DOCKET NO: A-98-49; II-A4-174

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT:

ADDITION OF CONTACT-HANDLED TRANSURANIC WASTE TO TH E ADVANCED

MIXED WASTE TREATMENT PROJECT APPROVED PROGRAM:

PRE-1980 INL-EXHUMED SUBSURFACE DISPOSAL AREA

SUMMARY CATEGORY GROUP S3000 AND S5000 WASTE

MAY 2013

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

July 2013ii TABLE OF CONTENTS

Section Page

Abbreviations and Acronyms ........................

................................................... ............................. iii

1.0 Introduction ......................................

................................................... .................................1

2.0 Purpose of Tier 1 Evaluations .....................

................................................... ......................6

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

................................................... .........................6

4.0 Scope of This Tier 1 Evaluation ...................

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

5.0 Tier 1 Evaluation Personnel .......................

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

6.0 Technical Evaluation of Acceptable Knowledge and Lo ad Management ...........................7

6.1 Subsurface Disposal Area Waste-Generating Activitie s .........................................7

6.2 Documents Provided ................................

................................................... .............8

6.3 Waste Characterization Element Description ........ ..................................................8

6.4 Technical Evaluation ..............................

................................................... ..............9

7.0 Findings and Concerns .............................

................................................... .......................14

8.0 Conclusions .......................................

................................................... ..............................14

LIST OF TABLES

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP ........ 4

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

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

ATTACHMENTS

Attachment A: Approval Summary for Advanced Mixed W aste Treatment Project

Contact-Handled Waste Characterization Program Attachment B: List of Documents Cited by EPA during the T1 Evaluationiii ABBREVIATIONS AND ACRONYMS

AK acceptable knowledge

AKD AK document

AKSR AK summary report

Am americium

AMWTP Advanced Mixed Waste Treatment Project

ANLE Argonne National Laboratory-East

BDR batch data report

CBFO Carlsbad Field Office

CFR Code of Federal Regulations

CH contact-handled

CIS characterization information summary

DCR document change request

DOE U.S. Department of Energy

EPA U.S. Environmental Protection Agency

EWR Early Waste Retrieval

HLW high-level waste

IDC item description code

IDR Initial Drum Retrieval

INL Idaho National Laboratory

INEL Idaho National Engineering Laboratory

INEEL Idaho National Engineering and Environmental Laboratory

ITG Idaho Treatment Group, LLC

LWA Land Withdrawal Act, as amended

MFC Materials and Fuels Complexiv

nCi/g nanocuries per gram

NDA nondestructive assay

NDE nondestructive examination

NWPA Nuclear Waste Policy Act of 1982

PCB polychlorinated biphenyl

Pu plutonium

RFP Rocky Flats Plant

RWMC Radioactive Waste Management Complex

SCG summary category group

SDA Subsurface Disposal Area

SNF spent nuclear fuel

T1 Tier 1

T2 Tier 2

TRU transuranic

WAC waste acceptance criteria

WAP waste analysis plan

WIPP Waste Isolation Pilot Plant

WMP waste material parameter

WSPF waste stream profile form1

1.0 INTRODUCTION

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of the proposed Tier 1 (T1) change to the EPA-approved tra nsuranic (TRU) waste characterization program at the U.S. Department of Energy’s (DOE’s) Advanced Mixed Waste Treatment Project (AMWTP) at the Idaho National Laboratory (INL). Thi s approval allows AMWTP to characterize pre-1980 INL-exhumed waste from two ex humations within the Subsurface Disposal Area (SDA) at INL: the Initial Drum Retrie val (IDR) and Early Waste Retrieval (EWR). This approval is for (a) direct shipment (wa ste in uncompacted containers) and supercompaction of containers with contact-handled (CH) debris [Summary Category Group (SCG) S5000] and (b) direct shipment of homogenous solid waste (SCG S3000). Both exhumations also generated soil (SCG S4000) during excavation, but DOE anticipates that this soil will not be TRU waste; therefore, this approva l does not include S4000 waste.

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA conducted Baseline Inspection No. EPA-AMWTP-03.06-8 of the waste characterization program at AMWTP on March 28–30 and April 11–13, 2006. EPA’ s October 2006 baseline approval applied to (a) CH retrievably-stored SCG S3000 and SCG S5000 waste and (b) newly-generated SCG S5000 CH waste. The AMWTP baseline final inspec tion report (see EPA Docket No. A98-49; II-A4-66, dated October 2006) documents EPA’ s approval of the acceptable knowledge (AK) and load management processes and several nond estructive assay (NDA) and nondestructive examination (NDE) systems for use in characterizing CH retrievably stored SCG S3000 and SCG S5000 waste and newly generated SCG S 5000 waste. The baseline report

defined inclusion of wastes from sources other than Mound Site, Rocky Flats Environmental Technology Site [or the Rocky Flats Plant (RFP)], B attelle Columbus Laboratories, and Bettis Atomic Power Laboratory (hereafter referred to as “ Bettis”) as an AK T1 change that required EPA approval before implementation. Wastes from the DOE sites listed above were specifically evaluated as part of the baseline inspection. Attac hment A provides a table listing EPA’s approvals of the AMWTP CH TRU waste characterizatio n program.

On February 20, 2013, the Carlsbad Field Office (CB FO) requested EPA’s approval of the addition of pre-1980 INL-exhumed SDA CH waste from SCGs S3000 and S5000 to the AMWTP baseline approval as a T1 change. EPA limited the scope of this review to the AK and load management processes. The review was necessary to determine whether AMWTP’s AK documentation and records adequately include and cr oss-reference available historical waste generation and disposal records supporting inclusio n of two categories of pre-1980 waste from two pre-1980 waste exhumations from the SDA at INL.

