DOCKET NO: A-98-49; II-A4-118

WASTE CHARACTERIZATION REPORT

TIER 1 CHANGE: EVALUATION OF VISUAL EXAMINATION TECHNIQUE (VET) FO R REMOTE-HANDLED TRANSURANIC (RH TRU) WASTE AT

IDAHO NATIONAL LABORATORY CENTRAL CHARACTERIZATION PROJECT (INL-CCP)

U.S. Environmental Protection Agency

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

September 20091

1.0 INTRODUCTION

This report approves a Tier 1 (T1) change to the re mote-handled (RH) transuranic (TRU) waste characterization (WC) program implemented by the Ce ntral Characterization Project (CCP) at the Idaho National Laboratory (INL).

In accordance with 40 CFR 194.8(b), in 2006, the U. S. Environmental Protection Agency (EPA) inspected for a baseline approval INL-CCP’s RH TRU WC program. In January 2007, the EPA initially approved this program, which included vis ual examination (VE) of a limited number of RH debris waste containers (see EPA Air Docket No. A -98-49; II-A4-72). Soon after the January 2007 baseline approval of the INL-CCP’s RH program, EPA approved the use of VE for characterizing any additional RH debris waste or ot her TRU Summary Waste Categories (i.e., solids and soils/gravel) from INL as a T1 change.

In July 2009, the Carlsbad Field Office (CBFO) verb ally requested that EPA review a proposed T1 change in the form of adding Visual Examination Technique (VET) to the approved INLCCP RH TRU WC program. On August 11, 2009, EPA per formed a T1 inspection of INLCCP’s implementation of VET for RH TRU wastes onsit e at INL. This report presents the

results of this T1 evaluation. EPA determined that the procedure and processes used at INL-CCP for VET of this waste stream were adequate and no c oncerns were identified. EPA, therefore, approves this T1 change.

2.0 PURPOSE OF TIER CHANGE EVALUATIONS

Certain changes to the WC activities from the date of the site’s baseline inspection must be reported to and, if applicable, approved by EPA acc ording to the tiering requirements set forth in 40 CFR 194.8 regulations and incorporated in the IN L Baseline Final Report cited above.

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

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1) and those req uiring post-implementation (Tier 2 or T2) notification are identified in the site-specific ba seline inspection reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the implementation of the change, or can opt to conduct a “desktop” review of information provided specific to a change. DOE may choose to characteri ze and dispose of, at risk of subsequent EPA disapproval, any previously-approved TRU waste usin g processes/procedures/equipment2

implemented as T2 changes. EPA reviews T2 changes on a quarterly basis. EPA may conduct a continued compliance inspections to evaluate implem ented T2 changes to verify adequacy

3.0 SCOPE OF REVIEW

This T1 change review included the evaluation of in formation supporting the WC technique of VET for RH TRU wastes characterized at INL-CCP, in accordance with procedure CCP-TP-500,
CCP Remote-Handled Waste Visual Examination, Revisi on 8

.

4.0 EVALUATION TEAM

This evaluation of VET was performed by Lindsey Ben der and Dorothy Gill. A complete listing of all individuals who participated in this T1 eval uation is provided in Table 1.

Table 1. Evaluation Team

Inspection Team Member Affiliation

Lindsey Bender EPA Dorothy Gill S. Cohen & Associates, Inc. Tom Clements CWI-RH-TRU Project

Alan Jines DOE-ID
Rhett Bradford CTAC (CBFO Observer) Bruce LaRue DEQ INL Oversight Project

Porf Martinez CTAC Greg Smith WTS/CCP Spencer Pattee WTS/CCP Keith Farmer CWI-RH-TRU Operations Irene Quintana WTS/CCP

5.0 T1 EVALUATION: VET OF RH WASTE

On August 11, 2009, EPA performed a T1 inspection o f VET at INL-CCP. EPA reviewed the VET procedures and processes INL-CCP used for exami nation of RH TRU waste. The CCP VET procedure CCP-TP-500, CCP Remote-Handled Waste Visual Examination, Revisio n 8, was evaluated to ensure that it contained adequate oper ational instructions for the generation of VET data. EPA determined that this procedure was adequ ate for performing VET of RH waste.

During the onsite inspection, EPA observed part of packaging and performance of VET of the contents of a 55-gallon drum, container No. IDAWAML8 8-064, whose contents were to be repackaged into two 30-gallon containers. The two 30-galllon containers were designated as Nos. IDAWAML88-064A and IDAWAML88-064B, and EPA obse rved part of the VET process and subsequent packaging for container No. IDAWAML8 8-064A. These containers were part of debris waste stream ID-MFC-S5400, which consists of four drums. Two Visual Examination Operators (VEOs) and one Visual Examination Expert (VEE) performed the VET event in Hot Cell 308 housed in Building CCP659. INL-CCP person nel manipulated and packaged the waste after VET had been completed for each waste item. One VEO observed the process through a

hot cell window and identified each item before it was placed into the 30-gallon receiving

container. This VEO called out waste identificatio n information and a second VEO repeated the3

identification information to ensure correct transf er of data. The second operator then manually

entered the waste identification information and Wa ste Material Parameter (WMP) of the item on Attachment 1, Visual Examination Data Form , from procedure CCP-TP-500. Cameras in the hot cell enabled the second VEO to visually verify the first VEO’s identification. The receiving container was verified as empty at the start of the examination before waste was placed into it. The second VEO used a paper copy of procedure CCP-T P-500 to guide the process and had a copy of the appropriate Acceptable Knowledge Summar y Report, so that the correct placement

of containers in Waste Stream ID-MFC-S5400 could be verified. A VEE is present at every VET event to provide support and direction to the V EOs, if needed.

EPA verified that the two VEOs and the VEE performi ng the demonstration were listed on the current List of Qualified Individuals (LOQI) and, t herefore, were qualified to perform the examination in accordance with INL-CCP requirements . Additionally, EPA reviewed the training records for the two VEOs in the form of Qu alification Cards and the letter of appointment for the VEE. All training records were determined to be complete.

A completed Batch Data Report (BDR) for this waste stream was not available for review, because it consists of only four containers. The f irst container examined from this BDR was rejected by INL-CCP, and the demonstration drum was the second to undergo VET. However, EPA did review BDR No. RHINLVE090002, which contain ed drums from a different waste stream that had been examined using the same proces ses inspected by EPA during this onsite visit. The BDR had undergone data generation and p roject level review. VET personnel had generated a non-conformance report (NCR) as required , and all data sheets were complete and signed by both VEOs.

6.0 FINDINGS OR CONCERNS

EPA did not identify any findings or concerns assoc iated with this T1 evaluation.

7.0 CONCLUSION

EPA determined that the procedure and processes use d at INL-CCP for VET of this RH TRU waste stream were adequate, effective, and implemen ted appropriately. No findings or concerns were identified, and EPA approves this T1 change.