DOCKET NO: A-98-49; II-A4-67

WASTE CHARACTERIZATION REPORT

EPA DESKTOP REVIEW OF A TIER ONE CHANGE:

EVALUATION OF ACCEPTABLE KNOWLEDGE FOR PIT 4 & PIT 6 (ARP-I & ARP-II) WASTES AT THE IDAHO NATIONAL LABO RATORY CENTRAL CHARACTERIZATION PROJECT (INL-CCP)

May 15, 2006

U.S. Environmental Protection Agency

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

August 2006**i** TABLE OF CONTENTS

**Section Page** 

**1.0 Executive Summary ..............................**

**................................................... ........................... 1** 

**2.0 Purpose of Tier 1 Change Evaluations...........**

**................................................... .................. 2** 

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

**................................................... ............................ 2** 

**4.0 Scope of Review................................**

**................................................... ............................... 3** 

**5.0 Desktop Evaluation Team ........................**

**................................................... ........................ 4** 

**6.0 Performance of the Review: Acceptable Knowledg e and Load Management of Pit 4 and** 

**Pit 6 ..............................................**

**................................................... .................................... 4** 

**7.0 Summary of Results .............................**

**................................................... .......................... 21** 

**7.1 Conclusions ....................................**

**................................................... .................... 21** **1**

1.0 EXECUTIVE SUMMARY

**In accordance with 40 CFR 194.8(b), the U.S. Enviro nmental Protection Agency (EPA or the**  **Agency) conducted Baseline Inspection No. EPA-INL-C CP-05.05-8 of the Central**  **Characterization Project (CCP), located at the Idah o National Laboratory (INL)**  **1 from May 3-5,**  **2005. The scope of this baseline inspection includ ed several aspects of the site’s program to**  **characterize wastes proposed for disposal in the Wa ste Isolation Pilot Plant (WIPP). As a result**  **of Baseline Inspection No. EPA-INL-CCP-05.05-8, EPA approved the INL-CCP waste**  **characterization (WC) program based on a demonstrat ion of the site’s capabilities, with** 

**conditions and limitations as documented in the INL Baseline Final Inspection Report (see EPA**  **Docket No: A-98-49; II-A4-59, March 2005). With re spect to Acceptable Knowledge (AK) and**  **Load Management, this approval encompassed retrieva bly-stored debris and solid waste**  **provided to CCP from the Advanced Mixed Waste Treat ment Project (AMWTP), a separate**  **operation co-located at INL, for characterization b y INL-CCP. The November 2005 approval of**  **the CCP program at INL required that AK compilation process of waste outside of the summary**  **category groups approved during the baseline will b e subject to EPA evaluation and review**  **through a Tier 1 (T1) change. INL-CCP subsequently requested a T1 change for newly**  **generated solid, debris, and soil waste from Area 1 of Pit 4 at Radioactive Waste Management**  **Complex (RWMC) located onsite at INL, referred to m ore specifically as the Accelerated**  **Retrieval Process Area I, or ARP-I. 2**  **Since the baseline inspection and approval in 200 5, INL**  **CCP elected to expand the excavated area to include Accelerated Retrieval Process Area II**  **(ARP-II), which is an approximately 1⁄2-acre area enc ompassing the eastern end of Pit 4 and**  **western portion of Pit 6, which was used for waste disposal through 1968. The waste in ARP-I**  **and ARP-II came from the Rocky Flats Environmental Technology Site. The specific areas**  **addressed in this approval are shown in Figure 1 in Section 4 of this report. EPA has evaluated**  **AK documentation for the shaded area shown in Figur e 1.** 

**This report serves as EPA’s evaluation of AK data f or debris (S5000), solid (S3000) and**  **soils/gravel (S4000) from Pits 4 and 6 as a T1 chan ge. Using the information provided in this**  **report, EPA has determined that AK information prov ided for CH TRU debris, solids, and**  **soils/gravel from Pits 4 and 6 is adequate.**

**In the future, EPA must review and approve AK docum entation for the waste excavated from the**  **non-shaded area of the remainder pf Pit 4 and Pit 6 shown in Figure 1 in Section 4 of this report**  **before the waste can be disposed of at WIPP. EPA b elieves that the AK documentation**  **compiled for non-shaded areas of Pit 4 and Pit 6 ar eas would be different than that reviewed for**  **this report. The reason being that the majority of waste in the non-shaded areas of Pit 4 and Pit 6**  **came from the Idaho National Engineering and Enviro nmental Laboratory and the Argonne**  **national Laboratory – West with a minor contributio n from other DOE facilities.** 

**1 The INL was previously called the Idaho National E**  **ngineering Laboratory (INEL) and the Idaho National Engineering and Environmental Laboratory (INEEL).**  **The use of one name versus another is not necessari ly**  **significant and this report uses all three names de pending on the context.** 

**2 The specific areas to which this approval pertains**  **are shown in the shaded portion of Figure 1 in Sec tion 4 of**  **this report. They are referred to as Pit 4 and Pit 6 in this report for the sake of convenience. The**  **AK documentation evaluated for approval apply only to specific secti**  **ons within Pit 4 and Pit 6 that are referred to as ARP I and ARP II,**  **respectively, as described in the text. 2** 

**Since it was determined that INL-CCP does not inten d to implement the practice of Load**  **Management for Pit 4 and Pit 6 at this time, Load M anagement is not included in this approval.**  **If load management for the waste from the Idaho Cle anup Project (ICP) were to occur, INL CCP**  **must comply with the requirements for load manageme nt given in the Appendix E of DOE’s**  **Waste Acceptance Criteria (WAC) for CH TRU waste.**

**This report, in conjunction with the INL Baseline F inal Inspection Report (see EPA Docket No:**  **A-98-49; II-A4-59, November 2005) completes EPA’s in itial evaluation of INL-CCP for CH** 

**TRU wastes.**

2.0 PURPOSE OF TIER 1 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 ac cording to the tiering requirements set forth in**  **the INL 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 the baseline inspection is**  **to approve the site’s WC program based on the demon stration that the program’s components,**  **with applicable conditions and limitations, can ade quately characterize TRU wastes and comply**  **with the regulatory requirements imposed on TRU was tes destined for disposal at the WIPP. An**  **EPA inspection team conducts an onsite inspection t o verify that the site’s system of controls is**  **technically adequate and properly implemented.**

**Following the EPA’s approval of WC processes evalua ted during the baseline inspection, EPA is**  **authorized to evaluate and approve, if necessary, c hanges to the site’s approved WC program by**  **conducting additional inspections under the authori ty of 40 CFR 194.24(h). Under**  **40 CFR 194.24, EPA has the authority to conduct con tinued compliance inspections to verify**  **that the site continues to use only the approved WC processes to characterize the waste, and**  **remains in compliance with all the regulatory requi rements. Based on the adequacies of the WC**  **processes demonstrated during the baseline inspecti on, including all conditions and limitations,**  **EPA specified which subsequent WC program changes o r modifications must undergo further**  **EPA inspection or approval under 40 CFR 194.24. Th is was accomplished by assigning a tier**  **level to each aspect of the CCP’s characterization program. T1 activities have more stringent**  **requirements, namely, DOE notifies EPA when a chang e is contemplated. DOE must then**  **provide EPA relevant documents for review, and may not implement that T1 change prior to**  **EPA approval or dispose of waste characterized usin g T1 designated methods not yet approved**  **by EPA.**

