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 LABORATORY 

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 Knowledge 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. Environmental Protection Agency (EPA or the 

Agency) conducted Baseline Inspection No. EPA-INL-CCP-05.05-8 of the Central 

Characterization Project (CCP), located at the Idaho National Laboratory (INL)1

 from May 3-5, 

2005. The scope of this baseline inspection included several aspects of the site’s program to 

characterize wastes proposed for disposal in the Waste 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 demonstration 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 respect to Acceptable Knowledge (AK) and 

Load Management, this approval encompassed retrievably-stored debris and solid waste 

provided to CCP from the Advanced Mixed Waste Treatment Project (AMWTP), a separate 

operation co-located at INL, for characterization by 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 be subject to EPA evaluation and review 

through a Tier 1 (T1) change. INL-CCP subsequently requested a T1 change for newlygenerated solid, debris, and soil waste from Area 1 of Pit 4 at Radioactive Waste Management 

Complex (RWMC) located onsite at INL, referred to more specifically as the Accelerated 

Retrieval Process Area I, or ARP-I.2

 Since the baseline inspection and approval in 2005, INLCCP elected to expand the excavated area to include Accelerated Retrieval Process Area II 

(ARP-II), which is an approximately 1⁄2-acre area encompassing 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 Figure 1. 

This report serves as EPA’s evaluation of AK data for debris (S5000), solid (S3000) and 

soils/gravel (S4000) from Pits 4 and 6 as a T1 change. Using the information provided in this 

report, EPA has determined that AK information provided for CH TRU debris, solids, and 

soils/gravel from Pits 4 and 6 is adequate. 

In the future, EPA must review and approve AK documentation 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 believes that the AK documentation 

compiled for non-shaded areas of Pit 4 and Pit 6 areas 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 Environmental Laboratory and the Argonne 

national Laboratory – West with a minor contribution from other DOE facilities. 

 

1

 The INL was previously called the Idaho National Engineering Laboratory (INEL) and the Idaho National

Engineering and Environmental Laboratory (INEEL). The use of one name versus another is not necessarily 

significant and this report uses all three names depending on the context. 

2

 The specific areas to which this approval pertains are shown in the shaded portion of Figure 1 in Section 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 sections 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 intend to implement the practice of Load 

Management for Pit 4 and Pit 6 at this time, Load Management is not included in this approval. 

If load management for the waste from the Idaho Cleanup Project (ICP) were to occur, INL CCP 

must comply with the requirements for load management given in the Appendix E of DOE’s 

Waste Acceptance Criteria (WAC) for CH TRU waste. 

 

This report, in conjunction with the INL Baseline Final Inspection Report (see EPA Docket No: 

A-98-49; II-A4-59, November 2005) completes EPA’s initial 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 according to the tiering requirements set forth in 

the INL Baseline Final Report cited above. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s 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 demonstration that the program’s components, 

with applicable conditions and limitations, can adequately characterize TRU wastes and comply 

with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An 

EPA inspection team conducts an onsite inspection to verify that the site’s system of controls is 

technically adequate and properly implemented. 

Following the EPA’s approval of WC processes evaluated during the baseline inspection, EPA is 

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

conducting additional inspections under the authority of 40 CFR 194.24(h). Under 

40 CFR 194.24, EPA has the authority to conduct continued 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 requirements. Based on the adequacies of the WC 

processes demonstrated during the baseline inspection, including all conditions and limitations, 

EPA specified which subsequent WC program changes or modifications must undergo further 

EPA inspection or approval under 40 CFR 194.24. This 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 change 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 using T1 designated methods not yet approved 

by EPA. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of the EPA’s desktop inspection of a T1 change to the initial 

baseline approval of INL-CCP. Specifically, this addresses the technical area of AK and Load 

Management for wastes from ARP-I and ARP-II areas of 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 evaluation 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 and Pit 6, respectively in this report. AK for 

wastes from non-shaded areas encompassing the remainder 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) Retrieval Areas 
4

5.0 DESKTOP EVALUATION TEAM 

This desktop review of the AK and Load Management aspects of INL-CCP’s WC program was 

performed by Connie Walker with assistance from Patrick Kelly. A complete listing of all 

individuals who participated in the original EPA Baseline Inspection in May 2005 is provided in 

the INL Baseline Final Inspection Report issued in November 2005. 

