DOCKET NO: A-98-49, II-A4-104 

WASTE CHARACTERIZATION INSPECTION REPORT 

FINAL APPROVAL 

EPA BASELINE INSPECTION NO. EPA-SRS-CCP-RH-07.07-8 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION 

PROGRAM FOR BATTELLE COLUMBUS LABORATORIES DECOMMISSIONING 

PROJECT WASTES STORED AT THE SAVANNAH RIVER SITE 

July - December, 2007 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

August 2008
i 

TABLE OF CONTENTS 

Section Page

Acronyms .......................................................................................................................................iii 

1.0 Executive Summary ............................................................................................................ 1 

2.0 Purpose of Inspection.......................................................................................................... 3 

3.0 Purpose of this Report......................................................................................................... 4 

4.0 Scope of Inspection ............................................................................................................. 5 

5.0 Inspection-Related Definitions............................................................................................ 6 

6.0 Personnel ............................................................................................................................. 6 

6.1 EPA Inspection Team.............................................................................................. 6 

6.2 Personnel Contacted................................................................................................ 7 

7.0 Performance of the Inspection............................................................................................. 7 

8.0 Technical Evaluation........................................................................................................... 8 

8.1 Acceptable Knowledge Process Overview and Analysis...................................... 20 

8.2 Radiological Characterization............................................................................... 32 

8.3 Physical Form and Prohibited Item Characterization – Visual Examination........ 46 

8.4 WIPP Waste Information System ......................................................................... 48 

8.5 Attainment of Data Quality Objectives................................................................. 49 

9.0 Response to Comments ..................................................................................................... 50 

10.0 Conclusions ....................................................................................................................... 52 

Baseline Approval............................................................................................................. 52 

11.0 References ......................................................................................................................... 53 

ATTACHMENTS 

Attachment A EPA Inspection Issue Tracking Form,

EPA Issue No. SRS-CCP-RH-AK-07-001F ................................................... 61 
ii 

LIST OF TABLES 

Table 1. EPA Inspection Team Members ...................................................................................... 6 

Table 2. Personnel Contacted during Inspection............................................................................ 7 

Table 3. Details of EPA Finding No. SRS-RH-K-07-001F ......................................................... 22 

Table 4. Summary of the Reported Radionuclides in the 69 Smear Samples.............................. 34 

Table 5. Radionuclide Scaling Factors......................................................................................... 39 

Table 6. Overall Uncertainty Listed by Radionuclide at a Density of 1.0 g/cm3

......................... 44 

LIST OF FIGURES 

Figure 1. Configuration and Dimensions of a 55-Gallon Drum TRU RH Liner ......................... 10 

Figure 2. Comparison of Scaling Factors Representative of Different Fuel Types Against 

Average Smear Sample Scaling Factors....................................................................... 36 

Figure 3. DTC Correlations as a Function of Waste Density at a Distance of 1 meter 

Centered on a RH TRU Drum Liner ............................................................................ 40 

Figure 4. Example Waste Drum DTC Conversion Record.......................................................... 41 
iii 

ACRONYMS 

AK acceptable knowledge 

AKE acceptable knowledge expert 

Am americium 

ANLE Argonne National Laboratory-East 

ANSI American National Standards Institute 

Ba barium 

BC Battelle Columbus 

BCL Battelle Columbus Laboratory 

BCLDP Battelle Columbus Laboratory Decommissioning Project 

BDR batch data report 

BMI Battelle Memorial Institute 

CAR Corrective Action Report 

CBFO Carlsbad Area Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations

CH contact-handled 

CH-TRAMPAC Contact-Handled Transuranic Waste Authorized Methods for Payload Control 

Ci curie 

Ci/Ci curies per curie 

Ci/L curies per liter 

Cm curium 

Co cobalt 

CPR cellulose, plastic, and rubber 

CRR Characterization Reconciliation Report 

Cs cesium 

CTAC Carlsbad Technical Assistance Contractor 

CTP Confirmatory Test Plan 

D&D decontamination and decommissioning 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 
iv 

DTC dose-to-curie 

EPA U.S. Environmental Protection Agency 

FGE fissile gram equivalent 

FR Federal Register 

Eu europium 

g gram 

g/cm3

 grams per cubic centimeter 

HCL Hot Cell Laboratory 

HEU highly enriched uranium 

HLW high-level waste 

INL Idaho National Laboratory 

kg kilogram 

LANL Los Alamos National Laboratory 

LLD lower limit of detection 

LWA Land Withdrawal Act

LWR light-water reactor 

m

3

 cubic meter 

MDA minimum detectable activity 

mR/hr milli Roentgen per hour 

mrem/hr millirem per hour 

MSDS material safety data sheets 

N/A not applicable 

nCi/g nanocurie per gram 

NCR non-conformance report 

NDE non-destructive examination 

Np neptunium 

ORIA Office of Radiation and Indoor Air 

PE Ci plutonium equivalent curie 

PTS Project Tracking System 

Pu plutonium 

QA quality assurance 

QAO quality assurance objective 

QAPD quality assurance program description 
v 

R/hr/Ci Roentgen per hour per curie 

RCRA Resource Conservation and Recovery Act 

RH remote-handled 

RIDS Record Inventory and Disposition System 

RTR real-time radiography 

Sb antimony 

SCG Summary Category Group 

SNF spent nuclear fuel 

SPM Site Project Manager 

Sr strontium 

SRS Savannah River Site 

Th thorium 

T1 Tier 1 

T2 Tier 2 

TBD to be determined 

TMU total measurement uncertainty 

TRU transuranic 

U uranium 

VE visual examination 

VEE visual examination expert 

WAC waste acceptance criteria 

WC waste characterization 

WCO Waste Certification Official 

WCPIP Waste Characterization Program Implementation Program 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF Waste Stream Profile Form 

WWIS WIPP Waste Information System 

Y yttrium
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1.0 EXECUTIVE SUMMARY 

In accordance with Title 40, Part 194.8(b), of the Code of Federal Regulations

[40 CFR 194.8(b)], the U.S. Environmental Protection Agency (EPA or the Agency) conducted 

Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 of the Central Characterization Project’s 

(CCP) waste characterization (WC) program for remote-handled (RH) transuranic (TRU) waste 

at the U.S. Department of Energy’s (DOE) Savannah River Site (SRS) located in Aiken, South 

Carolina. The waste characterized by the SRS-CCP is RH debris waste from the 

decommissioning of a hot cell laboratory at the Battelle Columbus Laboratory (BCL) that was 

shipped to SRS for characterization and disposal at the Waste Isolation Pilot Plant (WIPP). EPA 

conducted a baseline inspection of SRS-CCP’s program to characterize this waste in the 

Washington Group’s office in Denver, Colorado, on July 17–19, 2007 and at the DOE’s 

Carlsbad Area Field Office (CBFO) in Carlsbad, New Mexico, on July 31–August 2, 2007 and 

December 4–5, 2007. 

The RH waste from Battelle Columbus Laboratory Decommissioning Project (BCLDP) is 

packaged in 87 drum liners1

 and is in interim storage at SRS. SRS-CCP characterized this waste 

by implementing the WC activities discussed in this report and demonstrating compliance with 

40 CFR §194.24. SRS-CCP used the historical BCLDP-generated data to develop acceptable 

knowledge (AK) records. EPA’s baseline inspection’s sole focus was to evaluate the AK records 

that had been assembled to document RH TRU WC activities, including recently performed 

modeling, interpretation, and additional calculations based on previously generated measurement 

data for BCLDP RH debris Waste Stream SR-RL-BCLDP.001. 

On May 21, 2008, EPA issued a Federal Register (FR) notice proposing to approve BCL’s TRU 

RH debris wastes for disposal at WIPP that were characterized using the CCP-implemented RH 

waste characterization processes (see 73 FR 28504–29507). In response to the proposed 

approval, EPA received one comment that is docketed in EPA Air Docket ID EPA-HQ-OAR2008-0410 and which is included verbatim in Section 9 of this report, along with EPA’s 

response. This comment objected to the requirement for a new baseline inspection and approval 

of any non-BCLDP RH waste that SRS-CCP would characterize for disposal at WIPP. Upon 

considering and responding to the comment, EPA is finalizing the proposed retrospective 

approval of RH TRU debris waste for the disposal at WIPP. In addition, EPA approves the RH 

TRU waste characterization processes discussed in this report that SRS-CCP implemented and 

EPA evaluated for technical adequacy. No additional RH debris waste from this BCLDP waste 

stream, i.e., no wastes other than the 87 drum liners discussed in this report, is approved for 

WIPP disposal. Additionally, following this approval, any non-debris RH waste from BCLDP 

that SRS-CCP wishes to characterize using the approved WC activities discussed in this report 

will require EPA approval as a Tier 1 (T1) change. 

When proposing to approve the RH TRU WC processes discussed in the May 2008 baseline 

inspection report, EPA stated that if SRS-CCP embarks on characterizing RH wastes for WIPP 

disposal other than those generated at BCLDP, a separate baseline inspection and approval will 

 

1

 A liner is a 55-gallon rigid steel liner that fits within a standard 55-gallon drum and acts as an overpack. 

Specifications for drum liners are provided in Section 8, and are shown in Figure 1. 
2 

be necessary. That is, any SRS RH waste destined for WIPP disposal that is characterized by 

SRS-CCP or another program remains subject to EPA’s baseline inspection and approval. 

EPA must verify compliance with 40 CFR 194.24 before waste may be disposed of at the WIPP, 

as specified in Condition 3 of the Agency’s certification of the WIPP’s compliance with disposal 

regulations for TRU radioactive waste (63 Federal Register (FR) 27354 and 27405, May 18, 

1998). EPA Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 was performed in accordance 

with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, 

No. 136, pp. 42571–42583). The purpose of the SRS-CCP RH WC inspection was to evaluate 

the adequacy of the site’s WC programs for 87 drum liners in a single RH debris waste stream 

for disposal at the WIPP. The 87 drum liners of RH debris in this waste stream were generated 

from the decontamination and decommissioning (D&D) of the Building JN-1 Hot Cell 

Laboratory (HCL) at the West Jefferson North facility, which operated under the BCLDP from 

1955 until D&D began in 1988. 

EPA is finalizing the proposed approval of the following WC activities: 

(1) The AK process for the 87 drum liners of RH retrievably stored TRU debris in the waste 

stream designated as Waste Stream SRS-RL-BCLDP.001 currently stored at the TRU 

storage pads in the E Area of SRS. 

(2) The radiological characterization process using dose-to-curie (DTC) and modelingderived scaling factors, supported by radionuclide data from the analysis of 69 swipe 

samples, for assigning radionuclide values to 87 drum liners of RH retrievably stored 

TRU debris in one waste stream, designated as SRS-RL-BCLDP.001, that is documented 

in CCP-AK-LANL-501, Revision 2, and detailed in this report. 

(3) The visual examination (VE) process to identify waste material parameters and the 

physical form of the waste. 

(4) The WIPP Waste Information System (WWIS) to submit both characterization and 

certification data for RH TRU waste. 

(5) The attainment of pertinent data quality objectives (DQOs). 

Since no additional WC activities are expected to occur relative to the 87 drum liners of RH 

debris waste, changes to the WC activities evaluated during the baseline inspection are not 

anticipated. EPA, therefore, does not expect SRS-CCP to make additional revisions to the 

documents that were reviewed as part of the baseline inspection and this approval is limited to 

the WC processes specific to the 87 drum liners that were evaluated in July, August, and 

December 2007. In the event that SRS-CCP makes changes to the EPA-approved WC 

components discussed in this report and implements them to characterize additional waste from 

the BCLDP activity (e.g., solids or soil/gravel) associated with D&D activities at Building JN-1 

at the BCL, EPA will consider changes that have the potential to affect WC activities to be T1 

changes, as stated above. This report does not list specific T1 or Tier 2 (T2) designations 

relative to these 87 drum liners containing RH TRU debris waste from BCLDP and the WC 

components approved at this time. SRS-CCP, however, must provide to EPA a copy of the 
3 

WWIS controlled spreadsheet showing the manual data entries that were downloaded from CCPAK-SRS-501 upon completion as a one-time T2 change.

As experienced at the other RH waste sites, WC activities implemented under the CCP program 

are customized to site-specific RH waste streams. The applicability of RH WC techniques at one 

site to RH wastes at other sites is such that significant modifications may be required to 

individual WC components, and the process of developing documentation or objective evidence 

is site-specific (see Section 9 for further discussion). As stated in Section 9.0, should SRS-CCP 

request approval of any non-BCL RH waste generated at SRS or waste brought to SRS for 

characterization, a new baseline inspection will be necessary. 