3.0 PURPOSE OF THIS REPORT

**This report presents the results of the EPA’s deskt op inspection of a T1 change to the initial**  **baseline approval of INL-CCP. Specifically, this a ddresses the technical area of AK and Load**  **Management for wastes from ARP-I and ARP-II areas o f the eastern end of Pit 4 and the western** **3**

**end of Pit 6. The Baseline Final Inspection Report (see EPA Docket No: A-98-49; II-A4-59)**  **describes the conditions that EPA has approved and it documents the basis for EPA’s approval**  **decision of AK and Load Management related to these wastes.** 

4.0 SCOPE OF REVIEW

**The scope of this desktop review included the evalu ation of information supporting the technical** 

**areas of AK for wastes from Pit 4 and Pit 6 at INL. The shaded portions marked as ARP I and**  **ARP II in Figure 1 show the specific areas of Pits 4 and 6 to which this approval applies to. For**  **convenience, these areas are referred to as Pit 4 a nd Pit 6, respectively in this report. AK for**  **wastes from non-shaded areas encompassing the remai nder of Pit 4 and Pit 6 will be subject to**  **separate review and approval.**

Figure 1. Map of the Solid Waste Disposal Area at INL’s RWMC Showing the Pit 4 (APR-1) and Pit 6 (ARP-II) Retrie val Areas**4**

5.0 DESKTOP EVALUATION TEAM

**This desktop review of the AK and Load Management a spects of INL-CCP’s WC program was**  **performed by Connie Walker with assistance from Pat rick Kelly. A complete listing of all**  **individuals who participated in the original EPA Ba seline Inspection in May 2005 is provided in**  **the INL Baseline Final Inspection Report issued in November 2005.** 

6.0 PERFORMANCE OF THE REVIEW: ACCEPTABLE KNOWLEDG E AND

LOAD MANAGEMENT OF PIT 4 AND PIT 6

Background Information

**Area 1 of Pit 4 (ARP-I) at the RWMC was used for th e disposal of TRU wastes from January**  **1963 until September 1967. Approximately 81% (110, 000 ft**  **3 of the 136,000 ft**  **3 total) of the**  **wastes buried in this 1⁄2-acre area of Pit 4 originat ed at DOE’s Rocky Flats Environmental**  **Technology Site (RFETS). The remainder of the wast es in this area originated at INEEL**  **facilities and Argonne National Laboratory-West (AN L-W), with minor amounts attributed to**  **several facilities that were transshipped from RFET S. The objective of the ARP is to perform a**  **targeted retrieval of those wastes from RFETS that contain higher concentrations of TRU**  **radionuclides, depleted uranium (roaster oxide), an d Volatile Organic Compounds (VOCs). The**  **targeted wastes consist of:**

• **RFETS 741 Series sludge**

• **RFETS 743 Series sludge**

• **RFETS filters, RFETS roaster oxide**

• **RFETS graphite**

**Although all target wastes are from RFETS, CCP expe cted that many of the waste containers**  **would be breached and that their contents might the refore be commingled with wastes from other**  **areas. Excavation in Pit 4 (referred to as “Area G” in some references) was initiated in 2004 but**  **ceased in November of 2005 due to a safety-related c ontainer incident, and operations have yet**  **to be reinitiated. All excavation and retrieval op erations occur within enclosures for purposes of** 

**contamination control. If it is determined that co ntainers being excavated contain targeted**  **material, the container’s contents are removed, pla ced on a tray, and moved to another area**  **where Visual Examination (VE) is performed and the wastes are repackaged. Prohibited items** 

**are removed and all wastes that are confirmed to be targeted are placed in 55-gallon drums for**  **subsequent characterization. The data EPA evaluate d suggested that some drums were stacked**  **in the pit while others were dumped, and initial ob servations indicated that most waste containers**  **initially removed were in fact intact with regard t o structural integrity.** 

**As part of the inspection, EPA reviewed the element s of the AK process listed below:** 

• **Overall procedural technical sufficiency and scope and ability to follow the AK WC**  **process for containers and waste streams**

• **Waste-generating procedures, processes, and documen tation** **5**

• **Characterization of required waste material paramet ers (WMPs) and radionuclides** 

• **AK information assembly and compilation**

• **AK confirmation and associated discrepancy resoluti on** 

• **Sufficiency of AK characterization results**

• **Assembly of required information and use of supplem ental information** 

• **AK summary preparation**

• **Reassignment of waste stream due to AK and discrepa ncy analysis** 

• **AK accuracy**

• **Load Management**

• **AK-nondestructive assay (NDA) communication and use of AK by NDA** 

**AK is used to determine several aspects of TRU wast es at INL-CCP, including, but not limited**  **to, the following:**

• **Defense waste status**

• **Waste material parameters (WMPs)**

• **Waste stream**

• **Radionuclide information**

• **Waste matrix codes (WMCs)**

**EPA inspectors examined procedures and documents, i ncluding the following:** 

• **Program Tracking System/Container Tracking System ( PTS/CTS) printout, Pit 4 soils**  **(May 6, 2005)**

• **Interoffice Correspondence from I. Quintana to CCP Records, re: Waste Material**  **Parameter Weight Comparison Report for Idaho Nationa l Laboratory Pit 4, 2005**  **(Relative Percent Difference Comparison Report for Radiography and Visual**  **Examination), dated April 20, 2005**

• **Attachment 6 of CCP TP 005 Rev 14; Waste Form, Wast e Material Parameters,**  **Prohibited Items, and Packaging for a Described Are a in Pit 4 at the Idaho National**  **Laboratory (CCP-AK-INL-001 Rev 1) for Soils, Solid Inorganics, and Debris, (three**  **forms) obtained week of May 6, 2005**

• **Attachment 4 - CCP TP 005 Rev 14; Acceptable Knowle dge Source Document**  **Reference List for Waste Stream ID-SDA-PIT4-SOIL, I NEEL Pit 4 Soils, obtained week**  **of May 6, 2005**

• **Attachment 4 - CCP TP 005 Rev 14; Acceptable Knowle dge Source Document**  **Reference List for Waste Stream ID-SDA-PIT4-DEBRIS, INEEL Pit 4 Debris, obtained**  **week of May 6, 2005 6** 

• **Attachment 4 - CCP TP 005 Rev 14; Acceptable Knowle dge Source Document**  **Reference List for Waste Stream ID-SDA-PIT4-SLUDGE, INEEL Pit 4 Solids, obtained**  **week of May 6, 2005**

• **Attachment 1 - CCP TP 005 Rev 14; Acceptable Knowle dge Documentation Checklist**  **for INEEL Soil with Minor Amounts of Homogenous Soli ds and Debris, Waste Stream**  **ID-SDA-PIT4-SOIL, obtained week of May 6, 2005**