This evaluation did not consider the following wast e characterization activities:

• Use of EPA-approved NDA and NDE processes to charac terize these wastes. Upon generating two to three NDA and NDE batch date repo rts (BDRs) for these waste containers, AMWTP must provide these BDRs at the en d of the quarter along with the quarterly submission of Tier 2 (T2) changes. EPA ha s required submission of NDA and NDE BDRs for those CH TRU wastes that EPA approved as T1 approvals since the baseline approval of October 2006.2

• AK procedural adequacy, AMWTP procedural compliance , or drum or data traceability. EPA evaluated these elements as part of AMWTP’s con tinued compliance evaluation which occurred on October 30–November 1, 2012. (See EPA Docket No. A-98-49; IIA4-173).

EPA did not identify any findings or concerns durin g this review. Based on this evaluation, EPA approves the addition of the specified pre-1980 INL -exhumed SDA SCG S3000 and SCG S5000 CH waste to AMWTP’s EPA-approved program.

EPA’s evaluation required certain changes to RPT-TR UW-91, Revision 0, “Acceptable Knowledge Document for Pre-1980 INL-Exhumed SDA Was te” [hereafter referred to as the AK document (AKD)]. AMWTP provided a document change r equest (DCR) for the revised AKD to

EPA before the conclusion of this T1 evaluation . EPA expects final versions of the following documents to be submitted as part of AMWTP’s next q uarterly submission (no later than the fiscal year 2013 fourth quarter submission) of T2 changes to EPA for review and

concurrence:

• RPT-TRUW-06, Revision 15.

• RPT-TRUW-07, Revision 19.

• RPT-TRUW-12, Revision 20.

• RPT-TRUW-83, Revision 6.

• RPT-TRUW-91, Revision 1.

Based on this evaluation, there is one substantive change to the AK T1 designations: pre-1980

INL-exhumed SDA waste as defined in RPT-TRUW-91 has been added to the list of approved waste sources. There are two substantive changes to the AK T2 designations: (1) addition of AMWTP AK document RPT-TRUW-06 and supercompacted Wa ste Stream BN510.1 AK summary report (AKSR) RPT-TRUW-83 to the list of ex ample AKSRs and generator-sitespecific AK documents and (2) notification to EPA u pon completion of or revision to any item description code (IDC) inclusion memoranda. EPA als o revised the tiering table to ensure completeness and consistency with recent EPA T1 app roval reports. Table 1 shows the substantive T1 and T2 changes in bold text. T1 and T2 changes that were initiated during the baseline and subsequent T1 approvals remain in effe ct. The language in Table 1 regarding AK documentation applies to all AMWTP waste streams, i ncluding load-managed and direct-shipped

waste streams.

This approval allows AMWTP to characterize the phys ical and radiological contents of containers for the pre-1980 INL-exhumed SDA SCG S30 00 and SCG S5000 CH waste using the equipment, processes and procedures EPA approved as part of the baseline approval (see EPA Docket No. A-98-49; II-A4-66, October 3, 2006). As stated above, EPA requires submission of NDA and NDE BDRs for the subject wastes along with the applicable quarterly T2 submissions. This is different from EPA’s requirement that the N DA and NDE BDRs for ANLE and MFC wastes be provided prior to the first shipments of these wastes (see EPA Docket No. A-98-49; IIA4-169, January 29, 2013). This is due to EPA’s det ermination, based on reviews conducted during EPA’s Continued Compliance Inspection of Feb ruary 2013 and review of the ANLE and MFC BDRs received in February 2013, that AMWTP can adequately prepare BN-510 BDRs recording the radiological and physical contents of waste containers managed by the site. EPA3

also requires that if SNF or HLW is identified duri ng characterization of the pre-1980 INLexhumed SDA waste, AMWTP will immediately notify EP A and provide EPA with information describing management of the identified SNF or HLW.

This report serves as EPA’s public notification of the approval of this T1 change. This information will be provided through the EPA websit e and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).4Table 1. Tiering of CH TRU Waste CharacterizationProcesses Implemented by AMWTP(Based on March 28–30 and April 11–13, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated July 2013)Process ElementsAMWTP CH Waste Characterization Processes – T1 ChangesAMWTP CH Waste Characterization Processes – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste categoryAny waste from sources other than the Mound Site, Rocky FlatsEnvironmental Technology Site, Battelle Columbus Laboratories,Bettis Atomic Power Laboratory, Argonne NationalLaboratory-East, the Materials and Fuels Complex,andpre-1980INL-exhumed Subsurface Disposal Area wasteLoad management of any new or unapproved waste streamNotification to EPA upon completion of or substantive modification** to:•Implementation of procedures and related documentation that formalizeNDA-AK communication requirements•AK accuracy reports (annually, at a minimum)•All final WSPFs with related attachments(e.g., CIS), including updates oradditions to waste streams within approved SCGs andsummaries ofradiological data for those containers included onthe CIS drum list•New and revised AKSRs and generator-site-specific AK documents (e.g.,RPT-TRUW-79, RPT-TRUW-89, RPT-TRUW-06, RPT-TRUW-83)•Item description code inclusion memoranda•The load management status of approved waste streams•Site procedures requiring CBFO approval•Any waste identified outside of the waste profilesincluded in the 2002Transuranic Waste Baseline Inventory Report, when applicable•RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12Nondestructive Assay New equipment or substantive physical modifications to approvedequipment**Extension of or changes to the approved calibrationrange forapproved equipmentNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approval•Software for approved equipment•Operating ranges upon CBFO approvalReal-Time Radiography NoneNotification to EPA upon:•Substantive modification** to site procedures requiring CBFO approval•New equipment or substantive physical modifications** to approvedequipmentVisual Examination andVisual ExaminationTechniqueChanges in the vendor performing visual examinationor visualexamination techniqueNotification to EPA upon:•Substantive modification** to site procedures requiring CBFO approval•Addition of a new waste category•Addition of a new procedure or site equipment identifierWIPP Waste Data System Changes to Waste Data Systemalgorithms specific to loadmanagementNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approval•The load management status of approved waste streamsNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* AMWTP will report all T2 changes to EPA every three months.5** “Substantive modification” refers to a change with the potential to affect AMWTP’s CH waste characterization processes or documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.6