2.0 PURPOSE OF INSPECTION 

On May 18, 1998, EPA certified that the WIPP will comply with the radioactive waste disposal 

regulations in 40 CFR Part 191. In this certification, EPA also included Condition 3, which 

states that “the Secretary shall not allow shipment of any waste from...any waste generator site 

other than LANL for disposal at the WIPP until the Agency has approved the processes for 

characterizing those waste streams for shipment using the process set forth in §194.8.” The 

approval process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information 

on AK2

 for waste streams proposed for disposal at the WIPP, and (2) implement a system of 

controls used to confirm that the total amount of each waste component that will be emplaced in 

the WIPP will not exceed limits identified in the WIPP Compliance Certification Application. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must 

perform a baseline inspection of a TRU waste generator site’s WC program. 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 on-site inspection to verify that the 

site’s system of controls is technically adequate and properly implemented. Specifically, EPA’s 

inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the following: 

Any compliance application shall: . . . Provide information which demonstrates 

that a system of controls has been and will continue to be implemented to confirm 

that the total amount of each waste component that will be emplaced in the 

disposal system will not exceed the upper limiting value or fall below the lower 

limiting value described in the introductory text of paragraph (c) of this section.3

 

2

 As of the FR notice of July 16, 2004, EPA has replaced the term process knowledge with acceptable 

knowledge. Acceptable knowledge refers to any information about the process used to generate waste, material 

inputs to the process, and the time period during which the wastes were generated, as well as data resulting from the 

analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA 

certification decision to show compliance with Condition 3 of the certification decision. 

3

 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant 

to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of 

mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting 

value, of the total inventory of such waste proposed for disposal in the disposal system.” 
4 

The system of controls shall include, but shall not be limited to: Measurement; 

sampling; chain of custody records; record keeping systems; waste loading 

schemes used; and other documentation. 

In other words, the purpose of the baseline inspection is to implement the requirements of 

40 CFR 194 by assessing whether DOE sites that characterize TRU waste prior to disposal at the 

WIPP are capable of characterizing and tracking the waste. EPA may also conduct follow-up 

inspections to address issues remaining from the baseline inspection or to seek further 

clarification/discussion related to WC processes evaluated during a baseline inspection. By 

approving the WC systems and processes at SRS-CCP that were applied to the 87 drum liners of 

retrievably stored RH debris waste, EPA confirms that the Agency has evaluated the capabilities 

of systems and processes implemented by the site to accomplish two tasks: (1) the identification 

and measurement of waste components that must be tracked for compliance such as plutonium,4

and (2) the confirmation that the waste in any given container has been properly identified as 

belonging to the group of approved waste streams. 

Based on the adequacies of the WC processes demonstrated during the baseline inspection, 

including all conditions and limitations, EPA usually specifies which subsequent WC program 

changes or modifications must undergo further EPA inspection or approval under 

40 CFR 194.24. This is accomplished by assigning a tier level to each aspect of the 

characterization program, i.e., T1 and T2 activities. However, the nature of the WC activities at 

SRS-CCP is such that no additional characterization activities are anticipated, making a 

prospectively orientated T1 or T2 assignment irrelevant. Accordingly, no formal tiering is 

finalized for the SRS-CCP RH WC program at this time. As stated previously, EPA’s approval 

is limited to the 87 drum liners of RH TRU wastes whose characterization is documented in the 

records evaluated during the inspection and detailed in this report. Should SRS-CCP seek to 

characterize additional RH wastes from BCLDP for disposal at WIPP, such wastes would be 

considered a T1 activity and would be addressed accordingly. The rule applying to this baseline 

inspection can be found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004). EPA 

does not expect to conduct additional SRS-CCP RH waste inspections specific to this waste 

stream in the future. If SRS-CCP characterizes RH wastes that do not originate at BCLDP for 

WIPP disposal, a new EPA baseline inspection and approval will be necessary under the 

authority of 40 CFR 194.8. 

3.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s approval decision and explains the results of Baseline 

Inspection No. EPA-SRS-CCP-RH-07.07-8 in terms of findings or concerns. Specifically, this 

report does the following: 

 

4 The potential contents of a single waste stream or group of waste streams determine which processes can 

adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous, the site should 

select the matrix-appropriate radiological characterization technique to obtain adequate radionuclide measurements. 

VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the 

nature of the waste has been confirmed, characterization techniques quantify selected radionuclides in the waste. In 

some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste streams or only 

a few. A site’s stated limits on the applicability of proposed WC processes govern the scope of EPA’s inspection.
5 

• Describes the characterization systems SRS-CCP submitted for approval 

• Delineates a specific set of RH wastes submitted for approval 

• Provides objective evidence as basis for the approval of all WC systems and/or waste 

containers 

• Identifies all relevant limitations and or conditions for each WC system and/or waste 

container 

• Provides objective evidence of outstanding findings or concerns in the form of 

documentation, as applicable 

• Describes any tests or demonstrations completed during the course of the inspection and 

their relevance to EPA’s approval decision, as applicable 

The listings in each section reference the documents that the EPA inspection team members 

reviewed in support of the technical determination. To see or obtain copies of any items 

identified in the attached checklists, write to the following address: 

Quality Assurance Manager 

USDOE/Carlsbad Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s final approval decision regarding the SRS-CCP RH WC program is conveyed to DOE 

separately by letter. In accordance with 40 CFR 194.8(b)(3), this information is also available on 

EPA’s Web site at http://www.epa.gov/radiation/WIPP. 

4.0 SCOPE OF INSPECTION 

The scope of Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 included the technical 

adequacy of the WC systems used by SRS-CCP to characterize 87 drum liners of RH TRU 

wastes in SRS RH Waste Stream SR-RL-BCLDP.001. At the start of the inspection, SRS-CCP 

presented the number of drums in Waste Stream SRS-RL-BCLDP.001 as 88. However, SRSCCP determined that one of these drums did not meet the definition of TRU waste and it was 

removed from the waste stream directly prior to the inspection, leaving a total of 87 drums 

within the inspection’s scope. The basis for all radiological and physical waste characterization 

of these 87 drums was AK, and included the identification and quantification of the 10 WIPPtracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U). 

Accordingly, the inspection’s scope consisted of reviewing records of WC activities that had 

been performed previously in conjunction with the BCLDP, supplemented by data interpretation 

and manipulation, and the development and application of conceptual models related to WC 

performed more recently by SRS-CCP. 

During an inspection, EPA does not approve characterization data; that function is the sole 

responsibility of the site being evaluated during the inspection, in this case SRS-CCP. EPA 

evaluated records that documented the technical aspects of the WC processes implemented by 

SRS-CCP to characterize 87 drum liners of RH retrievably stored debris waste that were 
6 

conducted during the BCLDP. These records included more recent compilations of older 

information, as well as newer interpretations of, and additional calculations to, older 

measurement data. The evaluation consisted of interviewing personnel and inspecting records 

related to the WC processes within the inspection’s scope. An important aspect of this 

evaluation is the objective evidence that documents the effectiveness of the WC processes. 

Objective evidence typically takes the form of BDRs for radiological characterization and AK 

accuracy reports. EPA typically selects samples of each of these items based on the number and 

variety of items that were completed and available for inspecting each WC process, consistent 

with standard sampling techniques. However, because the WC activities for these BCLDP RH 

wastes are not ongoing, BDRs were not prepared. Accordingly, EPA evaluated records 

associated with the characterization of an appropriate sample of the 87 drum liners. EPA 

examined WC information that was provided within specific SRS-CCP reports that were the 

equivalent of what is typically contained in BDRs. Based on an evaluation of the WC processes 

documented in the SRS RH records, EPA determined the technical adequacy of the WC 

processes within the inspection’s scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

During the course of an inspection, EPA inspectors may encounter items or activities that require 

further inquiry for their potential to adversely affect WC and/or isolation within the repository. 

The two main categories relevant to WC inspections are identified below: 

Finding: A determination that a specific item or activity does not conform to 

40 CFR 194.24(c)(4). A finding requires a response from CBFO. 

Concern: A judgment that a specific item or activity may or may not have a negative effect on 

compliance and, depending on the magnitude of the issue, may or may not require a 

response. (Concerns not requiring a response do not have to be addressed prior to 

program approval.) 

6.0 PERSONNEL 

6.1 EPA Inspection Team 

The members of the EPA WC inspection team are identified in Table 1. 

Table 1. EPA Inspection Team Members 

Inspection Team Member Position Affiliation

Ms. Rajani Joglekar Inspection Team Leader U.S. EPA ORIA 

Mr. Ed Feltcorn Inspector U.S. EPA ORIA 

Ms. Connie Walker Inspector S. Cohen & Associates, Inc. 

Ms. Dorothy Gill Inspector S. Cohen & Associates, Inc. 

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc. 
7 

6.2 Personnel Contacted 

EPA and its support personnel conducted interviews with SRS-CCP personnel in several 

disciplines on several occasions. The personnel contacted represented a sample of the SRS-CCP 

WC staff, and they are listed in Table 2, along with their affiliation and technical area. This 

listing is comprehensive and includes personnel present at all meetings conducted as part of this 

baseline inspection. 

Table 2. Personnel Contacted during Inspection 

Personnel Affiliation Area of Expertise 

Rob Tayloe CCP AK/DTC; Scaling Factors 

Jene Vance CCP AK/DTC; Scaling Factors 

Keith Meger CCP AK/DTC; Scaling Factors

Eric D’Amico CCP RH SPM 

Larry Porter CCP AK, RH SPM; Scaling Factors 

Steve Schafer CCP AK, AKE 

Kevin Peters CCP AK, AKE 

Mark Doherty CCP DTC & Scaling Factors-MS Data 

J.R. Stroble DOE/CBFO RH TRU Waste Certification Manager 

Irene Quintana CCP RH SPM 

Charlie Riggs CTAC Observer 

Porf Martinez CTAC Observer 

7.0 PERFORMANCE OF THE INSPECTION 

Background and History: Battelle Columbus and Savannah River Site

The RH debris waste that is the focus of this inspection came from the West Jefferson North Site, 

which is part of Battelle Memorial Institute (BMI), located near West Jefferson, Ohio, 

approximately 15 miles west of the main BMI King Avenue facility in Columbus, Ohio. BMI 

had supported the first large-scale military application of nuclear power through development of 

fuel element/assemblies design and materials. The West Jefferson North Site’s focus was 

research in the areas of reactor fuel, control rod, and structural material studies. Since operations 

began in the JN-1 HCL in 1955, a variety of studies relating to the radiation performance of 

materials were conducted in the remote-handling facilities in Building JN-1. Experiments in the 

JN-1 HCL consisted primarily of reactor fuel studies that evaluated uranium, thorium, and 

plutonium alloys and compounds; control rod material studies of rare-earth absorbers; and 

evaluations of structural and cladding material. Remedial D&D activities of the West Jefferson 

North Site facilities began in 1988 under the BCLDP for the purpose of decontaminating the 

buildings and associated grounds such that they would be suitable for unrestricted use. Battelle 

completed the BCLDP D&D program with the final shipments of these RH TRU waste to SRS in 

December 2005 where they are currently stored on the TRU Pad in E Area of SRS. SRS-CCP 

did not perform any actual characterizations relative to these wastes, but instead was using the 

BCLDP-generated data to develop AK records that support the WC activities for these 87 RH 

drums. Accordingly, it was not necessary to conduct this baseline inspection at SRS, and EPA 
8 

conducted the review of AK records and discussions with SRS-CCP personnel in Denver, 

Colorado. Additionally, EPA decided to evaluate the non-destructive examination (NDE) and 

the WWIS in CCP’s Carlsbad office for logistical reasons. 

Inspection Process Overview

EPA Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 had the scope described in Section 4.0 

above, for the purpose of determining the site’s compliance with 40 CFR 194.24. The inspection 

was conducted in the following steps: 

(1) Obtaining and reviewing site procedures, reports, and other technical information related to 

RH WC activities previously used to characterize these wastes at BCLDP 

(2) Preparing technical questions specific to the various aspects of AK prior to the inspection 

based on the activities cited in the previous bullet 

(3) Interacting with CBFO and SRS-CCP personnel to arrange inspection logistics 

(4) Evaluating SRS-CCP’s implementation of WC processes for adequacy and demonstrating 

compliance with 40 CFR 194.24 requirements, as evidenced by the records of the WC 

activities previously conducted at BCLDP 

(5) Conducting the baseline inspection in Denver to verify the technical adequacy and/or 

qualifications of RH WC personnel, procedures, processes, and equipment, as evidenced by 

the records of the WC activities previously conducted at BCLDP 

(6) Recording one finding on an EPA Inspection Issue Tracking Form, which was completed 

and provided to CBFO and SRS-CCP personnel as it was generated (see Attachment A for 

a copy of this form) 

(7) Communicating with CBFO and SRS-CCP personnel regarding pertinent information 

(8) Pursuing resolution of all identified issues prior to completion of the inspection, when 

feasible 

(9) Conducting entrance, exit, and daily briefings for CBFO and SRS-CCP management 

personnel 

(10) Obtaining and reviewing SRS-CCP documents that were revised in response to the EPA 

finding after the inspection 

(11) Conducting additional meetings with SRS-CCP personnel to discuss the revised documents 

and examine objective evidence for the purpose of addressing the technical issues 

identified in the finding 

(12) Issuing the inspection report and approval 

8.0 TECHNICAL EVALUATION 

EPA examined the AK process and associated information to determine whether the SRS-CCP 

RH program for characterizing Waste Stream SR-RL-BCLDP.001 from the BCLDP 

demonstrated compliance with the requirements of 40 CFR 194.8. Due to the approach taken by 
9 

SRS-CCP BCLDP, all WC activities relative to the 87 drum liners in this waste stream fall under 

the general heading of AK. In this report, AK is divided into five sections: 

• 8.1, Acceptable Knowledge Overview and Process Analysis 

• 8.2, Radiological Characterization 

• 8.3, Physical Form and Prohibited Item Characterization – Visual Examination 

• 8.4, WIPP Waste Information System 

• 8.5, Attainment of Data Quality Objectives 

This report format differs from the format that EPA generally uses for baseline inspection 

reports, where there are multiple sections named for each WC process, i.e., AK, NDA, NDE, and 

WWIS. Such a format reflects that the WC activities evaluated during the inspection are 

ongoing and are expected to continue upon approval of the site’s WC program. The nature of the 

SRS-CCP program is different in that all WC activities have occurred and there are no further 

ongoing WC activities upon approval. The basis for all WC activities consists of records of 

previously conducted activities, and accordingly, all this information is considered AK. 