• **Attachment 1 - CCP TP 005 Rev 14; Acceptable Knowle dge Documentation Checklist**  **for INEEL Inorganic and Organic Sludge and Roaster O xide with Minor Amounts of Soil**  **and Debris, Waste Stream ID-SDA-PIT4-SLUDGE, obtain ed week of May 6, 2005** 

• **Attachment 1 - CCP TP 005 Rev 14; Acceptable Knowle dge Documentation Checklist**  **for Heterogeneous Debris with Minor Amounts of Homo genous Solids and Soil, Waste**  **Stream ID-SDA-PIT4-DEBRIS, obtained week of May 6, 2005** 

• **Attachment 8 - CCP TP 005 Revision 14; List of Wast e Containers for CCP-AK0INL**  **001, ID-SDA PIT4- SLUDGE, obtained the week of May 6, 2005** 

• **ID P091 A Comprehensive Inventory of Radiological a nd Nonradiological Contaminants**  **in Waste Buried in the Subsurface Disposal Area of the INEL RW MC During the Years**  **1952-1983 (Volumes 1-5), Lockheed, INEL-95/0310, dat ed 8/1/1995** 

• **ARA-U003, Installation Assessment Report for EG&G I daho Inc., Operations at the**  **Idaho National Engineering Laboratory, EG&G Idaho EE G-WM-6875, dated 1/1/1986** 

• **ID-U100, Waste Disposal Request and Authorization F orms, Idaho Generators to Buffer**  **Areas of Pit 4, 4/17/1964**

• **ID-C101, Pit 4, Area 1 Chemical Evaluation and RCRA Hazards Analysis, C.J. Johnson,** 

**2/2/2005**

• **RF-P085, Reconstruction of Historical Rocky Flats O perations and Identification of**  **Release Points, ChemRisk, 8/1/1992**

• **ID P109, Removal Action Plan for the Accelerated Re trieval Project for a Described Area**  **within Pit 4, Idaho National Engineering and Environ mental Laboratory,**  **DOE/NE-ID-11178, Rev B, 8/1/04**

• **RF-C028, Memo to Paul Sentieri, re: Pre-1970 RFP W aste, from Ed Vejvoda, 11/7/2002** 

• **RF-C101, Letter to T.S. Klayder, U.S. Food and Drug Administration re: Disposition of**  **Radioactive Devices, 5/17/61**

• **RF-U212, Can and Drum Counter Calculations for RF W aste, RFP-1274, dated** 

**10/21/1968**

• **TAN-P004, TAN Hot Shop and Satellite Facilities, R.A . Freeman, IDO-17032, 11/2/1964** 

• **RF-C123, Letter from Rod Thomas re: Meeting Notes pertaining to depleted uranium,**  **beryllium, spent graphic molds, to Ed Vejvoda, 9/12 /2000** 

• **ID-P105, Waste Categories and Characteristics for t he Accelerated Retrieval Project for a**  **Described Area within Pit 4; Thomas G. McDonald, ED F-4591, Rev. 0, 4/21/2004** **7**

• **ID-U292, Waste Inventory of Area G in Pit 4 for the Accelerated Retrieval Project within**  **the Radioactive Waste Management Complex, William H Landman, EDF 4478, Rev 1,** 

**1/3/2004**

• **ID-U304, Electronic WILD Database Dump, Shipment Li st with Detail for ARP-I,**  **Including East and West Bugger Areas, Data Limitati ons, and ARP Inventory ID List,**  **Lisa Frost, 2/24/2005 (two parts)**

• **ID-P103, Excavation Plan and Sequential Process Narr ative for the Accelerated Retrieval**  **Project for a Described Area within Pit 4, Brian Pr eussner, et al., ICP/EXT-04-00283,**  **Rev. 0, 4/1/2004**

• **RF-U400, Solid Radioactive Waste Disposal Order and Shipment Data for Shipments to**  **Pit 4, Area 1 in 1966 and 1967, E.S. Ryan et al., 1 2/15/66-3/31/67** 

• **INTEC-P001, Estimated Radiological Inventory Sent f rom the Idaho Nuclear Technology**  **Center and Engineering Center to the Subsurface Dis posal Area, 1952 through 1993,**  **James A. Vail et al, ICP/EXT-03-00967, 1952-1993**

• **ID-D001, Discrepancy Resolution, for Pit 4 AK Repor t, re: radionuclide quantification**  **of Pit 4 Waste, Steve Schafer, dated 4/25/2005**

• **CCP-AK-INL-001, Central Characterization Project Ac ceptable Knowledge Summary**  **Report for a Described Area in Pit 4 at the Idaho Na tional Laboratory, Transuranic Waste**  **Streams ID-SDA-PIT4-DEBRIS, ID-SDA-PIT4-SLUDE, ID-S DA-PIT4-SOIL,**  **Revision 1, April 15, 2005**

• **Memorandum, from Richard Provencher, Idaho Cleanup Project, re: Multi-Source**  **Leachate at Pit 4 and the Subsurface Disposal Area, dated April 28, 2005** 

• **CCP-TP-068, Container Management at Idaho National Laboratory (INL) Rev. 1,**  **Attachment 1, Container Traveler Part 4 for Pit 4 S oil** 

• **CCP-TP-005, Rev. 14, Attachment 7, Radionuclides, A K-NDA Memorandum, Pit 4**  **Sludge, Debris, Solids, dated 4/22/05**

• **CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 15, effective date**  **March 31, 2005**

• **Interoffice Correspondence, from A.J. Fisher to D.H . Haar, re: Current Central**  **Characterization Project Surveillance/Assessment Sc hedules, dated April 5, 2005** 

• **Site Project Manager (SPM) qualification card, B. B roomfield, dated September 7, 2004** 

• **SPQAO for validation and verification qualification card, C. Gomez, dated May 14, 2003** 

• **Surveillance Number SIR-CCP-001-05, Surveillance of CCP at the Carlsbad Project**  **Office and Included Acceptable Knowledge Documentat ion, dated August 17-19, 2005.** 

• **Interoffice Correspondence from A.J Fisher to D.H. Haar, re: Information Copy of**  **Completed Central Characterization Surveillance Rep ort SUF-CCP-001-05 Performed at**  **the Carlsbad Office, correspondence dated August 23 , 2005.** **8**

• **NCR No. NCR0INL-0429-05; containers ARP00047, ARP00123 , ARP00304; containers**  **less than the LLD, dated August 28, 2005**

• **NCR No. NCR-INL-0433-05, container ARP00218, incorrect density for soil/gravel,**  **dated October 3, 2005**

• **RF-P267, Radioassay Data Collected During 3100 Cubi c Meter Project-EDF by Cecilia**  **Hoffman, EDF–3374, Rev. 9, dated February 26, 2002**

• **ID-P110, Air Emissions Evaluation for the OU-7-10 G lovebox Excavator Method**  **Project, Michael L Abbott, EDF-2322, Rev. 1, March 22, 2004** 

• **P024, Content Code Assessments for INEL Contact-Hand led Stored Transuranic Wastes,**  **Thomas L Clements Jr., U.S. DOE, Idaho Operations O ffice, October, 1982** 