6.0 PERFORMANCE OF THE REVIEW: ACCEPTABLE KNOWLEDGE AND 

LOAD MANAGEMENT OF PIT 4 AND PIT 6 

Background Information

Area 1 of Pit 4 (ARP-I) at the RWMC was used for the disposal of TRU wastes from January 

1963 until September 1967. Approximately 81% (110,000 ft3

 of the 136,000 ft3 total) of the 

wastes buried in this 1⁄2-acre area of Pit 4 originated at DOE’s Rocky Flats Environmental 

Technology Site (RFETS). The remainder of the wastes in this area originated at INEEL 

facilities and Argonne National Laboratory-West (ANL-W), with minor amounts attributed to 

several facilities that were transshipped from RFETS. 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), and 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 expected that many of the waste containers 

would be breached and that their contents might therefore 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 container incident, and operations have yet 

to be reinitiated. All excavation and retrieval operations occur within enclosures for purposes of 

contamination control. If it is determined that containers being excavated contain targeted 

material, the container’s contents are removed, placed 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 evaluated suggested that some drums were stacked 

in the pit while others were dumped, and initial observations indicated that most waste containers 

initially removed were in fact intact with regard to structural integrity. 

As part of the inspection, EPA reviewed the elements 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 documentation 
5

• Characterization of required waste material parameters (WMPs) and radionuclides 

• AK information assembly and compilation 

• AK confirmation and associated discrepancy resolution 

• Sufficiency of AK characterization results 

• Assembly of required information and use of supplemental information 

• AK summary preparation 

• Reassignment of waste stream due to AK and discrepancy 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 wastes 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, including 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 National 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, Waste Material Parameters, 

Prohibited Items, and Packaging for a Described Area 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 Knowledge Source Document 

Reference List for Waste Stream ID-SDA-PIT4-SOIL, INEEL Pit 4 Soils, obtained week 

of May 6, 2005 

• Attachment 4 - CCP TP 005 Rev 14; Acceptable Knowledge 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 Knowledge 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 Knowledge Documentation Checklist 

for INEEL Soil with Minor Amounts of Homogenous Solids and Debris, Waste Stream 

ID-SDA-PIT4-SOIL, obtained week of May 6, 2005 

• Attachment 1 - CCP TP 005 Rev 14; Acceptable Knowledge Documentation Checklist 

for INEEL Inorganic and Organic Sludge and Roaster Oxide with Minor Amounts of Soil 

and Debris, Waste Stream ID-SDA-PIT4-SLUDGE, obtained week of May 6, 2005 

• Attachment 1 - CCP TP 005 Rev 14; Acceptable Knowledge Documentation Checklist 

for Heterogeneous Debris with Minor Amounts of Homogenous Solids and Soil, Waste 

Stream ID-SDA-PIT4-DEBRIS, obtained week of May 6, 2005 

• Attachment 8 - CCP TP 005 Revision 14; List of Waste Containers for CCP-AK0INL001, ID-SDA PIT4- SLUDGE, obtained the week of May 6, 2005 

• ID P091 A Comprehensive Inventory of Radiological and 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, dated 8/1/1995 

• ARA-U003, Installation Assessment Report for EG&G Idaho Inc., Operations at the 

Idaho National Engineering Laboratory, EG&G Idaho EEG-WM-6875, dated 1/1/1986 

• ID-U100, Waste Disposal Request and Authorization Forms, 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 Operations and Identification of 

Release Points, ChemRisk, 8/1/1992 

• ID P109, Removal Action Plan for the Accelerated Retrieval Project for a Described Area 

within Pit 4, Idaho National Engineering and Environmental Laboratory, 

DOE/NE-ID-11178, Rev B, 8/1/04 

• RF-C028, Memo to Paul Sentieri, re: Pre-1970 RFP Waste, 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 Waste, 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 the Accelerated Retrieval Project for a 

Described Area within Pit 4; Thomas G. McDonald, EDF-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 List with Detail for ARP-I, 

Including East and West Bugger Areas, Data Limitations, and ARP Inventory ID List, 

Lisa Frost, 2/24/2005 (two parts) 

• ID-P103, Excavation Plan and Sequential Process Narrative for the Accelerated Retrieval 

Project for a Described Area within Pit 4, Brian Preussner, 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., 12/15/66-3/31/67 

• INTEC-P001, Estimated Radiological Inventory Sent from the Idaho Nuclear Technology 

Center and Engineering Center to the Subsurface Disposal Area, 1952 through 1993, 

James A. Vail et al, ICP/EXT-03-00967, 1952-1993 

• ID-D001, Discrepancy Resolution, for Pit 4 AK Report, re: radionuclide quantification 

of Pit 4 Waste, Steve Schafer, dated 4/25/2005 

• CCP-AK-INL-001, Central Characterization Project Acceptable Knowledge Summary 

Report for a Described Area in Pit 4 at the Idaho National Laboratory, Transuranic Waste 

Streams ID-SDA-PIT4-DEBRIS, ID-SDA-PIT4-SLUDE, ID-SDA-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 Soil 

• CCP-TP-005, Rev. 14, Attachment 7, Radionuclides, AK-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 Schedules, dated April 5, 2005 

• Site Project Manager (SPM) qualification card, B. Broomfield, 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 Documentation, dated August 17-19, 2005. 