However, the actual information may consist of examinations of the waste using both NDA and 

NDE, in addition to historical information regarding the waste’s nature and origin. 

Waste Containers

All BCLDP wastes were loaded into 55-gallon steel drum liners (a rigid liner that essentially fits 

within a 55-gallon drum which acts as overpack). Once the liners were full, lids were installed 

and the liners were transferred into U.S. Department of Transportation (DOT)-approved 

containers. This report uses the term RH drum liner or waste liner, which requires clarification. 

Any use of the term liner in this report means a steel container that fits inside a standard 

55-gallon drum. Each liner has the following dimensions: 0.105 inch thick, 32.250" high, with 

an outer diameter of 22" and an inner diameter of 19.5", as shown in Figure 1. Each liner was 

sealed once it was full of waste, and 82 of the sealed liners were transferred to DOT-approved, 

UN/1A2/X400/S/99 55-gallon drums equipped with Nucfil-013 filters (vented). Five additional 

steel liners were loaded directly into two 72-B RH TRU canisters; three in one canister and two 

in the other canister. The total waste stream population consists of these 87 drum liners referred 

to throughout this report. In some cases, this report cites objective evidence (i.e., BCLDP or 

SRS-CCP reports) that uses the terms waste container or waste drum, both of which are 

synonymous with the term liner. 
10 

Figure 1. Configuration and Dimensions of a 55-Gallon Drum TRU RH Liner 
11 

Waste Origin and Generation

The RH debris in this waste stream was generated from the D&D of Building JN-1 in the West 

Jefferson North Site of BCL in Columbus, Ohio.5

 The JN-1 HCL was dedicated to reactor fuel 

research and material evaluation in support of DOE and other federal agencies. Remedial 

activities of the West Jefferson North facilities began in 1988 under the BCLDP and continued 

until the final shipment of BCLDP D&D wastes to SRS was made in December 2005. The 

BCLDP generated a total of 135 55-gallon drums [approximately 29 cubic meters (m3

)] of RH 

wastes, 48 of which are not within the scope of this inspection and are currently stored at DOE’s 

Hanford Site in Richland, Washington.6

 The remaining 87 drums of waste that are the subject of 

this inspection are composed of 82 individual 55-gallon drums and 5 additional 55-gallon drums 

that are contained in two 72B RH Casks, 3 drums in 1 cask and 2 drums in the other cask, all of 

which are currently stored at the TRU Storage Pad in E Area of SRS. The waste components 

include cellulosics, plastic, rubber, glass, and metal, and less than 50% by volume in any one 

container consists of homogeneous organic and inorganic materials. Radionuclide components 

of the waste include 241Am, 238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 234U, 235U, 238U, 137Cs, and 60Co. The 

scope of this inspection was the 87 drum liners of RH wastes currently stored at SRS and does 

not include the 47 additional 55-gallon drums of BCLDP wastes that are in storage at Hanford. 

The approval of additional BCLDP drum liners at Hanford or any other location will require a 

separate baseline inspection at such time that the site decides to characterize these wastes for 

disposal at WIPP. The wastes to which this approval applies are discussed in this report and 

were generated by the BCLDP. The fact that these wastes are stored at SRS has no bearing on 

characterization activities performed on any other contact-handled (CH) or RH TRU materials at 

SRS or any other DOE site. Should DOE notify EPA that there are additional containers of RH 

TRU wastes from the BCLDP for disposal at WIPP apart from the 87 liners discussed in this 

report, EPA would address the situation as a T1 change, as discussed previously. However, such 

an option would apply only to BCLDP wastes (such as solids or soil/gravel) that have waste 

generation and WC elements in common with the 87 liners described in this report. 

Waste Characterization Overview

Acceptable knowledge provides the basis for all radiological and physical WC information. In 

the case of this specific SRS RH waste stream, wastes were grouped using AK into a debris 

waste stream of 87 drum liners generated through D&D of the JN-1 HCL. As part of the 

inspection, EPA reviewed the following with respect to the use of AK for WC: 

• Waste stream definition and identification, including radiological content 

• Identification of TRU versus non-TRU wastes, i.e., high-level waste (HLW) and spent 

nuclear fuel (SNF) 

 

5

 The West Jefferson North Site included: Building JN-2 (Critical Assembly Laboratory); Building JN-3 

(Research Reactor Building); and Building JN-4 (Plutonium Laboratory). This waste stream only includes wastes 

from JN-1. 

6

 Forty seven of these drums are stored at Hanford and the one drum that SRS-CCP excluded from this waste 

prior to this inspection is stored at SRS. 
12 

• Identification and quantification of the waste’s radionuclide content, including 

uncertainty 

• Defense waste status 

• Waste Material Parameters (WMP) 

• Assignment of waste matrix codes (WMC) 

• Role of AK in the characterization methodology, with the determination of quality 

assurance (QA) equivalency (addressed outside of this report), peer review, or 

confirmation via modeling used as verification techniques 

• Compilation of AK documentation and assembly of required information 

• Adequacy of the Waste Characterization Program Implementation Plan (WCPIP) AK 

process implementation and AK summary report 

• AK data traceability for all drums and containers used in the process from data assembly 

through confirmatory modeling 

• AK source document sufficiency 

• WCPIP interpretation with respect to AK qualification 

• Confirmatory Test Plan (CTP) preparation and plan adequacy 

• Characterization Reconciliation Report (CRR) preparation and report adequacy 

• Correlation and Surrogate Summary Form and CH-RH correlation 

• Personnel training 

• AK discrepancy resolution (DR) 

• AK accuracy 

• Implementation of load management 

• Physical form and prohibited item characterization using VE 

• WWIS 

• Identification of the method for determining DQOs, including those to be attained by AK 

qualification 

Waste Stream SR-RL-BCLDP.001 has been characterized by AK that was qualified through a 

determination of QA equivalency (not addressed in this report). Because the characterization 

process is based solely on AK records and the various methods used to verify AK exclusive of 

confirmatory testing, the entire inspection was based on reviewing documents of activities that 

had been completed prior to the inspection. BDRs were not prepared to meet WCPIP 

requirements, and observations of procedural implementation could not be made because all 

characterization activities had been completed prior to the inspection. No further testing or 

characterization of the 87 drum liners will be performed. 
13 

Radiological information available for this waste stream includes the radiochemical analytical 

results of 69 swipe7

 samples taken at various locations within JN-1, as well as a memorandum 

presenting 235U enrichment, burn-up, and decay for light-water reactor (LWR) fuel pins. 

External exposure rate (dose rate)8

 measurements were taken at the time of packaging for all 

drum liners. The determination of several DQOs was achieved through use of radionuclidespecific scaling factors and isotopic distributions that were applied to dose rate data derived by 

applying the DTC technique for each drum liner. The scaling factors were derived using 

ORIGEN2.29

 modeling with input based on attributes of LWR fuels that were assumed to 

contribute the majority of the waste stream’s radionuclide content. Radionuclide data from the 

analysis of swipe samples taken throughout the JN-1 facility were used to support the scaling 

factors derived with ORIGEN2.2 for plutonium and americium isotopes and specific fission 

products. 

Documents Reviewed

The list of documents provided below includes all documents related to the SRS-CCP RH 

radiological characterization program that were evaluated to support this inspection: 

• C001, Interview Record: Eugene Sands, Master Research Technician; Larry Stickel, Master 

Technician; Harley Toy, Manager of Regulatory Compliance and Technical Services; Max 

Berchtold, JN-1 Lab Technician; George Kirsch, Health Physicist; K.J. Peters and J. 

Harrison, May 1, 1998 

• C002, Packet of Letters Concerning Destruction/Immobilization of Toxic Substances by 

Intense Gamma Irradiation, L. M. Lowry, H. L. Toy, E. W. Ungar, R. DiSalvo, November 8, 

1982, December 13, 1982, December 15, 1982, January 27, 1983 

• C003, Letter to Louis B. Myers, re: Characterization of the JN-1 Hot Cell Waste Drums, M. 

P. Failey, May 1, 1997 

• C004, Interview Record: Harley Toy, Manager of Regulatory Compliance and Technical 

Services; George Kirsch, Health Physicist, Historical Operations in JN-1, K.J. Peters, July 

12, 1998 

• C005, Interview Record: Scott Kitts, Manager Special Waste Projects, Hanford N-Reactor 

Process Tube in JN-1, K.J. Peters, July 16, 1998 

• C006, Interview Record: Max Berchtold, JN-1 Lab Technician, Historical Operations in JN-1 

 

7

 The terms swipe and smear refer to a small piece of absorbent material that is wiped or smeared on a surface 

area and subsequently analyzed by destructive or nondestructive radiometric techniques to estimate the amount of 

removable radioactive contamination on the area or item that was wiped. Standard Health Physics practices 

typically express swipe/smear results in activity units per area or per swipe, e.g., μCi/100 cm2

 or dpm/swipe. 

Consistent with the usage observed in the BCLDP documents reviewed during this inspection, these two terms are 

used interchangeably in this report. 

8

 Although the terms dose rate, dose equivalent rate, and external exposure rate have different meanings, they 

are sufficiently similar in this context to allow their use interchangeably in this report. The most prevalent 

terminology used to express this waste attribute in BCLDP documents is dose rate, stated in milliRoentgens per 

hour (mR/hr), which for our purposes is the equivalent of dose equivalent rate expressed in mRem/hr from the 

standpoint of determining a container’s RH status. 

9

 The computer code used is ORIGEN2, Version 2.2, which is expressed as ORIGEN2.2 throughout this report. 
14 

and Hydraulic Oil Composition (including MSDS), K.J. Peters, July 15, 1998 

• C007, Interview Record: Scott Kitts, Manager Special Waste Projects, Separation of Hot 

Cell Waste from Wastes from Supporting Areas, K.J. Peters, July 22, 1998 

• C008, Memorandum to Mike Brown, re: Certification Strategy for Transuranic Waste 

Generated from the Battelle Columbus Laboratories Decommissioning Project, C98-065, 

Various, June 25, 1998 

• C021, Letter to AK Record, re: Estimates of Waste Stream Generation Volumes and Waste 

Material Parameter Categories for Building JN-1 Repackaged Waste, K.J. Peters, May 7, 

1999 

• C033, Letter to Contractors, Richland, Washington; Director, Pacific Northwest Laboratory; 

President, Westinghouse Hanford Company, re: Spent Nuclear Fuel Records, 96-SFD-059, 

E.D. Sellers, March 14, 1996 

• C034, Memorandum to Elizabeth D. Sellers, re: National Spent Nuclear Fuel Program 

Evaluation of Hanford Building 327 Material for Applicability of RH-TRU Waste Criteria 

for Disposal at WIPP, OPE-SFP-081, J. Boyd, March 24, 1997 

• C035, Letter to H. J. Hatch, re: Contract No. DE-AC05-96RL13200 - Classification of 

Nuclear Materials in the 327 Building, 97-SFD-074, E.D. Sellers, April 21, 1997 

• C047, Letter to Pete Erickson, re: Findings on the Result of Pressure Wash Decontamination 

on the JN Waste Matrix, C. Jensen and J. Sarge, July 25, 2000 

• C501, Battelle Defense Determination Approval, E. Rose, July 15, 2005 

• C502, Surveillance (S-01-37) of the Battelle Columbus Laboratories Decommissioning 

Project (BCLDP) Remote Handled Waste Characterization, CBFO:QA:TJR:VW:01-

1451:UFC:2300, T. Baillieul, September 17, 2001 

• C504, Waste Material Parameter Weight Evaluation for Waste Stream SR-RL-BCLDP.001, 

K.J. Peters, April 11, 2007 

• C505, U.S. DOE CAO Audit Report of the Battelle Columbus Laboratories 

Decommissioning Project, TRU Waste Characterization Activities Related to Acceptable 