• **Central Characterization Project Surveillance Repor t Approval and Concurrence,**  **Verification of Acceptable Knowledge, S. Muse, Site Project Quality Assurance** 

• **Interoffice Correspondence, from I. Quintana to CCP Records Custodian, re: Savannah**  **River Site Summary Category Group Specific Miscerti fication Rate, dated January 21,** 

**2005**

• **Interoffice Correspondence, from I. Quintana to CCP Records Custodian, re: Waste**  **Material Parameter Weight Comparison Report for Sav annah River Site, September 2003**  **through December 2004 (Relative Percent Difference Comparison Report for**  **Radiography and Visual Examination), dated June 14, 2004** 

• **Interoffice Correspondence, from I. Quintana to P.C . Gomez and B. Broomfield, re:**  **Acceptable Knowledge Accuracy Report: Idaho Nationa l Laboratory Waste Stream**  **Number ID-RF-S5126, Lot 1, dated May 3, 2005**

• **ICP/EXT-04-00248, Revision 1; Historical Background Report for Rocky Flats Plant**  **Waste Shipped to the INEEL and Buried in the SDA fr om 1954 to 1971, March 2005.** 

• **CCP-AK-INL-001, Revision 2, Central Characterizatio n Project Acceptable Knowledge**  **Summary Report for Waste Retrieved from Designated Areas within the Subsurface**  **Disposal Area at the Idaho National Laboratory, Tran suranic Waste Streams**  **ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, Revision 2, March 20, 2006** 

• **Draft Waste Stream Profile Form, ID-SDA-PIT4-DEBRIS , for Audit Only, March 2,** 

**2006**

• **Draft Waste Stream Profile Form, ID-SDA-PIT4-SOIL, for Audit Only, March 2, 2006** 

• **Draft Waste Stream Profile Form, ID-SDA-PIT4-SLUDGE , for Audit Only, March 2,** 

**2006**

• **CCP-AK-INL-001 NDA Memo, March 29, 2006**

• **NDA AK Confirmation Spreadsheets (four) for 15 drums , PIT 4 Sludge, Soil, and Debris,**  **March 14, 2006**

• **CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 15, effective date**  **March 31, 2005 9** 

• **WILD Volume by Generator; spreadsheet showing each generator in ARP-I and ARP-II**  **by volume (not location) and general type of waste disposed of, April 20, 2006** 

• **ID-P221, Waste Inventory for the Accelerated Retrie val Project 2, Jeffrey D. Bryan,**  **EDF-5447, Rev.1, 5/31/05**

• **D-C204, Email Correspondence from Hopi Saloman to D ouglas Parker, re: SDA Waste**  **Retrieval Volume Projection Backup, 3/1/06**

• **P118 ORAU Dose Reconstruction for NIOSH, Technical Basis Document for Idaho**  **National Engineering and Environmental Laboratory, O RAUT-TKBS-0007-2, Rev.1,** 

**7/28/04**

• **ID-P218, Engineering Evaluation/Cost Analysis for A ccelerated Retrieval Project II,**  **U.S. DOE, Idaho Operations Office, DOE/NE-ID-11223, Rev. 0, 3/1/2005** 

• **ID-P178, Waste Inventory Estimate for the Described Area within Pit 4 for the**  **Accelerated Retrieval Project within the Radioactiv e Waste Management Complex,**  **10/9/2003, EDF-4478 Project 23927**

• **ID-U105, Waste Shipments in ARP-II Retrieval Area, West Buffer Area, and East Buffer**  **Area Spreadsheets from a WILD Database Query and Li mitations of the Data, Jeff**  **Harrison, 3/29/06**

**The following drums and respective batch data repor ts (BDRs) were also examined:** 

Drum

ID Number VE Batch ID Assay Batch ID

**ARP00230 (soil)**  **IN-ARP-VE-00019 IN-NDAT05004**

**ARP00152 (solid)**  **IN-ARP-VE-000202 IN-NDA-H050028**

**ARP00091 (solid)**  **IN-ARP-VE-000067 IN-NDA-W050009**

**ARP00352 (debris)**  **IN-ARP-VE-00014**

**(graphite) Not provided** 

**ARP00477 (debris)**  **IN-ARP-VE-000202 IN-NDAW050078** 

**The EPA obtained much of the information cited abov e from April through October 2005.** 

**Review of measurement data and Waste Stream Profile Forms (WSPFs) necessitated review of**  **additional data and revised procedures which EPA re quested later in 2005 and all requested**  **information was received by April 6, 2006. The ins pection team evaluated the adequacy of this**  **AK information specific to the contact-handled (CH) TRU newly-generated debris, soil and solid**  **waste and made the following observations:**

**(1) Overall procedural technical sufficiency and scope**  **and ability to follow the AK WC process**

**for containers and waste streams were evaluated. 10** 

**The following documents were provided to EPA as sho wn at different times over the last 8** 

**months:**

**- Revision 15 of CCP Procedure CCP-TP-005 – April 200**  **5;**

**- Revision 16 of the same procedure – March 2006;** 

**- Rivision 1 of an AK Summary addressing Area 1, Pit**  **4 solid, debris, and soils – April 2005;** 

**- Revision 2 addressing both the Pit 4 and Pit 6 area**  **s. WSPF ID-SDA-PIT4-SOIL, Draft (which includes drums lists and summary radio**  **assay information) dated May 3, 2005 – May 2005;** 

**- Draft WSPFs for Pit 6 sludge and debris – March 200**  **6;**

**- BDR data for select debris, soil, and solid-bearing**  **waste containers – March 2006;**

**and**

**- Assay data – April 2005.** 

**However, various CCP-TP-005 procedural attachments such as Attachments 10 and 13,**  **requested for review by EPA and which show AK confi rmation and re-evaluation activities** 

**were** not **completed for any of the Pit 4 waste streams. The sum of this information indicates**  **that the INL-CCP has prepared and revised CCP AK pr ocedures and has prepared general**  **AK-related documents required to demonstrate compli ance with procedural requirements.**  **Since the completed AK attachments were not provide d for review, EPA’s primary focus was**  **data and information provided to support Pit 4. La ter EPA was made aware of INL-CCP’s**  **desire to expand to Pit 6 wastes. EPA obtained inf ormation pertinent to Pit 6, and the data**  **reviewed indicated that this area had the same targ eted waste as Pit 4. The EPA inspector**  **could not identify specific differences between the two areas in terms of non-targeted**  **contributions because the AK Summary, Revision 2 wa s not written to include this**  **information, instead rolling together the data with out distinction. The review of the AK**  **summary is consistent with the AK tiering designati on given in the final baseline inspection**  **report. EPA will review changes to the AK Summary to reflect improvements and updates**  **that are necessary due to expansion of the target a rea. INL CCP must provide the revised AK**  **Summary with the next submission of T2 changes.**

**(2) The AK Summary Revision 1 for CH newly-generated so**  **il, solid, and debris waste generated from a described area in Pit 4 (i.e., ARP-I), Revis**  **ion 2 of the same AK Summary with respect to selected references and adherence to the**  **CH-WAC definition of waste stream was**