• Interoffice Correspondence from A.J Fisher to D.H. Haar, re: Information Copy of 

Completed Central Characterization Surveillance Report 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 Cubic Meter Project-EDF by Cecilia 

Hoffman, EDF–3374, Rev. 9, dated February 26, 2002 

• ID-P110, Air Emissions Evaluation for the OU-7-10 Glovebox Excavator Method 

Project, Michael L Abbott, EDF-2322, Rev. 1, March 22, 2004 

• P024, Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, 

Thomas L Clements Jr., U.S. DOE, Idaho Operations Office, October, 1982 

• Central Characterization Project Surveillance Report 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 Miscertification Rate, dated January 21, 

2005 

• Interoffice Correspondence, from I. Quintana to CCP Records Custodian, re: Waste 

Material Parameter Weight Comparison Report for Savannah 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 National 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 from 1954 to 1971, March 2005. 

• CCP-AK-INL-001, Revision 2, Central Characterization Project Acceptable Knowledge 

Summary Report for Waste Retrieved from Designated Areas within the Subsurface 

Disposal Area at the Idaho National Laboratory, Transuranic 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 Retrieval Project 2, Jeffrey D. Bryan, 

EDF-5447, Rev.1, 5/31/05 

• D-C204, Email Correspondence from Hopi Saloman to Douglas 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, ORAUT-TKBS-0007-2, Rev.1, 

7/28/04 

• ID-P218, Engineering Evaluation/Cost Analysis for Accelerated 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 Radioactive 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 Limitations of the Data, Jeff 

Harrison, 3/29/06 

The following drums and respective batch data reports (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 above 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 requested later in 2005 and all requested 

information was received by April 6, 2006. The inspection 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 shown at different times over the last 8 

months: 

- Revision 15 of CCP Procedure CCP-TP-005 – April 2005; 

- 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 areas. WSPF ID-SDA-PIT4-SOIL, 

Draft (which includes drums lists and summary radioassay information) dated May 3, 

2005 – May 2005; 

- Draft WSPFs for Pit 6 sludge and debris – March 2006; 

- 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 confirmation 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 procedures and has prepared general 

AK-related documents required to demonstrate compliance with procedural requirements. 

Since the completed AK attachments were not provided for review, EPA’s primary focus was 

data and information provided to support Pit 4. Later EPA was made aware of INL-CCP’s 

desire to expand to Pit 6 wastes. EPA obtained information pertinent to Pit 6, and the data 

reviewed indicated that this area had the same targeted 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 was not written to include this 

information, instead rolling together the data without distinction. The review of the AK 

summary is consistent with the AK tiering designation 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 area. 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 soil, solid, and debris waste generated 

from a described area in Pit 4 (i.e., ARP-I), Revision 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 Acceptable Knowledge 

Summary Report for a Described Area in Pit 4 at the Idaho National Laboratory, 

Transuranic Waste Streams ID-SDA-PIT4-DEBRIS, ID-SDA-PIT4-SLUDE, 

ID-SDA-PIT4-SOIL, Revision 1, April 15, 2005 
11

• CCP-AK-INL-001, Revision 2, Central Characterization Project Acceptable 

Knowledge Summary Report for Waste Retrieved from Designated Areas within the 

Subsurface Disposal Area at the Idaho National Laboratory, 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 the origin of wastes within Pit 4, as well as 

the processes that generated these wastes. Documents 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 content within the waste that will be 

extracted, and the subsequent AK-derived isotopic distribution. The references examined 

support or provide information related to the AK Summary text that referenced the 

supplemental data. EPA could not ascertain the differences 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 contributing 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 this approach is based on the assumption that 

drums within these Pit(s) would be breached, and therefore 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 became clear that while CCP suspected 

most of the containers in Pit 4 to be breached, most 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 mixed and original drum containers would be 

crushed. EPA expects CCP to continually examine the waste stream designations and to 

modify these designations, if appropriate, to ensure adherence to the definition of each waste 

stream with respect to DOE/WIPP-02-3122, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant,” 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 designated as newly-generated. The CCP 

indicated that their decision to define wastes originating 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., graphite vs. steel), etc. A portion of the waste 

generating process was observed, but EPA was not able to observe the full waste generating 

processes because either the equipment was under repair at the time of the EPA’s inspection, 

or because the process had been on temporary shut down due to other considerations. The 