Knowledge, May 7, 1999, Audit Number A-99-15, M.A. Italiano, June 4, 1999 

• DR002, Interview Record for Discrepancy Report of George Kirsch, re: Date of the 

Beginning of Operations of the HEC and Pool, K.J. Peters, July 28, 1998 

• DR004, Interview Record of Cidney Voth, re: Evaporation of the JN-1 Transfer/Storage Pool 

Water, K.J. Peters, April 27, 1999 

• DR005, Letter to AK Record, re: Discrepancy Report Relating to Lead Detected in Sample of 

Pool Water, K.J. Peters, May 12, 1999 

• DR006, Letter to AK Record, re: Discrepancy Report Relating to RCRA Metals Detected in 

Samples Pool Resins and Filters, K.J. Peters, June 29, 1999 

• DR009, Letter to AK Record, re: Discrepancy Report Regarding Generation of Four Debris 

Waste Streams, 5190-01, 5190-02, 5390-01, and 5390-02, K.J. Peters, May 25, 2001 
15 

• DR010, Letter to AK Record, re: Discrepancy Report Relating to RCRA Metals Detected in 

Pool Resins and Filters Samples, and TRU Resin Volume Estimation, S.M. Smith, May 25, 

2001 

• DR011, RCRA Hazardous Waste Number Assignment Discrepancy Report, K.J. Peters, Date 

TBD 

• P002, Fuel Storage Pool, Pump Room, and Washdown Room JN-1B. Decontamination and 

Decommissioning Operations, L.B. Myers, M.B. Berchtold, and J.L. Stickel, July 1, 1995 

• P003, High Energy Cell, Mezzanine, and Top of HEC JN-1B. Decontamination and 

Decommissioning Operations, L.B. Myers, M.B. Berchtold, P.D. Faust, and P.A. Tomlin, 

December 1, 1994 

• P004, Waste Storage Shed JN-1A. Decontamination and Decommissioning Operations, L.B. 

Myers and M.B. Berchtold, June 1, 1995 

• P005, Hot Cell Purposes and Activities. Decontamination and Decommissioning Operations, 

Battelle Columbus Laboratories, September 22, 1997 

• P006, Contents of the West Jefferson North Hot Cells and Storage Areas, L.B. Myers, M.B. 

Berchtold, and E.H. Sands, May 1, 1995 

• P008, West Jefferson North Hopper Location and Contents, L.B. Myers and M.B. Berchtold, 

June 1, 1995 

• P009, Chemistry Laboratory, Counting Room and Microprobe Room, L.B. Myers, M.B. 

Berchtold, P.A. Tomlin, and M.P. Failey, December 1, 1994 

• P010, Evaporator Room JN-1A, Louis B. Myers, M.B. Berchtold, and P.A. Tomlin, 

November 1, 1994 

• P011, Controlled Access Area Storage Rooms JN-1A, L.B. Myers, M.B. Berchtold, P.D. 

Faust, and P.A. Tomlin, October 1, 1994 

• P012, Controlled Access Area JN-1A, L.B. Myers, M.B. Berchtold, P.D. Faust, and P.A. 

Tomlin, September 1, 1994 

• P013, Mezzanines JN-1A, L.B. Myers and M.B. Berchtold, September 1, 1994 

• P014, Mechanical Test Cell JN-1A, L.B. Myers, C.A. Redd, Sr., and M.B. Berchtold, July 1, 

1994 

• P015, High Level Cell and Low Level Cell Hydraulic Doors and Hydraulic Door Room JN1A, L.B. Myers and M.B. Berchtold, September 1, 1994 

• P016, Subcells of the High Level and Low Level Cells in JN-1A, L.B. Myers, M.B. 

Berchtold, and P.A. Tomlin, November 1, 1994 

• P017, Low Level Cell JN-1A, L.B. Myers, M.B. Berchtold, T.A. Beddick, P.D. Faust, and 

P.A. Tomlin, August 1, 1994 

• P018, High Level Cell JN-1A, L.B. Myers, M.B. Berchtold, P.D. Faust, and P.A. Tomlin, 

August 1, 1994 
16 

• P019, Charpy Room JN-1A, Louis B. Myers, C.A. Redd, Sr., M.B. Berchtold, June 1, 1994 

• P023, Course 7: Metals for Nuclear Power, Lesson Ten: Structural Materials, Metals 

Engineering Institute, 1958 

• P025, Miscellaneous Material Safety Data Sheets (MSDS), Various 

• P026, The U.S. Government and Battelle: Partners in Nuclear Research, 1943 - Present, 

Various, Not Given 

• P028, Battelle Columbus Laboratory Hot Cell Facility, Radioactive Material Receipt Record 

and Survey, Project G-7656-3, T.R. Emswiler, October 24, 1967 

• P029, Battelle Memorial Institute - Columbus Laboratory, Radioactive Shipment and Receipt 

Form, Project 227566, T. R. Emswiler, December 24, 1970 

• P032, Procedures Manual for Battelle’s Radioisotope, Gamma, and Hot-Cell Laboratories, 

BMI-PM-662, D.N. Sunderman and R.F. Dickerson, February 20, 1962 

• P034, Finding of No Significant Impact and Environmental Assessment, Battelle Columbus 

Laboratories Decommissioning Project, U.S. DOE Chicago Operations Office, June 1, 1990 

• P037, Decontamination Work Plan for Building JN-1, Battelle Columbus Division, 

November 1, 1990 

• P041, Interim Guidance on Ensuring that Waste Qualifies for Disposal at the Waste Isolation 

Pilot Plant, U.S. DOE CBFO, December 13, 1997 

• P076, Acceptable Knowledge Summary, Pool Water Prefilter and Debris, Revision 1, 

WASTREN, Inc., January 19, 2001 

• P077, Waste Management Operating Procedure: Operation and Maintenance of the Alkota 

Pressure Washer, WA-OP-061, Revision 3, Battelle Columbus Laboratories, March 6, 2001 

• P078, Work Instruction: Operation of CAA Pressure Wash System, WI-976, Revision 2, 

Battelle Columbus Laboratories, November 30, 2000 

• P079, Work Instruction: Material Removal from the High Level Cell, WI-1021, Revision 0, 

BCL, February 2, 2001 

• P501, Building JN-1 Hot Cell Laboratory Acceptable Knowledge Document, TCP-98-03, 

Revision 2, K. J. Peters, August 2001 

• P503, Waste Characterization Classification, and Shipping Support Technical Basis 

Document for BCLDP West Jefferson North Facility, DD-98-04, Revision 4, C. W. Skapik, 

November 2002 

• P505, Segregation and Packaging of TRU Waste, TC-OP-01.4, Revision 2, P. Erickson, Date 

TBD 

• P506, Packaging Video Documentation, TC-OP-01.5, Revision 2, D. Garber, Date TBD 

• P511, Technical Basis Document, Acceptable Knowledge Process Description, Repackaging 

of Building JN-1 Clean-Up Waste Containers, TCP-98-03.1.2, Revision 2, K.J. Peters, 

WASTREN, Inc., July 2001 
17 

• P512, Technical Basis Document, Acceptable Knowledge Process Description, TRU Waste 

Laundry Decontamination, TCP-98-03.1.3, Revision 1, K.J. Peters, WASTREN, Inc., June 

2001 

• P514, Identification, Segregation, Separation, and Documentation of Low Level and 

Radioactive Mixed Waste, WA-OP-020, Revision 7, P. Erickson, Date TBD 

• P518, Lessons Learned Report for the BCLDP Transuranic Waste Shipments to Hanford and 

the Savannah River Site for Interim Storage and Final Characterization, N/A, P. Weaver, 

November 2006 

• P704, Characterization of Remote-Handled Transuranic Waste for the Waste Isolation Pilot 

Plant – Final Report, National Academy of Sciences, 2002 

• P727, CCP Calculation Cover Sheet: SRS TRU Radiological Characterizations, SRS-RH-01, 

Revision 0, R. Tayloe, June 26, 2007 

• P729, Swipe Sample Data Analysis Calculation Package, SRS-RH-03, Revision 0, J. Vance, 

May 16, 2007 

• P735, Fuel Type Evaluation, SRS-RH-09, Revision 0, J. Vance, May 16, 2007 

• P737, Calc Package for Determination of Reportable Isotopes, SRS-RH-11, Revision 0, J. 

Vance, May 16, 2007 

• U001, Miscellaneous Maps of Battelle Columbus West Jefferson North Facility, Battelle 

Columbus Laboratories, Date Not Given 

• U002, Description of the Battelle Hot Cell Laboratory, Battelle Columbus Laboratories, Date 

Not Given 

• U003, Battelle-Columbus Hot Cell Laboratory - Capability Summary, Battelle Columbus 

Laboratories, Date Not Given 

• U004, Buildings JN-1, JN-2, and JN-3 Summaries, Battelle Columbus Laboratories, Date 

Not Given 

• U006, ENG-92 Contract Projects Database 1 Printout, Query Dated May 20, 1985 

• U008, Nuclear Fuel Inventory at West Jefferson North, Battelle Columbus Laboratories, Date 

Not Given 

• U009, Miscellaneous JN-1 Waste Inventory Data, Battelle Columbus Laboratories, 

1988−1997 

• U014, ENG-92 Contract Projects Database 2 Printout, Battelle Columbus Laboratories, 

Query, October 17, 1986 

• U016, Nuclear Materials Questionnaires, Battelle Columbus Laboratories, 1985 

• U025, Actinide Screen Data for Radionuclides Contained in Strippable Paint from JN-1 

Charpy Cell, Battelle Columbus Laboratories, July 17, 2000 

• U026, 69 Sample Basis of DD-98-04 Technical Basis Document, Battelle Columbus 

Laboratories, May 25, 2001 
18 

• U509, Waste Management 2000 Presentation and Paper – RH-TRU Waste Packaging Visual 

Confirmation Using a Dual-Camera Video Security and Documentation System, D. Garber, 

J. Eide, and K. Peters, Not Dated 

• U513, Miscellaneous Inventory Spreadsheets, K.J. Peters, BCLDP, SRS, Hanford, Various 

• U516, Waste Management 2002 Paper, Adequacy of a Small Quantity Site RH-TRU Waste 

Programs in Meeting Proposed WIPP Characterization Objectives, J. Biedscheid, M. 

Devarakonda, S. Stahl, K. Peters, and J. Eide, 2002

• U734, Review of Spreadsheet WJ_samp.xls “69 Swipes from Battelle”, R. Tayloe, August 7, 

2001 

• CCP-AK-SRS-500: Central Characterization Project Acceptable Knowledge Report for 

Battelle Columbus Laboratory’s Decontamination Project (BCLDP) Remote Handled 

Transuranic Debris Waste from the Building JN-1 Hot Cell Laboratory, Waste Stream: SRBL-BCLDP.001, Revision 0, May 17, 2007 and Revision 1, August 27, 2007 

• CCP-AK-SRS-501: Central Characterization Project Remote Handled Transuranic 

Radiological Characterization Technical Report for Remote Handled Transuranic Debris 

Waste from Battelle Columbus Laboratory’s Decontamination Project at the West Jefferson 

North Facility, Revision 0, June 14, 2007 and Revision 2, November 28, 2007 

• CCP-AK-SRS-502: Central Characterization Project RH TRU Waste Certification Plan for 

40 CFR Part 194 Compliance and Confirmation Test Plan for BCLDP Waste Stream SR-RLBCLDP.001, Revision 0, June 11, 2007 

• CCP-AK-SRS-503: Central Characterization Project Battelle Columbus Laboratory 

Decommissioning Project Quality Assurance Equivalency Report and Procedure Matrix for 

Remote–Handled Transuranic Debris Waste, Revision 0, June 13, 2007 

• CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable 

Knowledge Characterization Reconciliation Report, Revision 2 

• Characterization Reconciliation Report, BC SRS Waste Stream - SR-RL-BCLDP.001, 

Attachment 5 and related required documents, prepared July 17, 2007 (Waste Stream Profile 

Form, Draft, also provided) 

• TRU Waste Package Loading Record, BC0048, February 24, 2003 

• Qualification Cards for S. Nance, AK Expert (AKE) and R. Tayloe (DTC Technical 

Specialist), provided July 19, 2007 

• Project Office Data Tracking System (PTS), CTS Corrective Action Non Conformance 

Reporting, provided July 19, 2007 

• Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, DOE/WIPP- 02-

3122, Revision 6, November 16, 2006 

• Remote-Handled TRU Waste Characterization Program Implementation Plan, DOE/WIPP -

02-3214, Revision 0D 

• Scaling Factor Development, Calculation Package No. SRS-RH-01 Revision 0, June 26, 

2007 and Revision 2, November 6, 2007 
19 

• Dose-to-Curie Correlation for Cs-137 and Co-60, Calculation Package No. SRS-RH-02, 