2.0 PURPOSE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization activ ities 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 and incorpor ated into the AMWTP CH baseline final report (see EPA Docket No. A-98-49; II-A4-66).

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

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1 changes) and t hose requiring post-implementation notification (T2 changes) are identified in the sit e-specific baseline inspection reports. When evaluating proposed T1 changes for approval, EPA ma y conduct a site inspection to observe implementation of the change or can opt to conduct a desktop review of information provided specific to a change. DOE may choose to characteriz e and dispose of any previously approved TRU waste using processes, procedures or equipment implemented as T2 changes at risk of subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and will conduct continued compliance inspections to evaluate implem ented T2 changes to verify their adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the technical basis for and re sults of EPA’s evaluation of the addition of SCG S3000 and SCG S5000 pre-1980 INL-exhumed SDA CH TRU waste to AMWTP’s baseline approval as a T1 change. EPA’s approval of pre-1980 INL-exhumed SDA SCG S3000 and SCG S5000 waste for characterization for emplac ement at the WIPP has been conveyed to DOE separately by letter. EPA will also announce th e decision on its website at www.epa.gov/radiation/wipp , in accordance with 40 CFR 194.8(b)(3).

DOE documents that EPA reviewed for this evaluation are cited in different sections throughout the report and are listed in Attachment B. Any of t hese documents can be requested from the following address:

Manager, National TRU Program

Carlsbad Field Office U.S. Department of Energy

P O Box 3090 Carlsbad, NM 88221-30907

4.0 SCOPE OF THIS TIER 1 EVALUATION

The scope of this T1 evaluation was the addition ofSCG S3000 and SCG S5000 pre-1980 INLexhumed SDA CH waste to the AMWTP baseline approval as a T1 change. EPA determined the scope of its review in part based on the knowledge that AMWTP expects to supercompact all of the pre-1980 INL-exhumed SDA SCG S5000 waste and se gregate most if not all of the SCG S3000 waste to existing RFP waste streams. EPA limi ted the scope of this review to the AK and load management processes to determine whether AMWT P’s pre-1980 INL-exhumed SDA AKD and records are sufficient to support inclusion of the pre-1980 INL-exhumed SDA SCG S3000 and SCG S5000 waste in the approved program. This review did not address AK, NDA or NDE procedural adequacy, AMWTP procedural complianc e, or NDA and NDE equipment because EPA evaluated these elements during its con tinued compliance evaluation of AMWTP on October 30–November 1, 2012, and February 26, 20 13 (EPA Docket No. A-98-49; II-A4- 173).

5.0 TIER 1 EVALUATION PERSONNEL

EPA and its support personnel conducted interviews with AMWTP personnel by telephone.

Table 2 lists the EPA evaluation team members and t he AMWTP personnel contacted, with their affiliations and function. This list includes perso nnel present at meetings conducted as part of

this evaluation.

Table 2. Tier 1 Evaluation Personnel

6.0 TECHNICAL EVALUATION OF ACCEPTABLE KNOWLEDGE AND LO AD

MANAGEMENT

6.1 Subsurface Disposal Area Waste-Generating Activitie s

The SDA at INL was used from the mid-1950s to 1970 for disposal of waste from various DOE and non-DOE sites. Waste has been and is currently being retrieved from the SDA for subsequent storage and ultimate post-characterizati on shipment to WIPP. This T1 encompasses wastes exhumed from the INL SDA before 1980; specif ically, drums from two retrieval activities: the 1974–1978 INL IDR project and the 1 976–1978 INL EWR project. The IDR and EWR projects exhumed approximately 18,841 container s, including both 55-gallon and 30- gallon drums. The exhumed wastes were overpacked in to cargo containers, fiberglass boxes, M-

1 In October 2011, Idaho Treatment Group (ITG), a DO E CBFO contractor, took over AMWTP’s TRU waste characterization program from the previous co ntractor.

Name Affiliation & Function Rajani Joglekar Lead Inspector, EPA Ed Feltcorn Inspector, EPA Connie Walker Technical Evaluator – Acceptable Know ledge, SC&A Patrick Kelly Technical Evaluator – Acceptable Know ledge/Radiological, SC&A Tim Venneman Acceptable Knowledge Expert, AMWTP-ITG 1
Steve Carpenter Acceptable Knowledge Expert, AMWTP- ITG George Byram TRU Programs Manager, AMWTP-ITG8

III bins (Department of Transportation 7A steel bin s) or 83- or 85-gallon drums. The containers were shipped to the Transuranic Storage Area-Retrie val Enclosure and placed into retrievable storage. The majority of containers were exhumed du ring the IDR project (18,024 containers), 91% of which were intact. Of the approximately 820 containers exhumed during the EWR project, approximately 30% were intact (References C1069A, P652S, P653S, P654S, P655S, P664A, P753A, P1404A, P1411S, P1412S, RPT-TRUW-05 a nd RPT-TRUW-91, Revision 1).