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

or IDA-SDA-Pit 4 Soil, based on the predominant content of the drum. Even though soil is 

not a targeted material, a considerable amount of commingled soil that is contaminated is 

expected.

While the full characterization process could not be observed, EPA did examine data related 

to the generation process to better understand waste generation. For example, the existing 

AK data were used to develop the Pit 4 excavation plan (e.g., ID-P103, ID-P105, ID-P109), 

which includes the concept of maximizing the removal 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 from RFETS with the understanding that 

wastes from other sites could be mixed with the targeted waste if all waste containers were 

crushed and wastes were subsequently commingled. The excavation plan anticipates 

removal of approximately 90,000 ft3

 (12,000 drums) from Pit 4, compared to a targeted waste 

volume of about 29,000 ft3

. CCP expects that most of the extra volume will be soil which 

comprises >45% of the total volume in Pit 4. Documents indicated the removal of an 

additional 163,970 ft3

 from Pit 6 is anticipated, noting that this number includes both targeted 

and non-targeted wastes. 

Data pertaining to Pit 4 were examined to understand the information that identifies waste 

location. The grid plots in ID-P103 (Pit 4) indicate that, in some cases, non-targeted waste 

(i.e., non-RF sludges and non-combustible debris waste) 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) also contains most of the 742 and 744 

sludges, considerable amount of debris waste, and about 75% of the roaster oxide waste, so 

inadvertent commingling of wastes may occur. Avoiding excessive commingling in this area 

will take considerable effort. If commingling occurs, care must be taken to ensure that such 

actions do not impact compliance with WAC requirements 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 location of waste in Pit 6, including 

references ID-P221 and U105. P221 included the location of targeted wastes within the 

subject area with their expected content of TRU radionuclides of these and non-targeted 

wastes in the Pit 6 area. This reference also shows that there are AK data that identify the 

specific location (i.e., X-Y coordinates) of targeted 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 obtained from the WILD database. Also, 

reference ID-C204 provides backup calculations pertaining 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 short, review of these data shows that RFETS 

waste is also the principal component of waste in the Pit 6 area, and references indicate that 

the targeted population is equivalent in terms of waste 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 content, 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 Summaries must provide sufficient 

information to understand the radiological and physical characteristics of waste, including 

but not limited to, changes in targeted materials. 

(4) AK information pertaining to radiological characteristics and waste material parameter 

content of material in Pit 4 was examined. 

As stated previously, EPA learned of the addition of Pit 6 to the AK Summary late in the 

process of evaluating this information. The following analysis was performed for Pit 4, and 

the general observations obtained through this analysis could also apply to Pit 6. 

Pit 4 (ARP-I) Analysis 

As stated in the 2005 INEEL NDA memo for Pit 4, “The overriding limitation concerning the 

radionuclide information presented in the AK Summary Report is that no data has been 

located that quantifies the radionuclides present in 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 waste characteristics of each waste container 

and on its location in the pit, but the specific radionuclide content of each container is not 

available. Instead, the radionuclide content was developed from data on RFETS wastes 

stored at RWMC during the 1970 to 1981 time frame and characterized through various 

programs (e.g., the INEEL 3100m3

 Program). The stored wastes were generated by various 

processes at RFETS that were in use at the time that became part of the Pit 4 area containing 

drummed waste. The key assumption pertinent to these wastes is that they are similar in 

radionuclide composition and concentration to the stored waste. 

 

For RFETS waste, the key documents reviewed when assessing Pit 4 were: 

• ICP/EXT-04-00248, Revision 1 for waste types, volumes, 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 1970s; 

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

project; 

• EDF-4591 (ID-P105), which developed data on each waste type in Pit 4 from 

references (2) and (3). The results of these reviews were compared with the values 

used in the AK Summary Report, Revision 1 (2005). 