Revision 0, June 26, 2007 and Revision 1, November 5, 2007 

• Evaluation of Swipe Sample Data, Calculation Package No. SRS-RH-03, Revision 0, June 

26, 2007 and Revision 1, October 26, 2007 

• Source Uncertainty Using MCNP5, Calculation Package No. RSR-RH-04, Revision 0, May 

16, 2007 and Revision 1, November 7, 2007 

• Dose-to-Curie Spreadsheet, Calculation Package No. SRS-RH-05, Revision 0, May 16, 2007 

and Revision 1, November 7, 2007 

• Uncertainty Analysis, Calculation Package No. SRS-RH-06, Revision 0, May 16, 2007 and 

Revision 1, November 7, 2007 

• ORIGEN2.2 Benchmarking for LWR Fuel, Calculation Package No. SRS-RH-07, Revision 

0, May 16, 2007 

• Evaluation of Different Fuel Type, Calculation Package No. SRS-RH-09, Revision 0, May 

16, 2007 and Revision 1, November 5, 2007 

• Evaluation of Different Fuel Type, Calculation Package No. SRS-RH-09, 

• Swipe Sample Data Decay Correction, Calculation Package No. SRS-RH-10, Revision 0, 

June 26, 2007 and Revision 1, November 5, 2007 

• Determination of Reportable Isotopes, Calculation Package No. SRS-RH-11, Revision 0, 

May 16, 2007 and Revision 1, November 6, 2007 

• Swipe Sample Data Input Check, Calculation Package No. SRS-RH-12, Revision 0, May 25, 

2007 

• Fission Product Contribution to Dose Rate, Calculation Package No. SRS-RH-13, Revision 

0, May 25, 2007 and Revision 1, November 5, 2007 

• ORIGEN2.2 Date Extraction Program (OriOout01), Calculation Package No. SRS-RH-14, 

Revision 0, May 29, 2007 

• TC-OP-01.4, Revisions 1 and 2 

• TCP-98-05, Revision 3, Training Plan for the Battelle Columbus Laboratories 

Decommissioning Project (BCLDP) TRU WCP, March 3, 2003 

• Training Program, TRU 100, WIPP Indoctrination for the BCLDP TRU WCP Training 

Program Record, Revision 2, June 15, 2000 

• Work Instruction WI-958, Set Up and Packaging of Transuranic Waste in the High Energy 

Cell, Revision 2, April 1, 2000 

• Work Instruction 956, Packaging of Transuranic Waste in the Mechanical Test Cell 

Addendum 1, March 1,1999 

• List of Containers in Waste Stream SR-RL-BCLDP.001 

• TRU Waste Packaging Loading Record Itemized Data, Container No. BC0090 
20 

• TRU Waste Packaging Loading Record Itemized Data and Audio/Visual recording, 

Container No. BC0070 

• TRU Waste Packaging Loading Record Itemized Data and Audio/Visual recording, 

Container No. BC0035 

• TRU Waste Packaging Loading Record Itemized Data and Audio/Visual recording, 

Container No. BC0051 

• TRU Waste Packaging Loading Record Itemized Data and Audio/Visual recording, 

Container No. BC0120 

• Training Record for VE Operator for Procedure TC-OP-01.4, Revision 2 

• Record Inventory and Disposition System (RIDS) for BCLDP from PR-AP-17.1, Revision 5 

• WIPP Waste Container Report for Canister ID0051 Housing Container Nos. 001131, 

001141, and 001143 

• WIPP Waste Container Report, Container No. 001131 

• WIPP Waste Container Report, Container No. 001141 

• WIPP Waste Container Report, Container No. 001143 

• WWIS Data Entry Summary Spreadsheet, Container No. 001131 

• RTR Data Sheet, Container No. 001131 

• Dose-to-Curie Data sheet, Container No. 001131 

• CAR/NCR Email for INL RH Lot 9 

• Waste Container Data, Container No. 001117 

8.1 Acceptable Knowledge Process Overview and Analysis 

(1) Waste stream definition for SRS-CCP BCLDP waste stream SR-RL-BCLDP.001 was 

examined and found to be adequate following incorporation of additional information. 

The WCPIP defines waste stream as “waste material generated from a single process or activity, 

or as waste with similar physical, chemical, and radiological properties.” Waste Stream 

SR-RL-BCLDP.001 is a debris waste stream generated in the JN-1 HCL facility during D&D 

activities performed from May 1999 through August 2004, and was packaged in June, consisting 

of 87 drum liners. 

The EPA inspection team evaluated the physical and radiological compositions of the waste with 

respect to waste stream definition to ensure they were appropriate. Several references were 

examined to understand the historical AK assessment of the stream, including, but not limited to, 

P501, C001, P023, P026, P511, P514, and U513. It was noted that the waste stream was 

generated solely through D&D of the JN-1 HCL, which included several areas, such as the 

Mechanical Test Cell, High-Energy Cell, Low-Energy Cell, Alpha-Gamma Cells, Controlled 

Access Area, and Charpy Room. Wastes generated included the spectrum of D&D-related 
21 

debris materials. Reference C504 summarized the WMP content within each drum liner. All 

waste in the drum liners had been mechanically compacted during loading to reduce void space 

and maximize waste packaging using a 5,000-pound weight. 

It was also noted that this waste stream includes four liners that contained mop heads, as well as 

residual solidified materials representative of small fines or the solidification of liquids 

associated with mop heads and other clean-up materials. While the WMPs in these four liners 

are distinguishable from the remaining D&D waste population, EPA concluded that the four 

drums containing mop heads and related materials were generated by the same process and 

should contain the same general material and radiological parameters, so inclusion of the drums 

in the stream was appropriate. The Acceptable Knowledge Experts (AKEs) interviewed stated 

that no individual drum liner contained greater that 50% solidified material, so the waste 

summary category group (SCG) was consistent within the waste stream, as presented in 

reference C504. 

The EPA inspection team determined that the AK record for this waste stream was initiated years 

prior to completion of waste packaging. For example, AK document P501 was prepared in 2001 

and described at least nine separate waste types based on physical form. The EPA inspection 

team also found that while SRS-CCP considered the debris in this stream to have originated from 

a single process similar in material, chemical, and radiological properties, BCL representatives 

packaging the waste during the clean-up process segregated the waste into four separate 

groupings: hazardous combustibles; non-hazardous combustibles; hazardous non-combustibles; 

and non-hazardous non-combustibles. The EPA inspection team determined that additional 

justification and information pertinent to waste stream packaging and waste stream 

determination were required to better support CCP’s conclusion to combine the 87 drum liners 

into a single waste stream. 

As part of EPA’s assessment of the waste stream determination, the EPA inspection team tracked 

and verified several elements of the AK summary (CCP-AK-SRS-500) and its references to 

ensure that radiological characterization performed was technically supported, with particular 

emphasis on AK parameters used to develop the JN-1 Standard Isotopic Mix and scaling factors. 

CCP-AK-SRS-500 presents the JN-1 Standard Isotopic Mix, citing P503 and U516 as among the 

primary references supporting the determination of this mix. However, P503 has only a general 

discussion of the isotopic mix determination and does not provide detailed supporting 

information, and U516 contains proceedings from a presentation given at a Waste Management 

conference in 2002. The EPA inspection team found that the memorandum documenting 235U 

enrichment, burn-up, and decay was not verified through supporting references or other 

information. The SRS-CCP AKE stated that some of the original BCL information was not 

available, and that they could not produce a historic database that cataloged the radiological 

experiments and parameters relative to the activities within JN-1. 

Some references contain worthwhile information, such as U014. The EPA inspection team also 

determined that the representativeness of the 69 swipe samples used to generate the radionuclide 

scaling factors was not adequately supported in the AK record. The EPA inspection team 

determined that it was necessary to better document the origin of 235U enrichment, and the burnup and decay values used as input to ORIGEN2.2 modeling in SRS-CCP documents. EPA 
22 

discussed the need for better documentation of the origin of 235U enrichment with AKEs, and 

also issued EPA Finding No. SRS-RH-AK-07-001F, which included a number of technical 

elements. This was the single finding of the inspection and it is discussed in Sections 8.1 and 8.2 

of this report. The aspects that pertain to waste stream determination and radiological 

characterization are presented below. 

EPA Finding No. SRS-RH-AK-07-001F: This finding covers four issues. Table 3 indicates 

where each issue is addressed, identifies the report section where the information provided by 

SRS-CCP is discussed, and gives the status of the issue. For a full description of this finding, see 

Attachment A to this report. 

Table 3. Details of EPA Finding No. SRS-RH-K-07-001F 

EPA Finding No. 

SRS-RH-AK-07-00F Issue Summary Report Section Where Issue is Discussed Issue Status 

Issue (a) Completeness and adequacy of 

documentation for AK and radiological 

characterization 

Section 8.1 (1), page 23 Resolved 

Issue (b), 1st bullet Limit waste stream documentation to 87 

drum liners at SRS 

Section 8.1 (3), page 26 Resolved 

Issue (b), 2nd bullet Clarify isotopic distributions Section 8.1 (3), page 26 Resolved 

Issue (b), 3rd bullet Expand discussion of radiological 

characteristics of waste stream 

Section 8.1 (3), page 26 Resolved 

Issue (c) Delineation of waste stream Section 8.1 (1), page 23 Resolved 

Issue (d) Documentation of TMU and radionuclide 

scaling factors 

Section 8.2 (6), page 43 

Section 8.2 (7), page 45 

Resolved 

EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and (c): In August 2001, EPA conducted 

a surveillance of the BCL RH WC program. In the report sent to DOE (EPA’s Technical and 

Regulatory Support Document for RH Waste Determination, February 2004, transmitted by EPA 

to DOE by Frank Marcinowski, March 26, 2004), EPA stated that “BC’s RH Program could be 

improved through more diligent acquisition and integration of AK-based radionuclide 

information to determine isotopic distributions.” EPA also questioned the representativeness of 

swipe samples collected that were later used as part of scaling factor/JN-1 isotopic mix 

development. EPA concluded that the “AK program data assembly/compilation elements were 

not complete.” EPA concluded that while the radioassay approach had merit, characterization 

activities performed to support the approach at the time of the 2001 surveillance “were not 

technically adequate.” 

EPA’s current inspection identifies the following issues related to AK and radiological 

characterization documentation completeness and adequacy, many of which are related to issues 

identified in our August 2001 surveillance: 
23 

Issue (a): Isotopic ratio/composition information from two primary sources was used to 

develop scaling factors (also the JN-1 Standard Isotopic Mix). The factors were derived 

from a combination of swipe sample and modeling results, using input data to the model 

(ORIGEN2.2) that originated in a memorandum from a 1999 meeting. As an auditable 

record, additional information and rationale supporting the approach is required both for the 

isotopic distributions based on the swipe data and the recommended burn-up, enrichment, 

and decay data from the 1991 memorandum. Documentation of the references and data 

sources that were reviewed and evaluated during the 1999 meeting is necessary to support the 

conclusions used by SRS-CCP. With regard to the swipe data, the sampling plan and 

collection, the sample numbers, sampling results, and other relevant information must be 

summarized to show that the sample data are sufficiently representative of the wastes within 

Waste Stream SR-RL-BCLDP.001. 

Issue (c): Through the course of the AK information acquisition and interpretation process, 

the number of waste streams identified in JN-1 has changed over time. Specifically, the 

current designation of Waste Stream SR-RL-BCLDP.001 stream was originally identified as 

four separate waste streams. There is no information given to show these waste streams were 

combined into a single stream. 

EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and (c) Resolution: In response to Issues 

(a) and (c), SRS-CCP provided a formal resolution letter describing their approach, as well as 

References C510, C511, C513, and C520, three of which contain additional information 

pertaining to the 1999 memorandum. While the source of information for the parameter ranges 

in the 1999 memorandum was not cited in C511 other than to cite general text references, C520 

indicates that these ranges agree with the fuel libraries associated with ORIGEN 2.2, the sources 

of which are documented. Reference C513 provides additional information concerning waste 

origin and distribution. 

Reference C510 states that while a sampling plan was not found, SRS-CCP interviewed the 

individuals that performed the sampling and analysis, and these individuals indicated that the 

sampling was authoritative in nature. SRS-CCP representatives indicated that the samples were 

selected to include the widest variety of surfaces within JN-1 to ensure that all possible 

contaminated surfaces were tested. SRS-CCP did not provide additional information to 

document that this approach was compliant with the WCPIP requirements for representativeness, 

with the understanding that the WCPIP was not in place at the time of sample collection. 

Accordingly, SRS-CCP could not demonstrate representativeness of the 69 swipe samples 

through a statistical analysis. It is evident from the available information that these wastes were 

transferred and packaged without regard to the generation location within the JN-1 complex (i.e., 

wastes from different areas were packaged together) and thus potentially contaminating surfaces 

throughout the JN-1 area. Accordingly, the JN-1 sample collection locations and number of 

samples taken should result in a reasonable portrayal of the potential contamination of the wastes 

generated within the JN-1 complex. 