**evaluated.**

**The following AK summaries were examined during the inspection:** 

• **CCP-AK-INL-001, Central Characterization Project Ac ceptable Knowledge**  **Summary Report for a Described Area in Pit 4 at the Idaho National Laboratory,**  **Transuranic Waste Streams ID-SDA-PIT4-DEBRIS, ID-SD A-PIT4-SLUDE,**  **ID-SDA-PIT4-SOIL, Revision 1, April 15, 2005 11** 

• **CCP-AK-INL-001, Revision 2, Central Characterizatio n Project Acceptable**  **Knowledge Summary Report for Waste Retrieved from D esignated Areas within the**  **Subsurface Disposal Area at the Idaho National Labor atory, Transuranic Waste**  **Streams ID-SDA-DEBRIS, ID-SDA-SLUDGE, ID SDA-SOIL, Revision 2, March**  **20, 2006**

**AK-INL-001 Revisions 1 and 2 addressed Pit 4 soil, solid and debris. Both documents**  **contain a large amount of information concerning th e origin of wastes within Pit 4, as well as**  **the processes that generated these wastes. Documen ts include roll-up data pertaining to the**  **physical, chemical and radiological characteristics of the waste as a whole, although it is**  **difficult to discern the specific contributions of each generator site. This is important**  **because it impacts the anticipated radionuclide con tent within the waste that will be**  **extracted, and the subsequent AK-derived isotopic d istribution. The references examined**  **support or provide information related to the AK Su mmary text that referenced the**  **supplemental data. EPA could not ascertain the dif ferences between Revisions 1 and 2. In**  **the future, all revisions to the AK Summary adding new areas should identify the waste types**  **specific to those areas, generator sites contributi ng waste, and radionuclide content within the** 

**new area.**

**The waste streams presented in this AK Summary are very broad, and are based solely on**  **Summary Category Groups. This approach is atypical with respect to waste streams defined**  **in the complex as a whole. The justification for t his approach is based on the assumption that**  **drums within these Pit(s) would be breached, and th erefore it would be impossible to**  **separate containers or wastes. During the May 2005 inspection, EPA was able to observe a**  **portion of the newly-generated WC process and it be came clear that while CCP suspected**  **most of the containers in Pit 4 to be breached, mos t of those extracted to date were intact.**  **The original Summary Category Group designation was established based on the assumption**  **that the waste extracted from the pit would be mixe d and original drum containers would be**  **crushed. EPA expects CCP to continually examine th e waste stream designations and to**  **modify these designations, if appropriate, to ensur e adherence to the definition of each waste**  **stream with respect to DOE/WIPP-02-3122, “Contact-H andled Transuranic Waste**  **Acceptance Criteria for the Waste Isolation Pilot P lant,” Revision 3, dated April 25, 2005**  **(CH-WAC), and the Waste Analysis Plan (WAP).**

**(3) Waste generating processes were examined.** 

**All waste originating from Pit 4 and Pit 6 are desi gnated as newly-generated. The CCP**  **indicated that their decision to define wastes orig inating from these areas as general**  **Summary Category Group Waste Streams, instead of by a more detailed subcategory, is**  **justified based on the waste being newly-generated and that the newly-generated waste**  **process would result in commingling of wastes that is not amenable to a more detailed**  **breakdown by physical characteristics (i.e., graphi te vs. steel), etc. A portion of the waste**  **generating process was observed, but EPA was not ab le to observe the full waste generating**  **processes because either the equipment was under re pair at the time of the EPA’s inspection,**  **or because the process had been on temporary shut d own due to other considerations. The** 

**CCP classifies waste from Pit 4 and Pit 6 as IDA-SD A-Pit 4 Debris, IDA-SDA-Pit 4 Sludge,** **12**

**or IDA-SDA-Pit 4 Soil, based on the predominant con tent of the drum. Even though soil is**  **not a targeted material, a considerable amount of c ommingled soil that is contaminated is**  **expected.**

**While the full characterization process could not b e observed, EPA did examine data related**  **to the generation process to better understand wast e generation. For example, the existing**  **AK data were used to develop the Pit 4 excavation p lan (e.g., ID-P103, ID-P105, ID-P109),**  **which includes the concept of maximizing the remova l of targeted waste and minimizing the**  **removal of non-targeted waste and soil. Targeted waste**  **is defined as waste with relatively high organic and radionuclide content originating f**  **rom RFETS with the understanding that**

**wastes from other sites could be mixed with the tar geted waste if all waste containers were**  **crushed and wastes were subsequently commingled. T he excavation plan anticipates**  **removal of approximately 90,000 ft 3**  **(12,000 drums) from Pit 4, compared to a targeted waste**  **volume of about 29,000 ft 3**  **. CCP expects that most of the extra volume will b e soil which**  **comprises >45% of the total volume in Pit 4. Docum ents indicated the removal of an**  **additional 163,970 ft 3**  **from Pit 6 is anticipated, noting that this number includes both targeted**  **and non-targeted wastes.**

**Data pertaining to Pit 4 were examined to understan d the information that identifies waste**  **location. The grid plots in ID-P103 (Pit 4) indica te that, in some cases, non-targeted waste**  **(i.e., non-RF sludges and non-combustible debris wa ste) are in distinctly different areas than**  **targeted waste. However, the area containing most of the 741 and 743 sludge and filters (the**  **central portion of Pit 4 to the eastern boundary) a lso contains most of the 742 and 744**  **sludges, considerable amount of debris waste, and a bout 75% of the roaster oxide waste, so**  **inadvertent commingling of wastes may occur. Avoid ing excessive commingling in this area**  **will take considerable effort. If commingling occu rs, care must be taken to ensure that such**  **actions do not impact compliance with WAC requireme nts with respect to TRU radionuclide**  **content, taking into account the potential for the variety of radionuclide contents that are**  **possible because of this commingling.**

**EPA also examined information pertaining to the loc ation of waste in Pit 6, including** 

**references ID-P221 and U105. P221 included the loc ation of targeted wastes within the**  **subject area with their expected content of TRU rad ionuclides of these and non-targeted** 

**wastes in the Pit 6 area. This reference also show s that there are AK data that identify the**  **specific location (i.e., X-Y coordinates) of target ed RFETS waste in Pit 6. U105 is a**  **spreadsheet that shows waste in Pit 6 by generator, disposal date, waste type, waste**  **generating process, etc., all of which were obtaine d from the WILD database. Also,**  **reference ID-C204 provides backup calculations pert aining to the location of waste in the**  **Solid Waste Disposal Area (SDA) that includes Pits 4 and 6, stating that it is the intent of the**  **project to retrieve waste from many other Pits and to “roll” this waste into the existing three** 

**waste streams derived from Pit 4 and Pit 6. In sho rt, review of these data shows that RFETS**  **waste is also the principal component of waste in t he Pit 6 area, and references indicate that**  **the targeted population is equivalent in terms of w aste type for Pit 4 and Pit 6. Information**  **pertaining to Pit 6 also shows that while specific information as to the location of wastes is**  **available, commingling will also likely take place. 13** 

**Differences between non-targeted wastes that may be present in Pit 4 and Pit 6, including**  **waste generator, waste type and radionuclide conten t, are difficult to discern, although it is** 