As would be expected, these references did not always agree in detail and did not provide 

exact corroboration of the conclusion in the AK Summary Report, Revision 1. The following 

items, however, were noted: 

 
14

• Both ID-P105 and EDF-3374 report identical radionuclide concentrations for1st- and 

2

nd-stage sludges, but the AK Summary Report indicates that only 1st-stage sludge is 

targeted because of higher radionuclide concentrations. This discrepancy was 

explained in Clements (1982): 2nd-stage sludge was handled as a separate category 

when Pit 4 was being filled initially and for a time in the 1970s when waste was being 

shipped to RWMC for storage. Thereafter, both 1st- and 2nd-stage sludges were 

reported as a combined waste type. Clements (1982) clarified that average TRU 

concentrations in 2nd-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 because of their high VOC 

concentrations, but theses sludges also exhibit high TRU concentrations. Both IDP105 and EDF-3374 show average TRU concentrations of >500 nCi/g. Clements 

(1982) lists average TRU concentrations of about 100 nCi/g; 

• Special setups (744-Series sludge) are fixed in a concrete monolith and are not 

targeted. Both Clements (1982) and ID-P105 indicate low concentrations of 

radionuclides in these sludges, but the 39 drums assayed 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 × 109

nCi/drum), but because of the containers’ low net weight the 

TRU concentrations are on the order of several thousand nCi/g; and 

• The Total Curie tabulations in ID-P105 appear inconsistent with the claim in the AK 

Summary Report (Section 5.4.1) that approximately 90% 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 2nd-stage sludge activity from Clements (1982) and the

filter concentrations from EDF-3374 are used the totals become 14,000 Ci targeted 

(65%) and 7,522 Ci non-targeted (35%). This implies the potential that a large 

number of curies remain in Pit 4. 

 

The above discrepancies are not included to show that the projected plan for retrieval is in 

error, but rather to highlight that there is significant uncertainty in predicted radionuclide 

concentrations. Anomalies with respect to radionuclide concentration, distribution, and 

occurrence are expected during routine retrieval operations. As such, EPA believes it is 

important to consider and re-evaluate the radionuclide data on a regular and consistent basis 

and to reconcile this information with the AK record to verify that the radionuclide content in 

waste extracted coincides with expectations. The need 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., roaster oxides. Each newly-generated waste 

drum must contain transuranic radionuclides as specified in the CH-WAC, Appendix E [see 

item (6) below for load management analysis]. Recognizing 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 WIPP. 
15

In addition to RFETS waste, AK Documentation for Pit 4 indicates that this area will also 

contain wastes from several facilities including ANL-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 Pit 4 in Table 4-1 of the AK Summary, 

Revision 1 to be 26,163 ft3

 and indicates that these wastes are not considered “targeted” 

wastes. The relative activities of the INEEL wastes are shown in Table 5-3. These wastes 

contain predominately Ni-63 (78%), Sr-90/Y-90, and Cs-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 states that these wastes may be 

commingled with RFETS waste as part of the waste generating processes, so the information 

was provided to address this contingency. The inclusion 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 assess whether the AK Summary Report 

Revision 1 data were assembled and interpreted properly. For example, the volume totals 

were 26,163 ft3

 in the AK Summary Report Revision 1 and 25,798 ft3 in Table 3 of 

EDF-4478. Most of the differences were in the other-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 mixed debris. The areas being used are not 

identical; a Table 4-1 footnote says only the 1⁄2-acre area is considered while Table 3 says 

“These volumes have been adjusted for disposal shipments that intersect the boundaries of 

the retrieval area.” Regardless, the comparison does indicate that the two documents are in 

relative agreement with respect to waste volume values. 

INEEL waste that may be present in Pit 4 are predominately mixed fission and activation 

products and may not, on their own, meet the criteria 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 radionuclide 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 Appendix D of EDF-4591 for each container 

disposed in Pit 4. This total was 27.149 Ci (a review of this table indicated about 25 Ci but 

there were legibility problems with the Table). These activity levels were decayed to 2005, 

so the calculations are valid. However, values from Table F-4 of Appendix F in INTECP0001 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. Because 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 confirm AK as Pit 4 is excavated, including 

continually documenting the information on appropriate reconciliation and comparison 

forms. 
16

Summary 

The AK record has relied on the assumption that isotopic 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 generating process may include nonRFETS waste (described as incidental by CCP), the usefulness 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” radionuclides. 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 respect 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 performed. It is worth noting that the AK 

Summaries document the type of materials added to Pits 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 location were evaluated. 

Because EPA became aware of the addition of Pit 6 to the AK Summary late in the 

evaluation process, the following analysis was limited to AK and Load Management for Pit 4 

wastes. However, EPA expects that the general observations 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 of 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 for TRU waste disposal at the same time. 