EPA’s conclusions are based upon interviews with SRS-CCP personnel, as there is no sampling 

plan or other documentation from the individuals who performed the sampling. To support both 

SRS-CCP’s assessment and EPA’s inspection, EPA required that SRS-CCP provide a 
24 

memorandum documenting the sampling approach prepared by BCL staff familiar with the 

swipe sampling at various JN-1 locations where RH debris waste was handled. EPA specifically 

required that this memorandum address the sampling procedure and rationale that were followed, 

with emphasis on the following: 

(1) Guidance that was followed to develop and execute the sample collection, e.g., DOE 

Order, CBFO Procedure, or other guidance 

(2) Sample protocols (reference the procedure(s) followed) 

(3) Reason for initial sample collection and the use of 69 samples to characterize the waste, 

i.e., why 69 samples were considered sufficient 

(4) Reason why the selected samples were considered representative, i.e., selected from a 

variety of surfaces that were typical of anticipated contamination in all areas 

(5) Indicate if the sampling was performed prior to approval of the WCPIP, if this is the case 

(6) Specify timing of sampling and the selection of the 69 sample subset 

EPA determined that the lack of this information prevents EPA from independently verifying 

that the data from the 69 swipe samples was representative on the basis of the objective evidence 

presented. Also, EPA considered it necessary to have this information to support DOE’s 

contention that 69 swipe samples are indeed representative, as discussed in Section 8.2 (2). 

SRS-CCP prepared Reference C509, which documented why BCLDP personnel performed the 

initial waste subdivisions, and why combining four different waste categories into a single 

stream is appropriate and compliant with WCPIP and requirements. 

The CCP responded to EPA’s request in April 2008, preparing a memorandum titled “Response 

to EPA SRS RH Additional Information Request.” In response to EPA Items 1 and 2, the 

memorandum stated the following: 

The sampling protocol used to collect the smears was the routine health physics 

survey procedure HP-OP-019, ‘Radiation and Contamination Survey Techniques’ 

(AK source document number P751). This procedure, coupled with waste 

instructions, provided the documentation used by BCLDP to collect the samples. 

The BCLDP staff considered this procedure as equivalent to the sampling plan at 

the time. Waste Instruction WI-956 (AK source document number P707) is an 

example of a waste instruction from the 1999 time frame.

Review of these references indicates that while HO-OP-019 (P751) certainly contains 

descriptions of smear survey protocols and other procedures that could also be used in 

characterization surveys, the document also states in Section 4.2 that “This procedure does not 

apply to characterization surveys, nor is it intended to alter current or future characterization 

surveys.” Reference P707 describes waste packaging protocols for pool filters and resins that are 

outside of the current waste stream. The Memorandum also relies heavily on expert judgment 

and personnel expertise to support appropriate sample collection. In response to EPA Item 3, the 

Memorandum states that surveyed material, surveyed locations, and statistical analysis (Central 
25 

Limit Theorum) indicate that 69 swipe samples are “reasonable and adequate.” EPA agrees that 

the number of samples collected should be sufficient if the initial population selected for 

sampling adequately captures the variability of the waste population as a whole. In response to 

EPA Item 4, the Memorandum reiterates information obtained by EPA during the inspection that 

samples were collected randomly from a variety of surfaces to capture the range of potential 

isotopic distributions that in the waste. The Memorandum, however, makes no statement 

regarding collection of samples prior to approval of the WCPIP (EPA Item 5). 

EPA recognizes that smear/swipe sampling was performed during the pre-2000 time period 

(EPA Item 6), while EPA approved the WCPIP addressing RH waste characterization activities 

in 2003. The WCPIP explicitly requires the preparation of a sampling and analysis plan when 

sampling is performed (Section 4.8.1): “...A sampling plan shall be developed and documented 

for each RH TRU waste stream....the burden of responsibility for developing a technically sound 

sampling plan rests with the TRU waste generator.” Since the smear samples were taken prior to 

the sampling and analysis (S&A) plan requirement of the WCPIP, EPA understands that 

compliance with all WCPIP requirements may not be possible for this waste stream. 

In the future, however, EPA expects that the CCP will provide rigorous and detailed information 

as part of the AK Record to document as much information about waste sampling as possible 

(such as that provided to resolve this EPA Finding) to meet the WCPIP-based sampling 

requirements initially for EPA evaluation. When proposing another BCLDP RH waste stream 

(e.g., BCLDP solids and soil/gravel) for EPA evaluation and approval as a T1 change, the CCP 

must provide rigorous and detailed sampling and analysis information when CCP cannot fulfill 

the S&A plan requirement of the WCPIP. Based on the information provided by CCP prior to, 

during, and since the inspection, EPA concludes that the samples collected, together with Fuel 

Type Scaling Factor comparisons (discussed in Section 8.2 of this report), results in a reasonable 

description of the isotopic distribution sufficient to verify AK. 

EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and (c) Status: Based on the information 

examined, as discussed here and in Section 8.2 (7), the EPA inspection team determined that the 

use of the 69 swipe sample data in the manner employed by SRS-CCP resulted in sufficient 

information to verify isotopic distributions presented in the AK Summary and assumptions 

discussed later in Section 8.2 of this report. EPA considers both Issues (a) and (c) to be closed. 

(2) The identification of these wastes as defense-related, TRU versus HLW, low-level waste, 

and SNF was examined and accepted. 

CCP-AK-SRS-500 stated that the waste met the definition of defense waste, even though the vast 

majority of radiological material managed in JN-1 was non-defense-related. DOE agrees with 

SRS-CCP’s justification as to the defense determination. DOE is solely responsible for the 

determination. EPA does not evaluate the defense determination that DOE performs for TRU 

waste destined for disposal at WIPP. The AK Summary stated that the waste met the definition 

of defense waste because defense-related naval reactor material was managed in the complex, 

and defense-related research and development activities took place in JN-1. The occurrence of 

both activities would cause the defense and non-defense material to be commingled, thus 

imparting a defense determination to the waste. This is also documented in Reference C501. 
26 

The AK Summary indicated that the waste did not contain wastes derived from the separation or 

reprocessing of constituent elements from reactor fuel, and the waste stream did not contain 

irradiated fuel elements withdrawn from a reactor. SRS-CCP BCLDP representatives stated that 

HLW is not included in this waste stream by definition. Similar to the LANL debris waste that 

lacked an explicit SNF pedigree (see Air Docket No. A-98-49, II-A4-89), the RH debris waste 

from BCLDP does not have an explicit SNF pedigree. 

(3) Sufficiency of the AK summary and implementation of AK as required in Attachment A 

of the WCPIP were evaluated and found to be adequate upon revision of key documents. 

Attachment A of the WCPIP specifies that the following be included in AK summaries: 

• Executive summary 

• Waste stream identification summary 

• AK data and information description 

• Program information 

• Waste stream information 

• Qualification of AK information 

• Container-specific information 

Attachment A of the WCPIP mandates that the data collection and analysis process should be 

similar to the process that is used for CH wastes. Both the content of the AK summary and 

sufficiency of AK implementation were assessed, and EPA determined that the AK Summary 

adequately addressed the main required elements of the WCPIP. The EPA inspection team, 

however, found discussion of additional separate waste streams within the text of the AK 

summary, which implies that SRS-CCP may have been seeking a broader scope of approval than 

what EPA determined through interview of the AKEs. EPA focused only on Waste Stream 

SR-RL-BCLDP.001 and limits its evaluation to that waste stream. The EPA inspection team 

also found the discussion in CCP-AK-SRS-500 concerning the “standard” versus “non-standard” 

radiological mixes and differing characterization processes confusing. The AKE indicated that 

this waste stream was only characterized using the JN-1 Standard Isotopic Mix and no other 

sampling or analysis approach was apparently used to characterize waste outside of this stream. 

The text of CCP-AK-SRS-500 did not include information pertaining to the general radiological 

content of materials managed in the JN-1 HCL, including the number of experiments associated 

with LWR and other reactors or related isotopic information. While the AKE indicated upon 

interview that only material originating from within JN-1 HCL was present in waste, AK data 

provided as references and in the CRR were confusing, because it was unclear how radiological 

data from the JN-2, JN-3, and JN-4 areas pertain to JN-1. This was discussed with SRS-CCP 

personnel during the inspection and EPA included this issue as a finding on the EPA Inspection 

Issue Tracking Form that was discussed throughout this report (see Attachment A of this report 

for a copy of this form). The aspects of the finding that pertain to the content of the AK 

Summary are presented below: 

EPA Finding No. SRS-RH-AK-07-001F, Issue (b): EPA’s current inspection identifies the 

following issues related to AK and radiological characterization documentation completeness 

and adequacy, many of which are related to issues identified in our August 2001 surveillance: 
27 

CCP-AK-SRS-500 must be revised to address the following: 

• Only describe the SRS waste stream of 87 drum liners subject to this inspection. 

• The document states that there are wastes in this stream that exhibit both “standard” and 

“non-standard” isotopic distributions, and that non-standard waste will undergo separate 

sampling and analysis. However, the AKE indicated that only “standard” isotopic mix 

wastes are included in the stream, and there are no wastes that underwent the alternative 

sampling and analysis approach discussed in the text. 

• Include a thorough presentation of general radiological characteristics of wastes. 

Information such as types of radionuclides handled in JN-1 in the various cells/areas, 

origin of radionuclides (e.g., LWR), outliers, and any other information necessary to 

provide a general overview of the radionuclides handled through the course of JN-1 

operations is necessary. 

EPA Finding No. SRS-RH-AK-07-001F, Issue (b) Resolution: SRS-CCP revised 

CCP-AK-SRS-500, noting that the number of drum liners within the most recent version was 

correctly reduced to 87. SRS-CCP removed the 88th drum liner from consideration as it did not 

meet the definition of TRU waste and, hence, not eligible for WIPP disposal. Also, while 

additional process information and the CCP radiological characterization approach were included 

in Revision 1 of CCP-AK-SRS-500, the radiological data cited in the EPA finding was included 

in Revision 2 of CCP-AK-SRS-501. Therefore, the radiological characteristics of waste are 

adequately defined in the combination of the information presented in the revised CCP-AK-SRS500 and CCP-AK-SRS-501 reports, as well as supporting references. 

EPA Finding No. SRS-RH-AK-07-001F, Issue (b) Status: Based on the information 

examined, the EPA inspection team determined that the AK Summary had been adequately 

revised to address the above issues. EPA considers this aspect of the finding to be closed. 

(4) Data traceability was examined and found to be adequate upon incorporation of 

additional information. 

Data traceability was assessed to understand the hierarchy of information that was ultimately 

used by AK personnel to identify the physical and radiological parameters associated with this 

waste stream. SRS-CCP-BCLDP personnel provided the following information pertaining to 

data traceability: 

• Waste Packaging Records for Liners BC0127 (Pressure Wash Filters), BC0075, and 

BC003 (Liner in Canister) 

• Certification Paperwork for Liners BC0127 (Pressure Wash Filters), BC0075, and BC003 

(Liner in Canister) 

• HP Survey Report for Liners BC0127 (Pressure Wash Filters), BC0075, and BC003 

(Liner in Canister) 
28 

• CCP-AK-SRS-501, Appendix 3, Waste Container Dose to Curie Conversion Records 

(All 87 Drum Liners) 

• Calculation Packages P729, P7353, and P737 

This waste stream did not have individual records pertaining to isotopic characteristics of 

individual containers (i.e., data that associated the 69 swipe samples with specific containers or 

campaigns were not available, and individual drum data except for drum loading travelers were 

not available). The AKE stated that the liners were not typically packaged in the same room or 

cell where the wastes were generated, so there could be no correlation between wastes and their 

generation point. However, VE records document the origin of individual waste items within the 

liners and shows that multiple areas may have contributed to the waste in an individual drum 

liner. Typically for CH TRU wastes, EPA evaluates traceability of radiological measurements of 

waste containers (drums) during the on-site inspection. In the case of this RH waste stream, the 

measurements used to support the WC are historical, which complicates the data traceability 

evaluation. Assessing data traceability is necessary to understand the origin and hierarchy of 

radionuclide and physical data associated with each canister. See Sections 8.1 (1) and 8.1 (2), 

above, regarding deficiencies with respect to radionuclide data traceability and supportability. 

(5) Sufficiency of AK support documents and related document tracking was evaluated and 

was found to be adequate. 

A list of AK source document references was prepared using unique identifiers for the different 

document types following the format used by SRS-CCP for CH wastes. The listing is based on 

CCP-TP-005 Revision 18, Attachment 4. The listing was complete and was easy to understand, 

because it followed the same format used for CH waste streams. Several AK support documents 

were referenced in the text and these documents address the specific element or issue with the 

AK summary, although applicability does vary. EPA only examines support documentation 

specific to the technical element referenced in the AK summary that caused that support 

reference to be selected for examination. 

(6) Interpretation of WCPIP was evaluated with respect to contents of the Certification Plan, 

the CTP and the proposed characterization process and was found to be adequate. 