**assumed that this information is available because the AK Summary was updated to include**  **this information. In the future, revisions to AK S ummaries must provide sufficient**  **information to understand the radiological and phys ical characteristics of waste, including**  **but not limited to, changes in targeted materials.**

**(4) AK information pertaining to radiological character**  **istics and waste material parameter**

**content of material in Pit 4 was examined.**

**As stated previously, EPA learned of the addition o f Pit 6 to the AK Summary late in the**  **process of evaluating this information. The follow ing analysis was performed for Pit 4, and**  **the general observations obtained through this anal ysis could also apply to Pit 6.** 

Pit 4 (ARP-I) Analysis

**As stated in the 2005 INEEL NDA memo for Pit 4, “Th e overriding limitation concerning the**  **radionuclide information presented in the AK Summar y Report is that no data has been**  **located that quantifies the radionuclides present i n the wastes buried in Pit 4, Area 1.**  **Additionally, there is no documentation of expected radionuclides.” CCP representatives**  **indicated that there are data on the origin and was te characteristics of each waste container**  **and on its location in the pit, but the specific ra dionuclide content of each container is not**  **available. Instead, the radionuclide content was d eveloped from data on RFETS wastes**  **stored at RWMC during the 1970 to 1981 time frame a nd characterized through various**  **programs (e.g., the INEEL 3100m 3**  **Program). The stored wastes were generated by var ious**  **processes at RFETS that were in use at the time tha t became part of the Pit 4 area containing**  **drummed waste. The key assumption pertinent to the se wastes is that they are similar in**  **radionuclide composition and concentration to the s tored waste.** 

**For RFETS waste, the key documents reviewed when as sessing Pit 4 were:** 

• **ICP/EXT-04-00248, Revision 1 for waste types, volum es, and shipping dates from**  **RFETS;**

• **Clements (1982) {WM-F1-82-021} for summaries of the radiological characteristics**  **of the RFETS waste stored at the RWMC during the 19 70s;** 

• **EDF-3374, Revision 0 for radioassay data collected during the 3100 cubic meter**  **project;**

• **EDF-4591 (ID-P105), which developed data on each wa ste type in Pit 4 from**  **references (2) and (3). The results of these revie ws were compared with the values**  **used in the AK Summary Report, Revision 1 (2005).**

**As would be expected, these references did not alwa ys agree in detail and did not provide** 

**exact corroboration of the conclusion in the AK Sum mary Report, Revision 1. The following**  **items, however, were noted: 14** 

• **Both ID-P105 and EDF-3374 report identical radionuc lide concentrations for1**  **st - and** 

**2 nd**  **-stage sludges, but the AK Summary Report indicates that only 1**  **st -stage sludge is**  **targeted because of higher radionuclide concentrati ons. This discrepancy was**  **explained in Clements (1982): 2 nd**  **-stage sludge was handled as a separate category when Pit 4 was being filled initially and for a tim**  **e in the 1970s when waste was being shipped to RWMC for storage. Thereafter, both 1**  **st - and 2**  **nd -stage sludges were**  **reported as a combined waste type. Clements (1982) clarified that average TRU** 

**concentrations in 2 nd**  **-stage sludge <100 nCi/g;**

• **For filters, ID-P105 shows a low TRU concentration in the 107 box equivalents**  **disposed in Pit 4 that would not justify targeting. However, EDF-3374 assays of**  **filters stored in drums indicate a somewhat higher concentration that would justify**  **targeting;**

• **Organic setups (743-Series sludge) are targeted bec ause of their high VOC**  **concentrations, but theses sludges also exhibit hig h TRU concentrations. Both ID**  **P105 and EDF-3374 show average TRU concentrations o f >500 nCi/g. Clements**  **(1982) lists average TRU concentrations of about 10 0 nCi/g;** 

• **Special setups (744-Series sludge) are fixed in a c oncrete monolith and are not**  **targeted. Both Clements (1982) and ID-P105 indicat e low concentrations of**  **radionuclides in these sludges, but the 39 drums as sayed in the 3100 cubic meter**  **project (EDF-3374) had average TRU concentrations > 10,000 nCi/g;** 

• **Combustible debris waste (combustibles and plastics ) have averages of less than**  **1 Ci/drum (i.e., 1** × **10 9**  **nCi/drum), but because of the containers’ low net w eight the** 

**TRU concentrations are on the order of several thou sand nCi/g; and** 

• **The Total Curie tabulations in ID-P105 appear incon sistent with the claim in the AK**  **Summary Report (Section 5.4.1) that approximately 9 0% of the activity (Ci) in Pit 4**  **are targeted because Table A in ID-P105 shows about 7,000 Ci targeted and 12,200**  **Ci as non-targeted. If the 2 nd**  **-stage sludge activity from Clements (1982) and the**

**filter concentrations from EDF-3374 are used the to tals become 14,000 Ci targeted**  **(65%) and 7,522 Ci non-targeted (35%). This implie s the potential that a large** 

**number of curies remain in Pit 4.**

**The above discrepancies are not included to show th at the projected plan for retrieval is in**  **error, but rather to highlight that there is signif icant uncertainty in predicted radionuclide**  **concentrations. Anomalies with respect to radionuc lide concentration, distribution, and**  **occurrence are expected during routine retrieval op erations. As such, EPA believes it is**  **important to consider and re-evaluate the radionucl ide data on a regular and consistent basis** 

**and to reconcile this information with the AK recor d to verify that the radionuclide content in**  **waste extracted coincides with expectations. The n eed for such reconciliation supports the**  **required communication between AK and NDA personnel. It is worth noting that some**  **drums may contain non-transuranic waste, e.g., roas ter oxides. Each newly-generated waste**  **drum must contain transuranic radionuclides as spec ified in the CH-WAC, Appendix E [see**  **item (6) below for load management analysis]. Reco gnizing that commingling will occur it**  **is necessary for CCP to ensure that such actions do not impact compliance with respect to** 

**TRU radionuclide content of wastes intended for WIP P.** **15**

**In addition to RFETS waste, AK Documentation for Pi t 4 indicates that this area will also**  **contain wastes from several facilities including AN L-W, ARA, PER, the Idaho Chemical**  **Processing Plant, and the Central Facility. The AK Summary Report(s) estimates the volume**  **of these wastes disposed in the ARP-I portion of Pi t 4 in Table 4-1 of the AK Summary,**  **Revision 1 to be 26,163 ft 3**  **and indicates that these wastes are not considered “targeted”** 

**wastes. The relative activities of the INEEL waste s are shown in Table 5-3. These wastes**  **contain predominately Ni-63 (78%), Sr-90/Y-90, and C s-137/Ba-137m, although some**  **wastes contain minor amounts of U-234, U-235, U-238 , and transuranic radionuclides. As**  **indicated previously, the AK Summary Revision 1 sta tes that these wastes may be**  **commingled with RFETS waste as part of the waste ge nerating processes, so the information**  **was provided to address this contingency. The incl usion of this material in the AK Summary**  **Report is appropriate and necessary.**

