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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT: 

ADDITION OF CONTACT-HANDLED TRANSURANIC WASTE TO THE 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 2013
ii 

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 Load Management ...........................7

6.1 Subsurface Disposal Area Waste-Generating Activities .........................................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 Waste Treatment Project 

Contact-Handled Waste Characterization Program 

Attachment B: List of Documents Cited by EPA during the T1 Evaluation 
iii 

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 Complex 
iv 

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 form 
1 

1.0 INTRODUCTION 

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

proposed Tier 1 (T1) change to the EPA-approved transuranic (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). This approval allows AMWTP to 

characterize pre-1980 INL-exhumed waste from two exhumations within the Subsurface 

Disposal Area (SDA) at INL: the Initial Drum Retrieval (IDR) and Early Waste Retrieval 

(EWR). This approval is for (a) direct shipment (waste 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 approval 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 inspection 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 nondestructive assay (NDA) and 

nondestructive examination (NDE) systems for use in characterizing CH retrievably stored SCG 

S3000 and SCG S5000 waste and newly generated SCG S5000 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)], Battelle 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. Attachment A provides a table listing EPA’s 

approvals of the AMWTP CH TRU waste characterization program. 

On February 20, 2013, the Carlsbad Field Office (CBFO) 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 cross-reference available historical waste 

generation and disposal records supporting inclusion 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 waste characterization activities: 

• Use of EPA-approved NDA and NDE processes to characterize these wastes. Upon 

generating two to three NDA and NDE batch date reports (BDRs) for these waste 

containers, AMWTP must provide these BDRs at the end of the quarter along with the 

quarterly submission of Tier 2 (T2) changes. EPA has 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 continued 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 during 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-TRUW-91, Revision 0, “Acceptable 

Knowledge Document for Pre-1980 INL-Exhumed SDA Waste” [hereafter referred to as the AK 

document (AKD)]. AMWTP provided a document change request (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 quarterly 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 Waste Stream BN510.1 AK 

summary report (AKSR) RPT-TRUW-83 to the list of example AKSRs and generator-sitespecific AK documents and (2) notification to EPA upon completion of or revision to any item 

description code (IDC) inclusion memoranda. EPA also revised the tiering table to ensure 

completeness and consistency with recent EPA T1 approval 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 effect. The language in Table 1 regarding AK 

documentation applies to all AMWTP waste streams, including load-managed and direct-shipped 

waste streams. 

This approval allows AMWTP to characterize the physical and radiological contents of 

containers for the pre-1980 INL-exhumed SDA SCG S3000 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 NDA 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 determination, based on reviews conducted 

during EPA’s Continued Compliance Inspection of February 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. EPA 
3 

also requires that if SNF or HLW is identified during characterization of the pre-1980 INLexhumed SDA waste, AMWTP will immediately notify EPA 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 website and by sending emails to the WIPPNEWS 

list, in accordance with 40 CFR 194.8(b)(3).
4

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

(Based on March 28–30 and April 11–13, 2006, Baseline Inspection and Subsequent T1 Evaluations, Up

Process Elements AMWTP CH Waste Characterization Processes – T1 Changes AMWTP CH Waste Characterizatio

Acceptable Knowledge, 

including Load Management 

Any new waste category Any waste from sources other than the Mound Site, Rocky Flats 

Environmental Technology Site, Battelle Columbus Laboratories, 

Bettis Atomic Power Laboratory, Argonne National Laboratory-East, the Materials and Fuels Complex, and pre-1980 

INL-exhumed Subsurface Disposal Area waste

Load management of any new or unapproved waste stream 

Notification to EPA upon completion of or 

• Implementation of procedures and relat

NDA-AK communication requirements

• AK accuracy reports (annually, at a min

• All final WSPFs with related attachmen

additions to waste streams within approradiological data for those containers in

• New and revised AKSRs and generator

RPT-TRUW-79, RPT-TRUW-89, RPT

• Item description code inclusion memo

• The load management status of approve

• Site procedures requiring CBFO approv

• Any waste identified outside of the was

Transuranic Waste Baseline Inventory R

• RPT-TRUW-05, RPT-TRUW-07 and R

Nondestructive Assay New equipment or substantive physical modifications to approved 

equipment** Extension of or changes to the approved calibration range for approved equipment 