EPA’s RH WCPIP framework approval letter dated March 26, 2004, indicated that sites must 

generate a Certification Plan that explains how RH waste characterization will take place at each 

site, as well as a CTP. Based on the previous RH inspection experience, EPA determined that 

combining the Certification Plan and CTP in a single document that described the proposed 

characterization process would satisfy the EPA requirements. In this instance, however, EPA 

observed that language within the CTP is sometimes confusing, as indicated in Item 7 below. 

 

(7) Content and technical adequacy of the CTP was evaluated and found to be adequate. 

The WCPIP requires a description of the following items to be included in the CTP: 

• The waste stream or waste stream lots to which the plan applies 
29 

• The confirmatory testing proposed, including the percentage of waste containers that will 

be subject to confirmatory testing 

• The WC DQOs and quality assurance objectives (QAOs) that will be satisfied with the 

data being qualified 

• The DQOs and QAOs that will not be confirmed with the data being qualified and an 

explanation of how compliance with those DQOs and QAOs will be demonstrated 

• How the tested subpopulation is representative of the waste stream or waste stream lot 

The required bullets listed above are addressed in the CTP. In the case of this waste stream, the 

CTP also includes a discussion pertaining to AK accuracy and related DQOs. Because this 

specific waste stream deals solely with AK-based WC, an evaluation of AK accuracy is not 

applicable (other than to document this statement in an AK accuracy memorandum and within 

the CTP). Also, EPA has noted that the use of the term confirmation is sometimes confusing in 

that EPA regards confirmation to mean actual radiological measurement data or estimation of 

physical contents of a waste container to confirm AK information, but CCP has sometimes used 

the term in a broader sense when verification activities take place. EPA understands that the 

form and substance of the CTP is designed to meet the requirements stated in the WCPIP, but 

care should be exercised in future RH site documentations with regard to the use of the term 

confirmation. 

 

(8) Content and technical adequacy of the CRR was evaluated and the process was found to 

be adequate as using example data provided for this inspection. 

The EPA inspection team evaluated the CRR against requirements in CCP-TP-506, Revision 1, 

for Waste Stream SR-RL-BCLDP.001 to evaluate if this report reflected the requirements of 

CCP-TP-506, and to ensure that the CRR addressed requirement elements as specified in the 

WCPIP, including the following: 

• Specification of applicable site and waste stream 

• A listing of each DQO 

• Data from the AK record that addresses each DQO 

• AK source document references that support/provide the data 

• A listing of AK record DRs relevant to each DQO, if any 

• Documentation, including specific references, of how the AK data for each DQO were 

qualified, such as batch data reports, corroborative data, proceedings of a peer review, 

etc. 

• Real Time Radiography (RTR) and/or VE summary to document that liquids greater than 

1% are absent from the waste and to confirm AK concerning the physical properties of 

the waste 

• A summary presentation of radiological measurement data used to meet the DQOs and to 

confirm AK 
30 

• A complete AK summary 

• A complete listing of all container identification numbers used to generate the Waste 

Stream Profile Form (WSPF), cross-referenced to each BDR 

• A listing of AK discrepancies generated by an AK qualification process and the 

corresponding resolutions 

• Signature of the Site Project Manager (SPM) 

The example CRR that the EPA inspection team examined included all of the above WCPIP 

requirements. As had been observed previously for the RH WC programs at INL and Argonne 

National Laboratory-East (ANLE) (see Docket Nos. A-98-49, II-A4-72 and A-98-49, II-A4-73, 

respectively), the CRR DQO worksheet (Attachment 3 of CCP-TP-506) for this RH waste stream 

did not include a listing of the 10 WIPP-tracked radionuclides as part of the DQO assessment 

process. These radionuclides need to be specified, quantified, and assessed as part of the CRR. 

In the past, site representatives declined to specifically address these because it is not required by

the WCPIP. However, EPA requires information for the 10 WIPP-tracked radionuclides and the 

CRR generated at other CCP RH TRU sites must include the ten radionuclides. The reason for 

this is that for the WIPP Performance Assessment performed in conjunction with the WIPP 

Repository Recertification every 5 years, identification and quantification of the 10 WIPPtracked radionuclides is essential. 

Radiological characterization BDRs are not prepared, because the characterization is performed 

based solely on AK. However, SRS-CCP documents the compliance of each container with 

DQOs and other SPM approvals (signatures) on Attachments 1 and 2 of CCP-TP-506, and the 

results of this analysis are rolled up into Attachments 3 and 4 of CCP-TP-506. The EPA 

inspection team usually examines these individual attachments to ensure that complete, drumspecific documentation is kept for each container throughout the process, and to ensure that this 

information is adequately “rolled up.” During this inspection, only the single example draft 

attachment was available. SRS-CCP personnel stated that data will be manually downloaded 

from CCP-AK-SRS-501 into a WWIS controlled spreadsheet. When such data are entered 

manually, DOE needs to provide to EPA for review a copy of the WWIS spreadsheet showing 

manual data entries. 

(9) Use of a Correlation and Surrogate Summary Form was evaluated and was found to be 

adequate. 

Completion of a Correlation and Surrogate Summary Form is required when AK information 

from a related CH waste stream is used in the RH WC. The CCP AKE stated that to date, no CH 

surrogate container has been identified pertinent to this waste stream. 

(10) Personnel training was evaluated and found to be adequate. 

Training records for Sherri Nance and Rob Tayloe were examined. Ms. Nance’s training was 

evaluated with respect to training to the RH TRU WCPIP, non-conformance and corrective 

action processes, the AK procedure presented in Attachment A of the WCPIP, site-specific 

training relative to the contents of the subject waste stream(s), and determination of radiological 
31 

contents of individual drums. The Qualification Card examined demonstrated training in each 

area except for non-conformances (which should be not applicable for this waste stream) and the 

determination of the radiological contents of each drum. Where detailed radiological analysis 

and expertise are required, Messrs. Jene Vance and Rob Tayloe performed those tasks. The 

expertise of Messrs. Vance and Tayloe was examined and Mr. Tayloe’s resume was reviewed, 

since he was the CCP technical expert for radiological characterization. Although Mr. Tayloe 

did not show direct training with respect to this area, his resume showed considerable expertise 

suitable to demonstrating proficiency. In summary, the evaluated AKE and the radiological 

Subject Matter Expert demonstrated the necessary level of knowledge in the area of radiological 

assessment through on-the-job training. 

(11) Discrepancy Resolution (DR) Forms were examined and found to be adequate. 

Because measurement data were not collected for this waste stream and all characterization is 

based on AK, Non Conformance Reports (NCRs) were not created. Instead, issues identified 

were AK-AK in nature, so DR forms were created. DR numbers DR001 through DR0010 were 

provided within the CRR. The forms provided detail AK-AK discrepancies dealing with 

radiological data in JN-4, transfer pool construction dates, WMP percentage recalculation, 

evaporation of JN-1 pool water, analytical data pertaining to the JN-1 pool (not included in this 

waste stream), Resource Conservation and Recovery Act (RCRA) code assignment, waste 

generation parameter discrepancies, and JN-1 pool water prefilter radiological data (not included 

in this waste stream). Most of these documents were prepared prior to the current SRS-CCP 

documentation process, and the documents adequately address the DR process. When SRS-CCP 

addresses items 1 and 3 above, discrepant data may be identified that require resolution or at 

least documentation. When this occurs, EPA expects that all discrepancies identified will be 

documented on DR forms with the appropriate supporting documents, and that this information 

(if generated) will be placed in the AK record and provided to EPA for review. 

(12) A WSPF was examined and was found to be adequate. 

An example WSPF was examined for Waste Stream SR-RL-BCLDP.001. The form included the 

required items as presented in the WCPIP, Attachment 4; the CRR and RH AK summary are also 

required for submission to CBFO to allow assessment of the WSPF. EPA understands that this 

form was abbreviated, because it was provided for inspection purposes only, and expects that the 

completed form will include more AK data, checklists (as applicable), etc., to better present the 

required information. EPA expects to receive the completed WSPF for review when available. 

(13) AK accuracy was assessed for applicability and was adequately addressed in the context 

of this waste stream. 

The WCPIP requires determination of AK Accuracy in three areas: reassignment of the waste to 

a different SCG; reassignment of the waste to a different waste stream; and stream-specific 

assessment of radiological parameter accuracy. In the case of Waste Stream SR-RLBCLDP.001, all characterization was based on AK alone, so an accuracy determination based on 

measurement versus AK comparisons cannot be performed. SRS-CCP included a discussion of 

AK Accuracy in the CTP and an AK Accuracy Memorandum. In this document, SRS-CCP cites 
32 

comparisons of the modeling/sampling and AK data with respect to TRU waste determination 

qualification. CCP-AK-SRS-502 states that TRU waste determination qualification is 

accomplished through comparison of AK and drum liner (also AK) measurement results, while 

activity determination qualification was accomplished through AK-based modeling and AK 

sampling results. CCP-AK-SRS-502 also states that AK Accuracy DQOs for residual liquid and 

physical form are demonstrated through packaging records. While the comparisons do show that 

AK data are in agreement in the cited examples, the information does not address AK Accuracy, 

which addresses the comparison of confirmatory measurement data and the AK record. 

Therefore, EPA concludes that AK Accuracy cannot be assigned for this waste stream, because 

confirmatory sampling and analysis information were not obtained and, therefore, there is no 

information on which to base an assessment of AK Accuracy. 

(14) The use of load management for this waste stream was assessed and was determined to 

be not applicable at this time. 

The possibility that containers have TRU concentrations less than 100 nCi/g was evaluated. 

None of the drum liners were reported to have TRU concentrations less than 100 nCi/g. The 

SRS-CCP SPM stated that this waste stream will not undergo load management, so approval of a 

load management by EPA is not requested. Since these drum liners are not likely to be opened 

for repackaging or adding other TRU waste, EPA expects load management not to occur. In a 

highly unlikely event SRS-CCP considers load management, compliance with Appendix E of the 

TRU Waste Acceptance Criteria (WAC) is necessary. 

8.2 Radiological Characterization 

EPA evaluated the method by which the required radiological constituents for each waste 

container were determined. The nature of RH TRU wastes presents some difficulty with respect 

to obtaining meaningful measurement data, as is routinely done with CH TRU. Apart from the 

obvious personnel concerns associated with working in external radiation fields in excess of 

200 millirem per hour (mrem/hr), RH TRU waste containers typically contain concentrations of 

energetic photon emitters, i.e., 137Cs and/or 60Co that prevent a meaningful measurement-based 

isotopic determination. Accordingly, RH radiological characterization relies heavily on alternate 

methods such as the development of scaling factors that can correlate an easily measured 

parameter like external exposure (dose) rate with isotopic distributions for target radionuclides. 

Overview of SRS Radiological Characterization Program

SRS-CCP’s approach to radiological characterization is generally consistent with the 

requirements and guidance provided in the WCPIP. The overall approach to radiological 

characterization SRS-CCP used for the BCLDP RH waste has several elements in common with 

the RH characterization approach EPA observed in the LANL-CCP RH program during EPA 

inspection No. EPA-LANL-CCP-RH-5.07-8 (see Docket No. A-98-49, II-A4-89). During this 

RH inspection, the EPA inspection team evaluated the conceptual bases of the characterization 

approach, including: 
33 

• Evaluation of radiochemical analyses of 69 swipe or smear samples taken in the JN-1 

facility to support the development of scaling factors using ORIGEN2.2 results 

• Development of a DTC correlation as a function of waste density using Microshield® 

based on each waste liner’s measured external exposure (dose) rate, assuming the main 

contributor to the external exposure was 137Cs 

• Derivation of radionuclide scaling factors for the WIPP-tracked radionuclides using 

ORIGEN2.2 based on the attributes of LWR fuels 

With the exception of the use of radionuclide data from the swipe samples, these techniques have 

been evaluated in detail during previous RH inspections. For a thorough evaluation of the 

conceptual basis and application of DTC and the development and application of scaling factors, 

the reader is directed to the baseline inspection reports for these RH inspections (see Docket Nos. 

A-98-49, II-A4-72; A-98-49, II-A4-73; and A-98-49, II-A4-89). These characterization methods 

used for the BCLDP SRS RH wastes were evaluated in terms of the technical adequacy of the 

approach as supported by the SRS-CCP WC program’s documents, procedures, and controls, and 

the knowledge and understanding of the personnel involved in the RH WC program. 

Technical Evaluation

The EPA inspection team evaluated the following aspects: 

(1) The technical adequacy of the radiochemical swipe data was evaluated and was found to 

be adequate. 