**The volume and radionuclide values reported in the AK Summary Report, Revision 1, were**  **checked against available reference documents to as sess whether the AK Summary Report**  **Revision 1 data were assembled and interpreted prop erly. For example, the volume totals**  **were 26,163 ft 3**  **in the AK Summary Report Revision 1 and 25,798 ft 3**  **in Table 3 of**

**EDF-4478. Most of the differences were in the othe r-than-metal debris categories. The AK**  **Summary Report Revision 1 used combustible and non- metal debris categories, whereas**  **EDF-4478 called the categories combustible and mixe d debris. The areas being used are not**  **identical; a Table 4-1 footnote says only the 1⁄2-acr e area is considered while Table 3 says**  **“These volumes have been adjusted for disposal ship ments that intersect the boundaries of**  **the retrieval area.” Regardless, the comparison do es indicate that the two documents are in**  **relative agreement with respect to waste volume val ues.** 

**INEEL waste that may be present in Pit 4 are predom inately mixed fission and activation**  **products and may not, on their own, meet the criter ia for TRU waste disposal at WIPP. The** 

**INEEL radionuclide distributions from Table 5-3 in the ARP-I AK Summary Report**  **Revision 1 were compared to Table A-11 in EDF-4591 (ID-P105). Agreement between the** 

**two tables was exact. Table A-11 used the radionuc lide distribution available from Table 1**  **in EDF-2322 (which was for data from Pit 9, not Pit 4). This distribution was applied to the**  **total curies listed in the remarks column in Append ix D of EDF-4591 for each container**  **disposed in Pit 4. This total was 27.149 Ci (a rev iew of this table indicated about 25 Ci but**  **there were legibility problems with the Table). Th ese activity levels were decayed to 2005,**  **so the calculations are valid. However, values fro m Table F-4 of Appendix F in INTEC**  **P0001 are considerably different. Table F-4 shows shipments to SDA in 1966 (the time of**  **disposal in Pit 4 was said to be from 12/65 to 4/67 in U-292) of 19,000 Ci of Cs-137, 17,000**  **Ci of Sr-90, and 159 Ci of other radionuclides. Be cause of the uncertainty of where these**  **high radioactivity wastes were interred, i.e., Pit 5 was also being used for active waste**  **disposal during 1966, there is the possibility that unexpectedly high activities could be**  **encountered in retrievals from Pit 4. This type of radionuclide uncertainty is an example of**  **why it is necessary to constantly update and confir m AK as Pit 4 is excavated, including**  **continually documenting the information on appropri ate reconciliation and comparison** 

**forms. 16** 

Summary

**The AK record has relied on the assumption that iso topic distributions and radionuclide**  **concentrations were similar to those produced from the same RFETS operations conducted 5**  **to 17 years earlier. This assumption is reasonable for isotopic distributions than for**  **radioactivity levels. However, because the waste g enerating process may include non**  **RFETS waste (described as incidental by CCP), the u sefulness of obtaining a complete and**  **accurate understanding of the radionuclide content of each container by NDA is underscored.**  **Additionally, the use of AK-based isotopics must be carefully and thoughtfully assessed with**  **respect to potential impact of the “incidental” rad ionuclides. The reliability of AK can be**  **assessed prospectively through frequent comparison of NDA data with the specific isotopic**  **information presented in the AK Summaries. With re spect to WMPs identification, because**  **the waste is newly-generated, the content of every drum will be reviewed and documented**  **prior to drum loading. The identification of WMPs should be sufficient following this**  **protocol noting that full VE of all waste will be p erformed. It is worth noting that the AK**  **Summaries document the type of materials added to P its 4 and 6, but the actual contents of**  **the newly-generated waste drums are best described during the drum loading process.** 

**(5) AK data pertaining to waste volume and waste locati**  **on were evaluated.**

**Because EPA became aware of the addition of Pit 6 t o the AK Summary late in the**  **evaluation process, the following analysis was limi ted to AK and Load Management for Pit 4**  **wastes. However, EPA expects that the general obse rvations obtained through this analysis**  **would also apply to Pit 6 wastes.**

Pit 4 (ARP-I) Volume and Waste Location Analysis

**The volumes of each waste type shown in Table 4-1 o f the AK Summary Report Revision 1**  **were compared with the timeline of waste shipments in Appendix D of ICP/EXT-04-00248**  **Revision 1 for 1965, 1966, and 1967. The Appendix D data were not always useful because** 

**it was discovered that Pit 5 and Pit 1 were used fo r TRU waste disposal at the same time.**  **Volume comparisons were made with two reports refer enced in Table 4-1, ID-U292 and**  **ID-P109. These two sources showed good agreement f or those waste types where volumes**  **could be compared, e.g., ID-P109 listed debris wast e and filters by number of boxes without**  **providing data for the volume per box. However, in all cases, the volumes cited in AK**  **Summary Report Revision 1 deviated significantly fr om the values cited in ID-U292 and**  **ID-P109. Specific examples of these differences in clude the following:** 

• **Volumes for 1 st**  **- and 2 nd**  **-stage sludges were greater by 7.6% and 4.8%, respe ctively.** 

• **Volumes for organic setup and special setup sludges were greater by 42% and 67%.** 

• **Roaster oxide volumes were greater in the AK Summar y Report by 17.5%.** 

• **Graphite waste volume in the AK Summary Report Revi sion 1 was only 42% of the** 

**value in ID-U292 and ID-P109. 17** 

• **Rocky Flats (RF) combustible and metal debris waste volumes were 64% and 50%**  **greater in the AK Summary Report Revision 1 than in ID-U292.** 

**The reason for the volume discrepancies is not know n, although some degree of variability is**  **expected. One possible outcome of uncertain volume s for different waste types is an**  **uncertainty with respect to predicting the type of waste present in a given location within a**  **pit, which increases the likelihood that non-target ed waste (including non-defense or non**  **TRU waste) could become commingled with WIPP-eligib le waste. Due to the lack of a**  **clearly defined disposal path for certain wastes (r oaster oxides and high VOC wastes) there**  **may be an incentive to allow commingling with WIPP- eligible wastes.** 

**Reports ID-U292 and ID-P103 addressed disposal of i ndividual waste containers in Pit 4 and**  **were evaluated to determine agreement, as well as t o assess the degree of commingling that**  **might be present between targeted waste, non-target ed waste, non-defense waste, and non**  **TRU waste. The ID-U292 report provides summary tot als of the 15 waste categories, as well**  **as the location of every waste container by a cell ID number. Unfortunately, the definition of** 

**the cell ID number has not been found in material e xamined and it was not possible to**  **compare the ID-U292 locations with the 15 feet x 15 feet grid areas used in ID-P103 to**  **indicate the volume of each waste category in a gri d area. Therefore, the available data**  **cannot be used to assess the degree of commingling in Pit 4. This is another reason why AK**  **should be updated and confirmed on a routine basis.**