Notification to EPA upon substantive modi

• Site procedures requiring CBFO approv

• Software for approved equipment 

• Operating ranges upon CBFO approval 

Real-Time Radiography None Notification to EPA upon: 

• Substantive modification** to site proc

• New equipment or substantive physical 

equipment 

Visual Examination and Visual Examination Technique 

Changes in the vendor performing visual examination or visual 

examination technique 

Notification to EPA upon: 

• Substantive modification** to site proc

• Addition of a new waste category • Addition of a new procedure or site equ

WIPP Waste Data System Changes to Waste Data System algorithms specific to load 

management 

Notification to EPA upon substantive modi

• Site procedures requiring CBFO approv

• The load management status of approve

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* 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 documentatio

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editori

address 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 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 and incorporated 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 the July 16, 2004, Federal Register notice 

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

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

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

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

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

destined for disposal at the Waste Isolation Pilot Plant (WIPP). 

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

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

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

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

notification (T2 changes) are identified in the site-specific baseline inspection reports. When 

evaluating proposed T1 changes for approval, EPA may 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 characterize 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 implemented T2 changes to verify their adequacy. 

3.0 PURPOSE OF THIS REPORT 

This report presents the technical basis for and results 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 emplacement at the WIPP has been conveyed to 

DOE separately by letter. EPA will also announce the 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 these 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 88221-3090 
7 

4.0 SCOPE OF THIS TIER 1 EVALUATION 

The scope of this T1 evaluation was the addition of SCG 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 segregate most if not all of the SCG 

S3000 waste to existing RFP waste streams. EPA limited the scope of this review to the AK and 

load management processes to determine whether AMWTP’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 compliance, or NDA and NDE equipment 

because EPA evaluated these elements during its continued compliance evaluation of AMWTP 

on October 30–November 1, 2012, and February 26, 2013 (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 the AMWTP personnel contacted, with their 

affiliations and function. This list includes personnel present at meetings conducted as part of 

this evaluation. 

Table 2. Tier 1 Evaluation Personnel 

6.0 TECHNICAL EVALUATION OF ACCEPTABLE KNOWLEDGE AND LOAD 

MANAGEMENT 

6.1 Subsurface Disposal Area Waste-Generating Activities 

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-characterization shipment to WIPP. This T1 encompasses 

wastes exhumed from the INL SDA before 1980; specifically, drums from two retrieval 

activities: the 1974–1978 INL IDR project and the 1976–1978 INL EWR project. The IDR and 

EWR projects exhumed approximately 18,841 containers, including both 55-gallon and 30-

gallon drums. The exhumed wastes were overpacked into cargo containers, fiberglass boxes, M-

 

1

 In October 2011, Idaho Treatment Group (ITG), a DOE CBFO contractor, took over AMWTP’s TRU 

waste characterization program from the previous contractor. 

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, EPA 

Ed Feltcorn Inspector, EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A 

Patrick Kelly Technical Evaluator – Acceptable Knowledge/Radiological, SC&A 

Tim Venneman Acceptable Knowledge Expert, AMWTP-ITG1

Steve Carpenter Acceptable Knowledge Expert, AMWTP-ITG 

George Byram TRU Programs Manager, AMWTP-ITG 
8 

III bins (Department of Transportation 7A steel bins) or 83- or 85-gallon drums. The containers 

were shipped to the Transuranic Storage Area-Retrieval Enclosure and placed into retrievable 

storage. The majority of containers were exhumed during 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 and 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 possibly Pits 9 and 10. The AKD states that pits 

were predominantly used for the disposal of RFP waste, while trenches were used to dispose of 

INL-generated or non-RFP offsite waste. AMWTP representatives 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 on overall SDA information (References 

C842S, P443A, P647A, P758A, RPT-TRUW-07, Revision 19a, and RPT-TRUW-12, Revision 

20C). 