Waste from the IDR project originated from Pits 11 and 12, while EWR-project waste originated from Pits 1 and 2, Trenches 1, 5, 7 and 8, and poss ibly Pits 9 and 10. The AKD states that pits were predominantly used for the disposal of RFP was te, while trenches were used to dispose of INL-generated or non-RFP offsite waste. AMWTP repre sentatives stated that they cannot verify with certainty the generator sites that contributed to the IDR- and EWR-project waste, although RFP is suspected to be the main contributor based o n overall SDA information (References C842S, P443A, P647A, P758A, RPT-TRUW-07, Revision 1 9a, and RPT-TRUW-12, Revision 20C).

6.2 Documents Provided

EPA evaluated the AMWTP documentation that supporte d inclusion of the SCG S3000 and SCG S5000 pre-1980 INL-exhumed SDA CH waste in AMWTP’s approved characterization program.

Attachment B lists all documentation cited in this report.

6.3 Waste Characterization Element Description

EPA limited the scope of the T1 review to the follo wing elements related to the use of AK for

CH waste characterization:

• Waste identification and description, including rad iological and physical characteristics and verification that the subject SCG S5000 waste i s suitable for inclusion in supercompacted Waste Stream BN510.1. 2

• Sufficiency of AK reports, including integration of source documents.

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

• Load management.

2 AMWTP intends to incorporate the pre-1980 INL-exhu med SDA SCG S5000 waste into supercompacted debris Waste Stream BN510.1 [see Item (1)] for ship ment to the WIPP facility.9

6.4 Technical Evaluation

(1) Information regarding the waste-generating processe s and radiological and physical

characteristics was evaluated to determine whether wastes were appropriately identified for future development of direct-ship waste streams and for inclusion of SCG S5000 waste in supercompacted Waste Stream BN510.1. Infor mation evaluated was adequate for this purpose.

The pre-1980 INL-exhumed SDA waste was generated at several sites across the country and shipped to INL for disposal in the SDA, including i n waste trenches and pits. Waste emplaced in Pits 1, 2, 11 and 12 and Trenches 1, 5, 7, 8, 9 and 10 include solid and debris waste. Soil waste was generated primarily through the removal of soli d and debris waste, but AMWTP personnel stated that drums of soil from generator sites are also expected. AMWTP representatives stated that soil (SCG S4000) is not expected to be TRU was te, so EPA did not include SCG S4000 in

this review.

The AKD, Revision 0, provided conflicting informati on about the percentage of waste in each SCG, but AMWTP representatives prepared a DCR to cl arify that 60% of the waste is expected to be debris, 30% solids and the remaining 10% soil s (References P847S, P1391A, P1392A and P1403S).

The AKD and references (e.g. References P443A, P647 A, P758A and P847S) indicate that waste in the SDA as a whole is composed primarily of comb ustible and noncombustible debris, as well as a variety of materials including but not limited to metals, glass, decontamination material, electrical instruments, equipment, glovebox waste, graphite, filters and other debris. Waste may also include solids, such as RFP roaster oxide, soi ls and masonry, organic sludge (e.g., RFP Organic Setups [74A- and 743-series]) and reactor d ebris. Also, residues from recovery, sewage sludge, solidified and absorbed solutions and sourc es are expected (References P647A, P1403S and RPT-TRUW-91, Revision 1). AMWTP representatives stated that, although the AKD did not say so, AMWTP examined real-time radiography re cords for several IDR containers and determined that the physical composition of debris was consistent with the anticipated Waste Stream BN510.1 waste material parameter (WMP) range s.

Detailed WMP percentages identifying the cellulose, plastic and rubber contents of waste containers are necessary to complete characterizati on. EPA, therefore, expects that future AKSRs for each direct shipped pre-1980 INL-exhumed SDA wa ste stream will include sufficiently detailed WMP percentages and distributions.

The original waste-generating processes are as vari ed as the sites generating the waste and include but are not limited to (References C842S, P 443A, P647A, P758A, P847S, P1389A, P1390A, P1391A, P1392A and P1393A):

• Weapons production and support (e.g., RFP).

• Project Pluto (e.g., Coors Porcelain Company).

• Unspecified research (Colorado School of Mines).

• Non-DOE government operations.

• Uranium-233 recovery operations (Idaho Nuclear Tech nology and Engineering Center).10

• Fuel examination and related activities (e.g., Nava l Reactor Facility).

• INL research support (e.g., Test Area North).

• Decontamination and decommissioning (e.g., INL, sit ewide).

• Test reactor support (Test Reactor Area, now the IN L Reactor Technology Complex).

• Lawrence Berkeley Laboratory.

• U.S. Nuclear Regulatory Commission, San Francisco, originating from cleanup activities.