**Additionally, there are differences between the tot al volumes of each waste category shown**  **in ID-U292 and in ID-P103. These discrepancies dif fer by less than 2% for the targeted**  **waste categories, except for 743 sludge, where the difference is 11.5%. The treatment of**  **debris waste varies in two ways: (1) the categorie s used in ID-P103 are combustible and**  **non-combustible, and in ID-U292 and the AK Summary Report Revision 1, they are**  **combustible, metal, and non-metal; and (2) the grid plots in ID-P103 do not differentiate**  **between RF and non-RF debris waste. Furthermore, t he stated volumes are much different**  **(15,756 ft 3**  **combustible waste in ID-U292 compared to 38,250 ft 3**  **in ID-P103; and 54,869 ft 3** 

**of metal and non-metal in ID-U292 versus 50,600 ft 3**  **of non-combustible waste in ID-P103). The AK Summary Report uses the value of 28,849 ft**  **3 for combustible debris and 68,158 ft**  **3**

**for metal and non-metal debris. The lack of differ entiation between RF and non-RF debris** 

**waste is unfortunate because much of the non-RF deb ris is probably either non-TRU or non**  **defense waste. However, the performance of VE on a ll waste containers during loading as**  **well as NDA of each container will help determine r adionuclide content and waste material**  **parameter content, even if AK documentation in this regard currently shows discrepancies.** 

**(6) Load management was assessed.** 

**The determination of whether loaded drums are TRU w astes (i.e., they contain >100nCi/g**  **of alpha-emitting transuranic radionuclides, and ar e eligible for disposal at WIPP) will be**  **made by measurement using NDA systems. Our understa nding is that Pit 4 and Pit 6 wastes**  **containing <100nCi/g will not be prepared for dispo sal at WIPP by load management. If INL**  **determines it will use load management for these wa stes, the appropriate notification and**  **documentation, as stipulated in the CH-WAC Attachme nt E, is required.** **18**

**(7) Defense Origin of Pit 4 waste was examined.** 

**The AK Summary Reports Revisions 1 and 2 were asses sed with respect to the defense**  **origin of these wastes. CCP contends that an asses sment of the defense nature of the waste is**  **not necessary since most of the waste and all of th e targeted waste is from RFETS. The AK**  **Summary Reports acknowledge that some non-RFETS was te may be from non-defense**  **activities but “much of the wastes are commingled d ue to the lack of container integrity and**  **would not be feasible to segregate from RF waste.” According to other documents reviewed,**  **it is possible to estimate the quantity of non-defe nse waste. For example, page 49 of the AK**  **Summary Report Revision 1, states that three drums from CSM, two from USGS, two from**  **DRI, and an indeterminate amount from ATI, SRE and the Hallam reactor have been shipped**  **to INEEL. Also, some INEEL wastes are probably not d efense-related wastes, specifically**  **those from ANL-W, Test Area North (TAN), Advanced Re actor Area (ARA), and the Power**  **Excursion Reactor (PER). Although not specified, a dditional sources may also be present in**  **Pit 6, but the AK Summary Report, Revision 2 was no t written to differentiate between Pit 4** 

**and Pit 6 sources.**

**When the AK Summary Report is revised more detail o n the amount of non-defense waste**  **that may be in Pit 4 and Pit 6 would be useful sinc e much of the non-defense waste could be**  **easily recognized. For example, EDF-4478, Table A. 1 indicates that ANL-W, ARA, PER,**  **and TAN wastes are in large containers. Providing c ell ID locations in Table A.1 and the** 

**waste identification information in Section 3 of ID -P103 would also assist in identifying** 

**these wastes. Since most of the containers seen th us far are not breached, segregation of**  **unacceptable waste is feasible because many of the unbreached (intact) drums can be**  **removed and assessed without commingling them with known WIPP-eligible waste. In**  **short, the data reviewed for this evaluation sugges t that identification and segregation of non** 

**defense waste is achievable if the waste containers are intact and the AK information**  **identifying where the material is buried holds true**

**.**

**(8) NDA-AK communication was assessed.** 

**CCP-TP-005 Section 4.4.20 requires the preparation of a memorandum documenting how**  **AK and NDA interrelate and how AK is used by NDA pers onnel. The memo is used to**  **communicate AK data information and limitations, an d is signed by both the AKE and NDA**  **Subject Matter Expert (SME) to ensure both agree on AK data use. The AK memo is** 

**included with Attachment 7 of CCP-TP-005. EPA was provided two versions of this memo,**  **one dated 4/22/05, and the other dated 3/29/05. Co mments on each memo are provided** 

**below.**

AK- NDA Memo, April 22, 2005

**This memo addresses how NDA personnel use AK, but in cludes several typographical and** 

**minor technical errors that make the use of the mem o confusing. These include, but are not** 

**limited to: 19** 

• **The AK memo for Pit 4 soil clearly states that the data therein are based on 3100m**  **3**
**waste analysis, and that “it is not possible to ade quately predict a radiological**  **distribution when each of the three identified [Pit 4] waste streams is expected to**  **contain wastes from several waste categories, with some of the categories overlapping**  **into each of the waste streams.” Nevertheless, the memo proposes use of default**  **Pu-239, Pu-238, U-235, and U-238; default isotopics are provided in the text for all** 

**but Pu-238. Information for Pu-238 or a reference where that information can be** 

**found should be included in this memo.**

• **Formulas are provided for calculating U-234 from U- 235 or U-238. These formulas**  **are appropriate, but the memo does not reference th e correct table for U-235 data.** 

• **An uncertainty value of 50% is applied to calculate d U-234 values, and while this is**  **consistent with previously approved memos by EPA, j ustification for this value is**  **lacking.**

• **The discussion pertaining to Pu-242 is inconsistent with respect to whether Pu-242**  **can be measured. In practical terms, Pu-242 cannot be measured by existing NDA**  **equipment.**

AK-NDA Memo March 29, 2006, Additional Comments

• **The AK-NDA memo has been revised to remove isotopic information other than that**  **for wastes from RFETS. When the targeted waste mat erials originated from RFETS**  **and when these materials are encountered the specif ied distributions, i.e., Weapons**  **Grade Pu isotopics, will be appropriate. However, the memo does not adequately**  **address how the isotopic distribution will be asses sed when TRU wastes that are not** 

**RFETS based are encountered.**

• **Several sources of interference are identified. EP A expects that this information will**  **be transmitted to the appropriate NDA personnel and that the interferences will be**  **within the NDA system’s ability to apply correction factors in order to derive a**  **technically valid assay value.**

**In summary, while RFETS waste is targeted, addition al waste may be present that affect the**  **isotopic distribution. The RFETS distributions sho uld be sufficient if targeting is successful,**  **but neither memo indicates how “commingled” waste w ould be addressed if container**  **measurement via NDA is not successful. An explanati on for this possibility in the March 29,**  **2006, AK-NDA memo is desirable when the memo is revi sed.** 

**(9) AK Accuracy was evaluated, including reassignment o**  **f wastes to different waste streams**

**from Pit 4.**

**An AK Accuracy report was not provided by CCP for P it 4 and Pit 6. EPA’s analysis has** 

**shown that there are uncertainties associated with AK data for various wastes in Pit 4 and Pit**  **6, and the generation of waste via commingling crea tes added uncertainties with respect to**  **radiological waste content in each drum. Therefore , ongoing assessment of AK accuracy at**  **an initial frequency greater than annually would be prudent, as well as a comparison of the**