6.2 Documents Provided 

EPA evaluated the AMWTP documentation that supported 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 following elements related to the use of AK for 

CH waste characterization: 

• Waste identification and description, including radiological and physical characteristics 

and verification that the subject SCG S5000 waste is 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 origin and is not high-level waste (HLW) 

or spent nuclear fuel (SNF). 

• Load management. 

 

2

 AMWTP intends to incorporate the pre-1980 INL-exhumed SDA SCG S5000 waste into supercompacted 

debris Waste Stream BN510.1 [see Item (1)] for shipment to the WIPP facility. 
9 

6.4 Technical Evaluation 

(1) Information regarding the waste-generating processes 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. Information 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 in 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 solid 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 waste, so EPA did not include SCG S4000 in 

this review. 

The AKD, Revision 0, provided conflicting information about the percentage of waste in each 

SCG, but AMWTP representatives prepared a DCR to clarify that 60% of the waste is expected 

to be debris, 30% solids and the remaining 10% soils (References P847S, P1391A, P1392A and 

P1403S). 

The AKD and references (e.g. References P443A, P647A, P758A and P847S) indicate that waste 

in the SDA as a whole is composed primarily of combustible 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, soils and masonry, organic sludge (e.g., RFP 

Organic Setups [74A- and 743-series]) and reactor debris. Also, residues from recovery, sewage 

sludge, solidified and absorbed solutions and sources 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 records 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) ranges. 

Detailed WMP percentages identifying the cellulose, plastic and rubber contents of waste 

containers are necessary to complete characterization. EPA, therefore, expects that future AKSRs 

for each direct shipped pre-1980 INL-exhumed SDA waste stream will include sufficiently 

detailed WMP percentages and distributions. 

The original waste-generating processes are as varied as the sites generating the waste and 

include but are not limited to (References C842S, P443A, 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 Technology and Engineering Center). 
10 

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

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

• Decontamination and decommissioning (e.g., INL, sitewide). 

• Test reactor support (Test Reactor Area, now the INL 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 different processes, but the exhumation 

activities may comingle waste when containers are breached or compromised. Waste evaluation 

is ongoing, and AMWTP expects all debris to be transferred to Waste Stream BN510.1 and 

many of the SCG S3000 waste containers to be transferred to existing RFP S3000 waste streams. 

Consequently, process characteristics of pre-1980 INL-exhumed SDA direct-shipped waste 

cannot be ascertained at this time. EPA expects that future waste streams will be developed in 

accordance with the definition of “waste stream” presented 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 (241Am), plutonium-239 (239Pu), 240Pu and 

241Pu; the most prevalent radionuclides are expected to be 241Pu and 241Am. Because significant 

waste segregation is expected with respect to RFP solids and debris to be supercompacted, these 

estimates may not hold true when or if direct-shipped 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 anticipated radiological composition of 

supercompacted waste fits within the radiological envelope identified in RPT-TRUW-83, 

Revision 3, “Acceptable Knowledge Summary for Supercompacted Debris Waste (BN510.1).” 

AMWTP expects to supercompact all of the pre-1980 INL-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 presented 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 direct-shipped waste. 

(2) The acceptable knowledge reports and related documentation were assessed and found to 

be adequate. 

AMWTP prepares multiple documents that together summarize the available information for 

pre-1980 INL-exhumed SDA CH TRU waste. AMWTP’s AK characterization process, 

 

3

 New Mexico Environment Department, “Waste Isolation Pilot Plant Hazardous Waste Facility Permit,” 

Waste Analysis Plan, Santa Fe, New Mexico, June 29, 2010. 