Waste placed in the SDA originated from several dif ferent processes, but the exhumation activities may comingle waste when containers are b reached or compromised. Waste evaluation is ongoing, and AMWTP expects all debris to be tran sferred to Waste Stream BN510.1 and many of the SCG S3000 waste containers to be transf erred to existing RFP S3000 waste streams. Consequently, process characteristics of pre-1980 I NL-exhumed SDA direct-shipped waste cannot be ascertained at this time. EPA expects tha t future waste streams will be developed in accordance with the definition of “waste stream” pr esented in the WIPP waste analysis plan (WAP) 3 and waste acceptance criteria (WAC). 4

AMWTP expects that, because waste from the EWR and IDR projects originated primarily from RFP, 95% of the activity will be from americium-241 ( 241 Am), plutonium-239 ( 239 Pu), 240 Pu and

241 Pu; the most prevalent radionuclides are expected t o be 241 Pu and 241 Am. Because significant waste segregation is expected with respect to RFP s olids and debris to be supercompacted, these estimates may not hold true when or if direct-shipp ed waste streams are identified. EPA expects that the radiological composition of direct-shipped waste streams will be evaluated in more detail when the waste streams are determined. The anticipa ted radiological composition of supercompacted waste fits within the radiological e nvelope identified in RPT-TRUW-83, Revision 3, “Acceptable Knowledge Summary for Super compacted Debris Waste (BN510.1).”

AMWTP expects to supercompact all of the pre-1980 I NL-exhumed SDA SCG S5000 waste and segregate most if not all of the SCG S3000 waste to existing RFP waste streams. If this is not possible, AMWTP may decide to direct ship pre-1980 INL-exhumed SDA SCG S3000 and SCG S5000 waste. EPA determined that AK information pre sented in reviewed documents is adequate to support the development of direct-shipped AKSRs and verified that the debris waste fit within the identified Waste Stream BN510.1 waste envelope. Notification to EPA upon completion of or revision to AKSRs and waste stream profile forms (WSPFs), including those for any directshipped waste streams, continues to be a T2 change (see Table 1). See Item (4) for additional requirements related to payload management of direc t-shipped waste.

(2) The acceptable knowledge reports and related docume ntation were assessed and found to be adequate.

AMWTP prepares multiple documents that together sum marize the available information for pre-1980 INL-exhumed SDA CH TRU waste. AMWTP’s AK c haracterization process,

3 New Mexico Environment Department, “Waste Isolatio n Pilot Plant Hazardous Waste Facility Permit,” Waste Analysis Plan, Santa Fe, New Mexico, June 29, 2010.

4 U.S. DOE CBFO, “Transuranic Waste Acceptance Crite ria for the Waste Isolation Pilot Plant,” DOE/WIPP-02-3122, Revision 7.2, Carlsbad, New Mexic o, June 13, 2011.11

procedure MP-TRUW-8.13, Revision 24, 5 states that the process begins with development of generator-site-specific AK documents. In the case o f this T1 request, AMWTP prepared one AKD: RPT-TRUW-91, Revision 0, “Acceptable Knowledge Document for Pre-1980 INLExhumed SDA Waste.” The AK document is very general and includes data from the entire SDA, not just the area from which the pre-1980 INL- exhumed SDA waste was extracted. EPA

identified several issues associated with the AK do cument. Specifically, EPA identified errors in

the number of waste containers listed under each SC G, the trenches that contributed waste to the EWR project, the justification for waste comingling based on lack of container integrity (i.e., since the majority of containers extracted are appa rently intact), and other typographical and text clarifications related to packaging and management of EWR- and IDR-project wastes. On May 21, 2013, AMWTP provided EPA with a DCR and draft R evision 1 of the AK document that addressed these issues. EPA expects a fully approve d revision of RPT-TRUW-91 (Revision 1) to be included in the next quarterly T2 report (no lat er than the fiscal year 2013 fourth quarter report).

According to procedure MP-TRUW-8.13, information fr om the generator-site-specific AK document is then used to update other AMWTP summary reports. AMWTP provided the following reports to EPA as evidence of this proces s:

• RPT-TRUW-05, Revision 31, “Waste Matrix Code Refere nce Manual.”

• RPT-TRUW-07, draft Revision 19a, “Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge.”

• RPT-TRUW-12, draft Revision 20C, “AMWTP Waste Strea m Designations.”

These reports plus their supporting source document s contain the information required by the

WIPP WAC and WIPP WAP. AMWTP revised each document in whole or in part to address the pre-1980 INL-exhumed SDA waste, as discussed below. The waste stream definition and documentation of physical and radiological componen ts are discussed further in Item (1) above. The defense origin of the waste and the absence of SNF and HLW are discussed further in Item (3) below.

The waste matrix code reference manual, RPT-TRUW-05 , contains detailed information, listed by generator site IDC and WMC, about the physical c haracteristics of all waste that is handled by AMWTP, including low-level waste. RPT-TRUW-05 in cludes information for all the IDCs identified in the pre-1980 INL-exhumed SDA AK docum ent. RPT-TRUW-05 is also the primary source of information about the prohibited-item con tent of each IDC, because the AK docuemnt (RPT-TRUW-91, Revision 1) does not include this inf ormation. RPT-TRUW-05 appropriately distinguishes between the EWR and IDR projects’ was te packaging configurations (References P652S, P653S, P654S, P655S, P664A and P753A). EPA r eviewed RPT-TRUW-05, Revision 31, and found that the report does not yet include info rmation about primary WMPs. This lack of information corresponds with a similar lack of deta il in the AK document. RPT-TRUW-05 must be updated to present the physical characteristics of each IDC in the pre-1980 INL-exhumed

5 AMWTP, “Collection, Review, and Management of Acce ptable Knowledge Documentation,” MP-TRUW-8.13, Revision 24, Idaho Falls, Idaho, Dece mber 12, 2011.12

SDA CH waste. Notification to EPA upon the availabi lity of a revised RPT-TRUW-05 continues to be a T2 change (see Table 1).