Volume comparisons were made with two reports referenced in Table 4-1, ID-U292 and 

ID-P109. These two sources showed good agreement for those waste types where volumes 

could be compared, e.g., ID-P109 listed debris waste 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 from the values cited in ID-U292 and 

ID-P109. Specific examples of these differences include the following: 

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

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

• Roaster oxide volumes were greater in the AK Summary Report by 17.5%. 

• Graphite waste volume in the AK Summary Report Revision 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 known, although some degree of variability is 

expected. One possible outcome of uncertain volumes 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-targeted waste (including non-defense or nonTRU waste) could become commingled with WIPP-eligible waste. Due to the lack of a 

clearly defined disposal path for certain wastes (roaster 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 individual waste containers in Pit 4 and 

were evaluated to determine agreement, as well as to assess the degree of commingling that 

might be present between targeted waste, non-targeted waste, non-defense waste, and nonTRU waste. The ID-U292 report provides summary totals 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 examined 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 grid 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 total volumes of each waste category shown 

in ID-U292 and in ID-P103. These discrepancies differ 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 categories 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, the stated volumes are much different 

(15,756 ft3

 combustible waste in ID-U292 compared to 38,250 ft3in ID-P103; and 54,869 ft3

of metal and non-metal in ID-U292 versus 50,600 ft3

 of non-combustible waste in ID-P103). 

The AK Summary Report uses the value of 28,849 ft3

 for combustible debris and 68,158 ft3

for metal and non-metal debris. The lack of differentiation between RF and non-RF debris 

waste is unfortunate because much of the non-RF debris is probably either non-TRU or nondefense waste. However, the performance of VE on all waste containers during loading as 

well as NDA of each container will help determine radionuclide 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 wastes (i.e., they contain >100nCi/g 

of alpha-emitting transuranic radionuclides, and are eligible for disposal at WIPP) will be 

made by measurement using NDA systems. Our understanding is that Pit 4 and Pit 6 wastes 

containing <100nCi/g will not be prepared for disposal at WIPP by load management. If INL 

determines it will use load management for these wastes, the appropriate notification and 

documentation, as stipulated in the CH-WAC Attachment E, is required. 
18

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

The AK Summary Reports Revisions 1 and 2 were assessed with respect to the defense 

origin of these wastes. CCP contends that an assessment of the defense nature of the waste is 

not necessary since most of the waste and all of the targeted waste is from RFETS. The AK 

Summary Reports acknowledge that some non-RFETS waste may be from non-defense 

activities but “much of the wastes are commingled due 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-defense 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 defense-related wastes, specifically 

those from ANL-W, Test Area North (TAN), Advanced Reactor Area (ARA), and the Power 

Excursion Reactor (PER). Although not specified, additional sources may also be present in 

Pit 6, but the AK Summary Report, Revision 2 was not written to differentiate between Pit 4 

and Pit 6 sources. 

When the AK Summary Report is revised more detail on the amount of non-defense waste 

that may be in Pit 4 and Pit 6 would be useful since 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 cell 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 thus 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 suggest that identification and segregation of nondefense 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 personnel. The memo is used to 

communicate AK data information and limitations, and 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. Comments on each memo are provided 

below. 

AK- NDA Memo, April 22, 2005 

This memo addresses how NDA personnel use AK, but includes several typographical and 

minor technical errors that make the use of the memo 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 3100m3

waste analysis, and that “it is not possible to adequately 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 the correct table for U-235 data. 

• An uncertainty value of 50% is applied to calculated U-234 values, and while this is 

consistent with previously approved memos by EPA, justification 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 materials originated from RFETS 

and when these materials are encountered the specified distributions, i.e., Weapons 

Grade Pu isotopics, will be appropriate. However, the memo does not adequately 

address how the isotopic distribution will be assessed when TRU wastes that are not 

RFETS based are encountered. 

• Several sources of interference are identified. EPA 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, additional waste may be present that affect the 

isotopic distribution. The RFETS distributions should be sufficient if targeting is successful, 

but neither memo indicates how “commingled” waste would be addressed if container 

measurement via NDA is not successful. An explanation for this possibility in the March 29, 

2006, AK-NDA memo is desirable when the memo is revised. 

(9) AK Accuracy was evaluated, including reassignment of wastes to different waste streams 

from Pit 4.

An AK Accuracy report was not provided by CCP for Pit 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 creates 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