4

 U.S. DOE CBFO, “Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” 

DOE/WIPP-02-3122, Revision 7.2, Carlsbad, New Mexico, 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 of 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 document. Specifically, EPA identified errors in 

the number of waste containers listed under each SCG, 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 apparently 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 Revision 1 of the AK document that 

addressed these issues. EPA expects a fully approved revision of RPT-TRUW-91 (Revision 1) to 

be included in the next quarterly T2 report (no later than the fiscal year 2013 fourth quarter 

report). 

According to procedure MP-TRUW-8.13, information from 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 process: 

• RPT-TRUW-05, Revision 31, “Waste Matrix Code Reference 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 Stream Designations.” 

These reports plus their supporting source documents 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 components 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 characteristics of all waste that is handled 

by AMWTP, including low-level waste. RPT-TRUW-05 includes information for all the IDCs 

identified in the pre-1980 INL-exhumed SDA AK document. RPT-TRUW-05 is also the primary 

source of information about the prohibited-item content of each IDC, because the AK docuemnt 

(RPT-TRUW-91, Revision 1) does not include this information. RPT-TRUW-05 appropriately 

distinguishes between the EWR and IDR projects’ waste packaging configurations (References 

P652S, P653S, P654S, P655S, P664A and P753A). EPA reviewed RPT-TRUW-05, Revision 31, 

and found that the report does not yet include information about primary WMPs. This lack of 

information corresponds with a similar lack of detail 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 Acceptable Knowledge Documentation,” 

MP-TRUW-8.13, Revision 24, Idaho Falls, Idaho, December 12, 2011. 
12 

SDA CH waste. Notification to EPA upon the availability of a revised RPT-TRUW-05 continues 

to be a T2 change (see Table 1). 

RPT-TRUW-07 presents radiological information for EPA-approved waste sites, i.e. RFP, 

Mound Site, Battelle Columbus Laboratories, Bettis, the Hanford Site, and AMWTP 

supercompacted and newly generated (not supercompacted) wastes. RPT-TRUW-07, Revision 

19a, includes Chapter 10 and Appendix H that address pre-1980 INL-exhumed SDA waste; 

AMWPT also revised parts of other sections and chapters to include pre-1980 INL-exhumed 

SDA waste. The pre-1980 INL-exhumed SDA radiological information presented in RPTTRUW-07 is very general and reflects AMWTP’s determination 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 composition 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-1980 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 remains a T2 change (see Table 1). See Item 

(4) for additional information about payload management. 

RPT-TRUW-12 is limited to descriptions of AMWTP-approved 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 report also indicates that SDA waste can be 

subdivided into additional IDCs beyond those identified 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-bearing waste. RPT-TRUW-12, Revision 20C, 

adequately addresses SCG S5000 and SCG S3000 pre-1980 INL-exhumed SDA waste. 

Notification to EPA upon the availability of a revised RPT-TRUW-12 continues to be a T2 

change (see Table 1). 

Information about all AMWTP-generated waste, including 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 about 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 to both documents were in progress at the 

time of this evaluation. EPA examined earlier versions 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-TRUW-83 remains a T2 change (see 

Table 1). 
13 

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

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

TRU waste to be emplaced in the WIPP must be defense in origin. DOE guidance defines waste 

as defense in origin if it was generated in whole or part by one of the atomic energy defense 

activities listed in section 10101(3) of the Nuclear 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 non-defense waste generators has been 

disposed of at the SDA. This waste when exhumed should not be comingled with defense TRU 

CH debris as direct-shipped or supercompacted containers 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, historical 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 shipped 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 manage it separately from defense TRU CH 

waste destined for WIPP. In such as event, AMWTP will immediately notify EPA and provide 

EPA with information describing management of the identified 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), AMWTP 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 memoranda 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 payload 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 overpack, canister)] for TRU waste material 

that is placed in a reusable Type B shipping container (e.g., TRUPACT-II, TRUPACT-III, 

 

6

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

7

 Public Law 102-579, The Waste Isolation Pilot Plant 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 estimate of the total waste volume and 

percentage of the waste volume that is above and below 100 nCi/g. Each drum selected for 

payload management must also contain at least one TRU isotope whose activity exceeds the 

lower limit of detection of the radioassay system used to characterize the waste, and each drum 

may only be overpacked into a payload container with other containers from the same TRU 

waste stream. 