RPT-TRUW-07 presents radiological information for E PA-approved waste sites, i.e. RFP, Mound Site, Battelle Columbus Laboratories, Bettis, the Hanford Site, and AMWTP supercompacted and newly generated (not supercompac ted) wastes. RPT-TRUW-07, Revision 19a, includes Chapter 10 and Appendix H that addres s pre-1980 INL-exhumed SDA waste; AMWPT also revised parts of other sections and chap ters to include pre-1980 INL-exhumed SDA waste. The pre-1980 INL-exhumed SDA radiologica l information presented in RPTTRUW-07 is very general and reflects AMWTP’s determ ination that the pre-1980 INL-exhumed SDA waste will be composed primarily of RFP waste. EPA pointed out that the report included typographical errors in the anticipated quantities of pre-1980 INL-exhumed SDA waste for each SCG. AMWTP did not provide a draft revision of RPT- TRUW-07 or a DCR to rectify SCG errors or clarify the anticipated radiological comp osition of the pre-1980 INL-exhumed SDA

waste as a whole. EPA assumes that RPT-TRUW-07 will be further refined to better reflect the radiological and physical composition of the pre-19 80 INL-exhumed SDA waste, particularly if pre-1980 INL-exhumed SDA wastes are singled out for direct shipment. Notification to EPA upon the availability of a revised RPT-TRUW-07 rema ins a T2 change (see Table 1). See Item (4) for additional information about payload manage ment.

RPT-TRUW-12 is limited to descriptions of AMWTP-app roved waste streams that originated at EPA-approved waste sites but are shipped to WIPP as AMWTP waste streams. RPT-TRUW-12 is typically used to identify the waste’s hazardous constituents by IDC. AMWTP updated RPT-TRUW-12 (to draft Revision 20C) to include the chemical composition of pre-1980 INLexhumed SDA waste as a whole for each SCG. The repo rt also indicates that SDA waste can be subdivided into additional IDCs beyond those identi fied in the AK document (i.e., SDA wastes that are presumably not pre-1980 in origin are IDCs SD-704, -705 and -706). AMWTP representatives indicated that additional IDCs may be assigned to address, for example, polychlorinated biphenyl (PCB) versus non-PCB-beari ng waste. RPT-TRUW-12, Revision 20C, adequately addresses SCG S5000 and SCG S3000 pre-19 80 INL-exhumed SDA waste. Notification to EPA upon the availability of a revi sed RPT-TRUW-12 continues to be a T2 change (see Table 1).

Information about all AMWTP-generated waste, includ ing supercompacted Waste Stream BN510.1, is presented in RPT-TRUW-06 (the AMWTP AK document). RPT-TRUW-83 (the Waste Stream BN510.1 AKSR) includes information abo ut all feed material to the supercompacted waste stream. AMWTP did not provide updated versions of either RPT-TRUW06 or RPT-TRUW-83 to EPA for review because edits t o both documents were in progress at the

time of this evaluation. EPA examined earlier versi ons of both documents (RPT-TRUW-06, Revision 14, and RPT-TRUW-83, Revision 3) to ensure that the proposed T1 pre-1980 INLexhumed SDA waste fit within the Waste Stream BN510 .1 envelope. Notification to EPA upon the availability of revised RPT-TRUW-06 and RPT-TRU W-83 remains a T2 change (see Table 1).13

(3) The generator-site-specific acceptable knowledge do cument was examined and indicates

that data are available to determine that the waste s are defense in origin and are not highlevel waste or spent nuclear fuel.

TRU waste to be emplaced in the WIPP must be defens e in origin. DOE guidance defines waste as defense in origin if it was generated in whole o r part by one of the atomic energy defense activities listed in section 10101(3) of the Nuclea r Waste Policy Act of 1982 (NWPA). 6 The WIPP Land Withdrawal Act (LWA), as amended, 7 prohibits the disposal of SNF and HLW as defined by the NWPA at the WIPP.

The AK document indicates that waste from several n on-defense waste generators has been disposed of at the SDA. This waste when exhumed sho uld not be comingled with defense TRU CH debris as direct-shipped or supercompacted conta iners for disposal at the WIPP. EPA expects AMWTP to ensure that only defense debris waste will be included in direct-shipped waste streams in accordance with DOE guidance (Reference C329A). When this occurs the disposition of segregated non-defense waste should be properly recorded in the AK as IDC memoranda.

Similarly, while HLW and SNF are not expected, hist orical AK documentation does indicate that fuel may have been disposed of in the SDA pits and trenches. For example, Reference C842S states that Experimental Breeder Reactor-1 Mark III Fuel may be in Idaho Chemical Processing Plant waste in SDA Pit 12. However, the AK document indicates that SNF was not included in the IDR- or EWR-project wastes that had been shippe d to AMWTP for packaging as a WIPP compliant waste. If AMWTP does identify SNF or HLW during future waste management operations of pre-1980 INL-exhumed SDA waste, AMWTP will segregate and handle the SNF or HLW waste on a case-by-case basis and must manag e it separately from defense TRU CH waste destined for WIPP. In such as event, AMWTP wi ll immediately notify EPA and provide EPA with information describing management of the i dentified SNF or HLW.

