Total 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 determination of the radiological constituents of RH 

TRU waste. These aspects are assumed to be independent, which allows them to be added in 

quadrature. The TMU determination included 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 sources of uncertainty in the 137Cs scaling factors result from: 

variations in the campaign-to-campaign scaling factors; variations in the 137Cs partition factors; 

and variations in the waste content from drum-to-drum. The largest single contributor to the 

overall uncertainty is the scaling factor, 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/cm3

Radionuclide

137Cs 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 assessed and were found to be adequate. 

The determination that the RH containers meet the definition of TRU waste and RH waste were 

examined during the baseline inspection. Both of these aspects are directly involved with the 

DTC measurement at the Transuranic Waste Processing 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 determinations had changed. There were no technical or 

documentation-related concerns regarding the TRU and RH determinations for ORNL Pre-SETF 

wastes. 

Summary of Radiological Characterization Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to radiological 

characterization. There are no open concerns related to radiological characterization resulting 

from this T1 evaluation. 

Tiering Changes

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

assigned to radiological characterization during the baseline approval. 
 27 

5.0 FINDINGS OR CONCERNS 

Summary of Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to AK or radiological 

characterization. There are no open concerns related to AK or radiological characterization 

resulting from this T1 evaluation. 

Tiering Changes

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

that had been assigned to AK or radiological characterization during the baseline approval except 

the updated text for AK T1 changes reflecting the SETF waste approval and this approval since 

the baseline approval decision. 

6.0 CONCLUSIONS 

EPA concluded that the waste characterization processes of AK and radiological characterization 

proposed for use to characterize RH TRU wastes from the Pre-SETF period are adequate, as 

evidenced by the records produced in characterizing 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 wastes at ORNL-CCP. Based on 

the results of this evaluation, EPA approves this T1 change. ORNL-CCP is approved to 

characterize the Pre-SETF RH TRU wastes, consistent with the limitations specified in this 

report. 

Tiering Changes

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

assigned to AK or radiological characterization during the baseline approval except the updated 

text for AK T1 changes reflecting the SETF waste approval and this approval since the baseline 

approval decision. 
A-1 

Appendix A 

List of AK and Radiological Characterization Documents Provided to EPA 

• C601, RH TRU Waste Correlation and Surrogate Summary Form for OR-REDC-RH-HET 

Waste Stream, K. Peters, July 1, 2008 

• DR003, Discrepancy Resolution: Generation Location Discrepancies, Jeff Harrison, June 27, 

2008 

• DR004, Discrepancy Resolution re: Radiological Discrepancies, Jeff Harrison, January 12, 

2009 

• DR009, Discrepancy Resolution for: Waste Incidental to Reprocessing re: REDC CH and 

RH Waste in Building 7920, Jeff Harrison, October 2, 2008 

• M023, Defense Determination for REDC Heterogeneous 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 Transuranic Waste Engineering Study for the 

22-Trench Area at Oak Ridge National Laboratory, Bechtel Jacobs, August 2001 

• U090, Mark 42 Period -HFIR-ORNL RH TRU Data Extracted from Process Information 

Package for Radiological Characterization 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 Characterization 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, 1977 
A-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 Information Input Check, J. Vance, Revision 0, 

June 1, 2009 

• U650, CCP Calculation Package - Uncertainty Analysis 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 Assay Information Input Check, Pre-SETF, J. 

Vance, Revision 0, June 1, 2009 

• U660, CCP Calculation Package - Direct Assay Data Analysis, Pre-SETF, J. Vance, 

Revision 0, June 1, 2009 

• U661, CCP Calculation Package - Residual Cs-137 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 Alternative 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 Radiochemical Engineering Development Center, 

Remote-Handled Transuranic Waste, Waste 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 Radiochemical Engineering Development Center, 

Waste Stream: OR-REDC-RH-HET Revision 3, August 13, 2009 
A-3 

• CCP-AK-ORNL-502, Central Characterization Project RH TRU Waste Certification Plan for 

40 CFR Part 194 Compliance and Confirmation 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 Characterization Project Nondestructive Assay Sampling 

Plan for Oak Ridge National Laboratory Radiochemical Engineering Development Center 

Remote-Handled Transuranic Waste (Pre-SETF), Revision 0, December 31, 2008 

• CCP-AK-ORL-505B, Central Characterization Project Nondestructive Assay Sampling Plan 

for Oak Ridge National Laboratory Radiochemical Engineering Development Center 

Remote-Handled Transuranic Waste (SETF), Revision 0, May 21, 2009 

• CCP-TP-005, Revision 18: Attachment 4, Acceptable Knowledge Source Document 

Reference List for OR-REDC-RH-HET, provided November 13, 2009; Attachment 6, Waste 

Form, Waste Material Parameters, Prohibited 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 Container 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 Energy Carlsbad Field Office, February 5, 2009 

• Historic Data Sheets, CH Drums X10C9311909, X10C9312455, including 2109 forms, 

Data/manifest packaging logs, original CH assay (2004), Request 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 Waste 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 Ridge National Laboratory Radiochemical 

Engineering Development Center, Mixed Heterogeneous Debris Waste (does not include 

SETF waste), April 24, 2008 

• Pre-SETF Feed Inventory Spreadsheet, provided November 13, 2009 

• Remote Handled TRU Waste Characterization Program Implementation Plan, Revision 0d, 

(Subject to Approval), U.S. Department of Energy Carlsbad Field Office, October 30, 2003 
A-4 

• RH CRR Container Data Work Sheets (examples 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), including Characterization Reconciliation Report 

(CRR), June 3, 2009 

• 2109 Forms to Support Traceability for 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 ORRH00023 to Waste Stream OR-REDCRH-HE