AMWTP includes WAC payload documentation in RPT-TRUW-07 instead of in individual 

AKSRs. Supercompacted waste is payload managed because the 100-gallon drum in which 

supercompacted silver drums are placed is considered to be the payload container. Pre-1980 

INL-exhumed SDA waste that is direct shipped from AMWTP may also be payload managed so 

long as the appropriate WAC requirements are met. AMWTP updated RPT-TRUW-07 (to 

Revision 19a) to include pre-1980 INL-exhumed SDA waste, 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 EPA upon availability of a revised RPTTRUW-07 incorporating modifications to the quantities of pre-1980 INL-exhumed SDA waste 

remains a T2 change. 

7.0 FINDINGS AND CONCERNS 

The EPA inspection team did not identify any findings or concerns during this T1 evaluation. 

There are no open issues related to this T1 evaluation. 

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 change. Table 1 was modified to 

update the list of approved waste sources to include pre-1980 INL-exhumed SDA waste, to 

explicitly list modifications to RPT-TRUW-06 and RPT-TRUW-83 as examples of T2 changes. 

Notification of any IDC inclusion memoranda associated with changes to RPT-TRUW-83 is a 

new T2 change. EPA also revised the tiering table to ensure completeness and consistency with 

recent EPA T1 approval reports. Table 1 shows the substantive T1 and T2 changes in bold text. 

T1 and T2 changes that were initiated during the baseline approval remain in effect; these are 

listed as applicable in section 6.0. The language in 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 characterize pre-1980 INL-exhumed SDA SCG 

S3000 and SCG S5000 waste. With this approval of the AK aspect of the characterization 

process, AMWTP may characterize physical and radiological 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 different from EPA’s requirement that the NDA and 
15 

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 EPA’s Continued Compliance Inspection of 

February 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. EPA also requires 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 describing 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 and 

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-A4-173 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS CITED BY EPA DURING THE T1 EVALUATION 

C329A, Correspondence from Frank Marcinowski to EM-13 (Stan Wolf, 301-903-7962), 

Process for TRU Waste Defense Determination, February 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, Inc. 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 Subsurface Disposal Area at the Idaho National 

Laboratory, CCP-AK-INL-001, ICP/EXT-06-01203, Revision 2 

P652S, Initial Drum Retrieval Final Report, EG&G Idaho, 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 Idaho, James R. Bishoff and Robert J. 

Hudson, TREE-1321, August 1979 

P655S, Containment of Transuranic Contamination at the Early Waste Retrieval Project, Joseph 

L. Harness and Joseph D. McKinney, TREE-1061, January 1977 

P664A, Early Waste Retrieval Interim Report, EG&G Idaho, D.H. Card, Manager, Retrieval 

Operations, TREE-1047, February 1977 

P753A, Early Waste Retrieval Interim Report, EG&G Idaho, Kirk 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, National 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, 1990 
B-2 

P1389A, A Comprehensive Inventory of Radiological and 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 and 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 and 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 and 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 and 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 Transuranic 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 Material, U.S. Department of Energy, 

DOE O 5820.1, 1982 

P1411S, Overview of an Integrated Comprehensive Environmental Response, Compensation and 

Liability Act Evaluation of the Subsurface Disposal Area at the Idaho National Engineering and 

Environmental Laboratory, K.J. Holdren, August 4, 2002 

P1412S, Radioactive Waste Management Complex Investigation 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, Advanced 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, 2013 
B-3 

RPT-TRUW-12, AMWTP Waste Stream Designations, Advanced Mixed Waste Treatment 

Project, Revision 19, November 13, 2012, Revision 20C, draft provided to EPA May 1, 2013 

RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted 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 provided to EPA May 21, 2013