As a result of an EPA concern identified during the 2012–2013 AMWTP continued compliance inspection (EPA Docket No. A-98-49; II-A4-173), AMW TP will prepare IDC inclusion memoranda documenting the evaluations performed on each new IDC to be included in Waste

Stream BN510.1. These memoranda will document that the IDCs meet the requirements of the LWA restrictions with respect to non-defense waste, SNF and HLW. Notification to EPA upon completion of or revision to IDC inclusion memorand a is a new T2 change (see Table 1).

(4) Load management was found to be acceptable.

The WIPP WAC allows payload management in which a p ayload container may include drums that measure less than 100 nanocuries per gram (nCi /g) so long as the payload in total is greater than 100 nCi/g. The WAC defines a payload container as “the outermost container [(e.g., drum, Standard Large Box 2, standard waste box, 10-drum o verpack, canister)] for TRU waste material that is placed in a reusable Type B shipping contai ner (e.g., TRUPACT-II, TRUPACT-III,

6 U.S. Code, Title 42, “The Public Health and Welfar e,” Chapter 108, “Nuclear Waste Policy Act of 1982. ”

7 Public Law 102-579, The Waste Isolation Pilot Plan t Land Withdrawal Act, October 30, 1992, as amended by Public Law 104-201, September 23, 1996.14

HalfPACT, RH-TRU 72-B, or 10-160B) for transport.” The AKSR for each waste stream selected for payload management must include an est imate of the total waste volume and percentage of the waste volume that is above and be low 100 nCi/g. Each drum selected for payload management must also contain at least one T RU isotope whose activity exceeds the lower limit of detection of the radioassay system u sed to characterize the waste, and each drum may only be overpacked into a payload container wit h other containers from the same TRU

waste stream.

AMWTP includes WAC payload documentation in RPT-TRU W-07 instead of in individual AKSRs. Supercompacted waste is payload managed beca use the 100-gallon drum in which supercompacted silver drums are placed is considere d to be the payload container. Pre-1980 INL-exhumed SDA waste that is direct shipped from A MWTP may also be payload managed so long as the appropriate WAC requirements are met. A MWTP updated RPT-TRUW-07 (to Revision 19a) to include pre-1980 INL-exhumed SDA w aste, but AMWTP needs to make additional changes to the estimated quantities for each SCG to incorporate the changes presented in RPT-TRUW-91, draft Revision 1. Notification to E PA upon availability of a revised RPTTRUW-07 incorporating modifications to the quantiti es of pre-1980 INL-exhumed SDA waste remains a T2 change.

7.0 FINDINGS AND CONCERNS

The EPA inspection team did not identify any findin gs or concerns during this T1 evaluation. There are no open issues related to this T1 evaluat ion.

8.0 CONCLUSIONS

Changes to Tiering

Notification to EPA upon revision to AMWTP reports RPT-TRUW-05, RPT-TRUW-06, RPTTRUW-07, RPT-TRUW-12 and RPT-TRUW-83 remains a T2 c hange. Table 1 was modified to update the list of approved waste sources to includ e pre-1980 INL-exhumed SDA waste, to explicitly list modifications to RPT-TRUW-06 and RP T-TRUW-83 as examples of T2 changes. Notification of any IDC inclusion memoranda associa ted with changes to RPT-TRUW-83 is a new T2 change. EPA also revised the tiering table t o ensure completeness and consistency with recent EPA T1 approval reports. Table 1 shows the s ubstantive T1 and T2 changes in bold text. T1 and T2 changes that were initiated during the ba seline approval remain in effect; these are listed as applicable in section 6.0. The language i n Table 1 regarding AK documentation applies to all AMWTP waste streams, including load-managed and direct-shipped waste streams.

Approval

This T1 change consisted of the use of AK to charac terize pre-1980 INL-exhumed SDA SCG S3000 and SCG S5000 waste. With this approval of th e AK aspect of the characterization process, AMWTP may characterize physical and radiol ogical contents of these two waste types using the equipment, processes and procedures that EPA approved during the October 2006 baseline approval (see EPA Docket No A-98-49: II-A4 -66, October 3, 2006). As stated above, EPA requires submission of NDA and NDE BDRs for the subject wastes along with the applicable quarterly T2 submissions. This is differ ent from EPA’s requirement that the NDA and15

NDE BDRs for ANLE and MFC wastes be provided prior to the first shipments of these wastes (see EPA Docket No. A-98-49; II-A4-169, January 29, 2013). This is due to EPA’s determination, based on reviews conducted during EP A’s Continued Compliance Inspection of February 2013 and review of the ANLE and MFC BDRs r eceived in February 2013, that AMWTP can adequately prepare BN-510 BDRs recording the radiological and physical contents of waste containers managed by the site. EPA also r equires that if SNF or HLW is identified during characterization of the pre-1980 INL-exhumed SDA waste, AMWTP will immediately notify EPA and provide EPA with information describ ing management of the identified SNF or

HLW.A-1 ATTACHMENT A

APPROVAL SUMMARY FOR ADVANCED MIXED WASTE TREATMENT PROJECT

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, Approval Dates EPA Docket Number

AMWTP CH Baseline Approval EPA-AMWTP-03.06-8
October 2006 A-98-49; II-A4-66

T1 Change – Addition of Four Hanford Legacy Debris Waste Streams to the BN510 Super-Compacted Debris

Waste Stream June 2010 A-98-49; II-A4-127

Unannounced Continued Compliance Inspection March 2011 A-98-49; II-A4-143

T1 Change – Addition of ANLE-generated SCG S3000 an d S5000 CH Waste and MFC-generated SCG S5000 CH

Waste January 2013 A-98-49; II-A4-169

Continued Compliance Inspection April 2013 A-98-49; II-A4-173B-1 ATTACHMENT B

LIST OF DOCUMENTS CITED BY EPA DURING THE T1 EVALUA TION

C329A, Correspondence from Frank Marcinowski to EM- 13 (Stan Wolf, 301-903-7962), Process for TRU Waste Defense Determination, Februa ry 2005

C842S, Email correspondence, between Tim Venneman (AMWTP) and Kirk Green (ICP), Pits 11 and 12 disposals, October 20, 2009

C1069A, Estimated Waste Stream Volumes for Pre-1980 INL-Exhumed SDA wastes, TV-TV002-12

P443A, Historical Background Report for Rocky Flats Plant Waste Shipped to the INEEL and Buried in the SDA from 1954 to 1971, North Wind, In c. TRU Program Technical Services, ICP/EXT-04-00248, Revision 1, March 2005

P647A, Central Characterization Project Acceptable Knowledge Summary Report for Waste Retrieved from Designated Areas within the Subsurfa ce Disposal Area at the Idaho National Laboratory, CCP-AK-INL-001, ICP/EXT-06-01203, Revis ion 2

P652S, Initial Drum Retrieval Final Report, EG&G Id aho, Kirk B. McKinley and Joseph D. McKinney, TREE-1286, August 1978

P653S, Initial Drum Retrieval Interim Report, EG&G Idaho, D.H. Card and D.K. Wang, TREE1079, May 1977

P654S, Early Waste Retrieval Final Report, EG&G Ida ho, James R. Bishoff and Robert J. Hudson, TREE-1321, August 1979

P655S, Containment of Transuranic Contamination at the Ear ly Waste Retrieval Project, Joseph L. Harness and Joseph D. McKinney, TREE-1061, Janua ry 1977

P664A, Early Waste Retrieval Interim Report, EG&G I daho, D.H. Card, Manager, Retrieval Operations, TREE-1047, February 1977

P753A, Early Waste Retrieval Interim Report, EG&G Idaho, K irk B. McKinley and Joseph D. McKinney, TREE-1265, May 1978

P758A, Solid Radioactive Waste Retrieval Test, R.J. Thompson, Allied Chemical Corporation, Idaho Chemical Programs, Operations Office, Nationa l Reactor Testing Station, ACI-120, May 1972

P847S, Subsurface Disposal Area (SDA) Waste Identification (1952–1970 Emphasis), M.J. Vigil, INEL Environmental Restoration Program, EGG-WM-8727, Revision 2, January 24, 1990B-2

P1389A, A Comprehensive Inventory of Radiological a nd Nonradiological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952– 1983, Volume 1, INEL-95/0310 (Formerly EGG-WM-10903 ), Revision 1, August 1995

P1390A, A Comprehensive Inventory of Radiological a nd Nonradiological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952– 1983, Volume 2, INEL-95/0310 (Formerly EGG-WM-10903 ), Revision 1, August 1995

P1391A, A Comprehensive Inventory of Radiological a nd Nonradiological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952– 1983, Volume 3, INEL-95/0310 (Formerly EGG-WM-10903 ), Revision 1, August 1995

P1392A, A Comprehensive Inventory of Radiological a nd Nonradiological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952– 1983, Volume 4, INEL-95/0310 (Formerly EGG-WM-10903 ), Revision 1, August 1995

P1393A, A Comprehensive Inventory of Radiological a nd Nonradiological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952– 1983, Volume 5, INEL-95/0310 (Formerly EGG-WM-10903 ), Revision 1, August 1995

P1403S, A Brief Analysis and Description of Transur anic Wastes in the Subsurface Disposal Area of the Radioactive Waste Management Complex at INEL, D.A. Arrenholz and J.L. Knight, EGG-WTD-9438, Revision 1, November 22, 1991

P1404A, Management of Transuranic Contaminated Mate rial, U.S. Department of Energy, DOE O 5820.1, 1982

P1411S, Overview of an Integrated Comprehensive Env ironmental Response, Compensation and Liability Act Evaluation of the Subsurface Disposal Area at the Idaho National Engineering and Environmental Laboratory, K.J. Holdren, August 4, 2 002

P1412S, Radioactive Waste Management Complex Invest igation Report, Volumes 1 through 4, M.L. Paarmann, EGG-WM-9707, December 1991

Document Change Request for RPT-TRUW-91, Revision 0 , Advanced Mixed Waste Treatment Project, DCR-12333, provided to EPA May 21, 2013

RPT-TRUW-05, Waste Matrix Code Reference Manual, Ad vanced Mixed Waste Treatment Project, Revision 31, January 31, 2013

RPT-TRUW-06, Acceptable Knowledge Baseline Document for AMWTP Waste, Revision 14, July 5, 2012

RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge, Advanced Mixed Waste Treatment Project, Revision 18, March 19, 2013, Revision 19a, draft provided to EPA May 1, 2013B-3

RPT-TRUW-12, AMWTP Waste Stream Designations, Advan ced Mixed Waste Treatment Project, Revision 19, November 13, 2012, Revision 2 0C, draft provided to EPA May 1, 2013

RPT-TRUW-83, Acceptable Knowledge Summary for Super compacted Debris Waste (BN510.1), Advanced Mixed Waste Treatment Project, Revision 3, September 17, 2012

RPT-TRUW-91, Acceptable Knowledge Document for Pre- 1980 INL-Exhumed SDA Waste, Revision 0, February 14, 2013, Revision 1, draft pr ovided to EPA May 21, 2013