CCP-SSR personnel stated that between 1996 and 1999 hundreds of swipe samples were taken 

from various areas within the JN-1 Facility as part of the site’s routine contamination control 

program. These samples were collected periodically, depending on the conditions or activities 

within the facility. Some of the swipe samples were also used to identify the radionuclide 

content of the subject waste stream and thee swipe sample assay results were used to support the 

derivation of radionuclide scaling factors. During these surveys, surfaces were identified for the 

collection of one or more swipe samples of floors, work surfaces, equipment, waste containers 

and tools that were subsequently submitted for radiochemical analysis. Table 4-2 of 

CCP-AK-SRS-501 lists the types of surfaces within JN-1 that were swiped. This process 

produced a total of 47 of swipes and 22 additional samples from high-efficiency particulate air 

filters from the ventilation system servicing areas within the JN-1 HCL for a total of 69 samples 

that were submitted for a suite of radiochemical analyses. The analyses consisted of: alpha 

spectrometry for isotopes of americium, uranium, plutonium and thorium10; gamma spectrometry 

for specific isotopes of cobalt, cesium, europium and antimony; and liquid scintillation counting 

for the beta-emitting 90Sr. 

The EPA inspection team did not observe objective evidence documenting the purpose for which 

the swipes were taken, although SRS-CCP personnel stated they were collected to support the 

 

10 SRS-CCP records do not indicate the specific methodology used to quantify 244Cm and 237Np although alpha 

spectrometry is the usual analytical approach used to identify and quantify these radionuclides. 
34 

development of radionuclide scaling factors, as stated in CCP-AK-SRS-501. SRS-CCP records 

indicate that while many of the 10 WIPP-tracked radionuclides were among the list of target 

radionuclides some were not, specifically 241Pu11 and 242Pu. SRS-CCP personnel stated that the 

radioanalytical values in CCP-AK-SRS-501 represent all the available values, and that it is 

possible that all 69 swipe samples were analyzed for the full list of target radionuclides but not 

all samples showed measurable values for these radionuclides. Accordingly, although 69 swipe 

samples were analyzed for 238Pu, 60Co and 90Sr, the analytical results showed 69 measurable 

values for 238Pu, 61 measurable values for 60Co and 13 measurable values for 90Sr. Analytical 

results that were not detected, i.e., below the assay system’s lower limit of detection (LLD)12 for 

a specific radionuclide, are not available. The numbers of usable values based on these analyses 

are shown in Table 4, below. Because the EPA inspection team was unable to determine how 

many swipe samples were taken in JN-1, it is not possible to establish what fraction of the total 

sampling effort within the JN-1 facility the 69 samples represent, which has bearing on the 

samples’ representativeness, as discussed in Sections 8.1 (1) and 8.2 (2), below. Based on the 

available information the EPA inspection team accepted that the 69 analytical results that are 

available constitute all useable radionuclide values discussed in Section 8.1 above and item (2), 

below. 

Table 4. Summary of the Reported Radionuclides in the 69 Smear Samples 

Radionuclide 

Number of Samples 

Analyzed 

Number of Values 

Above MDA 

Number of Values 

Below MDA 

241Am 69 69 0 

244Cm 69 69 0 

238Pu 69 69 0 

239Pu/ 240Pu 69 69 0 

60Co 69 61 8 

154Eu 69 54 15 

134Cs 69 49 20 

233U/ 234U* 29 24 5 

90Sr 13 13 0 

238U* 29 13 16 

235U/236U 29 4 25 

237Np 24 4 20 

230Th 24 12 12 

125Sb 69 8 61 

* Two anomalous uranium results were removed from population 

The analyses were conducted by a commercial laboratory (Data Chem) and by BMI. The criteria 

for deciding where the samples were analyzed are not clear but available information suggests 

that BMI performed all of the gamma spectrometry analyses, Data Chem performed the early 

 

11 241Pu is not one of the 10 WIPP-tracked radionuclides but it may be useful in developing radionuclide scaling 

factors. 

12 Although they are technical different, in this context the term LLD is taken to be synonymous with Minimum 

Detectable Activity (MDA). 
35 

alpha spectrometry analyses and BMI performed the later alpha spectrometry analyses. No 

formal evaluation of the Data Chem and BMI radioanalytical data provided by SRS-CCP was 

deemed unnecessary. Both laboratories provided report sheets that were reviewed during the 

inspection and examples of these are included in attachments to CCP-AK-SRS-501. The EPA 

inspection team reviewed a sampling of these data sheets for gamma spectrometry, alpha 

spectrometry and isotopic uranium from BMI and all were adequate. The swipe data are 

technically adequate and sufficiently documented to support the development of radionuclide 

scaling factors.

(2) Representativeness of Radiochemical Swipe Data 

 

The degree to which the 69 swipe samples that were subjected to radiochemical analysis are 

representative of the wastes that were handled within the JN-1 HCL is of key importance [see 

Section 8.1, (1), above]. Specifically, the contamination on the swipes must represent the types 

and characteristics of fuel rods that were handled in JN-1 to technically support the scaling factor 

development presented in CCP-AK-SRS-501. As discussed above, apart from the analytical 

results, initially SRS-CCP did not produce additional objective evidence to support the design or 

intent of the sample collection and analysis process. The most important piece of documentation 

would be a sampling plan, which would ideally discuss the measures taken to ensure that the 

samples collected were indeed representative of the materials used within the sampled area. 

Similarly, detailed information on the types and characteristics of fuel rods that were handled in 

the JN-1 was not available. Without this information, EPA cannot confirm that the 

areas/materials that were swiped are representative of the fuels that were handled in JN-1 on the 

basis of documentation. Accordingly, the EPA inspection team concluded during the July 2007 

inspection, that SRS-CCP’s contention that the swipes are representative was not adequately 

supported. This was discussed with SRS-CCP personnel during the inspection and EPA included 

this in the EPA finding discussed throughout this report. 

In the absence of documentation regarding sample collection, the EPA inspection team focused 

on an empirical determination to address the issue of representativeness. Because exact 

information regarding the contribution of the fuels handled within JN-1 was unknown, the 

average scaling factors for all fuel types, i.e., LWR, highly enriched uranium (HEU) and 

thorium, were plotted against the scaling factors derived from the swipe data and the application 

of ORIGEN2.2. The comparison is shown in Figure 5-1, of CCP-AK-SRS-501 and is 

reproduced in this report as Figure 2, below. This plot indicates good agreement between the 

results of the swipe analyses and the characteristics of LWR fuel for the majority of the 

radionuclides, with the exception of 230Th, the uranium isotopes and 154Eu. SRS-CCP personnel 

stated that these differences can be explained based on: a lack of equivalent data for 230Th; the 

unexpected processing of unirradiated fuel which would skew the uranium values; and, simple 

radioactive decay of 154Eu due to its shorter physical half-life. These issues are discussed in 

detail in CCP-AK-SRS-501, Revision 2. 
36 

Figure 2. Comparison of Scaling Factors Representative of Different Fuel Types Against 

Average Smear Sample Scaling Factors 

Upon examination during and after the inspection, the EPA inspection team personnel agreed 

that the empirical demonstration shown in Figure 2, below, had considerable technical merit. 

EPA’s acceptance of SRS-CCP’s assertion of representativeness is based on the technical merit 

of the empirical demonstration, as discussed in the preceding paragraph. EPA inspection team 

personnel revisited this issue following revision of CCP-AK-SRS-501 and the other documents 

discussed in Section 8.1 (1), above, during the July and December 2007 meetings. The revised 

documents provide additional details relative to the representativeness of the swipe samples. 

However, the lack of specific information regarding the design or intent of sample collection is a 

weakness. In the future, when sample collection plays as important a role in a site’s RH WC 

program as it does for this waste stream, EPA will require that the site provide a sampling plan 

as required as part of EPA’s site procedures review and approval prior to the baseline inspection. 

Based on the strength of the empirical demonstration supported by the revised documents, EPA 

agrees that there is sufficient support for SRS-CCP’s contention that the swipes are 

representative of the attributes of LWR. Also, as discussed in Section 8.1 above, based on the 

additional documentation provided by CCP, EPA concurs that the 69 swipe samples are 

representative of the different fuel types handled in the hot cell. 

1.0E-09

1.0E-08

1.0E-07

1.0E-06

1.0E-05

1.0E-04

1.0E-03

1.0E-02

1.0E-01

1.0E+00

TH230

U233/4U235/6

U238

PU238

PU239/40

AM241

CM244

SR 90

SB125

CS134

EU154

Scaling Factor

Thorium

LWR

HEU

Sample Data
37 

(3) The development of radionuclide scaling factor was evaluated and found to be technically 

adequate. 

In the absence of specific fuel irradiation data, information regarding the fuels materials’ 235U 

content, burn-up and decay was selected based on the assumption that the majority of the TRU 

materials within the JN-1 facility were LWR fuels. Ranges for these parameters were developed 

in 1999 [see Section 8.1 (1)] as input for 1000 ORIGEN2.2 calculations, the results of which 

were used to derive radionuclide scaling factors for 

241Am, 238Pu, 239Pu, 240Pu, 241Pu, 242Pu, 234U,

235U, 238U and 60Co plus the fission product 154Eu. These scaling factors were compared with 

radionuclide-specific data generated by the radiochemical analysis of 69 swipe samples that were 

collected from locations inside the JN-1 facility, as discussed in the previous section. The 

scaling factor for 233U was developed exclusively on the basis of the 234U results of the swipe 

sample analyses, as discussed below. The determination of 154Eu and 60Co was necessary to 

account for their potential contribution to the measured dose rate and to identify all radionuclides 

that contribute to 95% of each liner’s radiological hazard13

. 

The EPA inspection team evaluated the following aspects: 

• Activity values that are used are derived from modeling and statistical metrics that 

support their use, and the statistical metrics include mean and standard deviation values 

for each measured radionuclide. 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute. 

• Isotopic activity values are correlated to each drum liner’s major radionuclide content(s) 

responsible for the measured external dose rate, i.e., 137Cs and 60Co. 

• The calculated results used to develop the factors and convert the measured external dose 

rates to radionuclide activity levels. 

• Calculations supporting the scaling factors were performed using appropriate shielding 

analysis techniques, i.e., Microshield®

. 

Regarding the second bullet, above, Revision 1 of CCP-AK-SRS-501 did not cite the source of 

the specific activity and physical half-life values, although SRS-CCP personnel stated that these 

values were taken from the CH TRAMPAC. The lack of this reference was included in EPA 

Finding No. SRS-RH-AK-07-001F, which is discussed in Section 8.2 (7), below. All references 

were appropriately cited in Revision 2 of CCP-AK-SRS-501 that the EPA inspection team 

reviewed during the December 2007 meeting, which closed this part of the finding. 

The purpose of a radionuclide scaling factor is to provide a technically sound method of deriving 

values for the 10 WIPP-tracked radionuclides within each container based on the container’s 

 

13 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this

information may be useful in understanding other aspect of a container’s radiological characterization. 
38 

measured external dose rate. ORIGEN2.2 was used to derive scaling factors for all of the 

reportable radionuclides based on the ranges of the three parameters listed below as input: 

•

235U enrichment – 2.0 to 4.0 (weight percent) 

• Burn-up – 15k through 45k 

• Decay (years post-irradiation to 2002) – 13 through 30 

These ranges were based on the assumption that the materials processed in the JN-1 HCL were 

predominantly LWR fuels, which is discussed earlier in this report. With the exception of 233U, 

the scaling factor for each radionuclide was determined by taking the arithmetic mean of 1000 

ORIGEN2.2 runs. The treatment of 233U is addressed below. The scaling factors are multiplied 

by the 137Cs concentration, which is derived based on the measured dose rate of each drum and 

the DTC technique discussed below. The mass (gram) quantities of the actinides were extracted 

from the ORIGEN2.2 output results along with the activity (curie) quantities of the fission 

products. Mass and activity values can be converted interchangeably using the specific activity 

values provided in the Contact-Handled Transuranic Waste Authorized Methods for Payload 

Control (CH-TRAMPAC). The average scaling factors representing the total fuel pin population 

were calculated by taking the ratios of the average curies of each radionuclide to the average 

curies of 137Cs in a metric ton of fuel. These averages are the actual scaling factors used to 

derive the quantities and distribution of the radionuclides for all 87 drum liners in this population 

of BCLDP RH wastes. The standard deviation for each radionuclide was used to calculate the 

relative standard error associated with its variation in the fuel compositions. CCP-AK-SRS-501, 

Table 6-1, lists the scaling factors derived in this manner for each of the radionuclides that was 

used to characterize the 87 drum liners. This table is reproduced as Table 5, below, and lists the 

scaling factors in units of curies of each radionuclide per curie of 137Cs (Ci/Ci 137Cs). 

The scaling factor for 233U was developed from the geometric mean of the swipe sample data 

discussed in a previous section. Because the analytical technique of alpha spectrometry is unable 

to resolve the peaks of 233U and 234U, the 233U activity would be reported as 234U, a value that 

includes both 233U and 234U. To provide an upper estimate of both radionuclides, the scaling 

factor derived for 234U based on the swipe sample data is used for 233U also. 
39 

Table 5. Radionuclide Scaling Factors 

Radionuclide 

Scaling Factor, 

Ci/Ci 137Cs 

U-233 5.12E-05 

U-234 2.59E-05 

U-235 3.58E-07 

U-238 5.89E-06 

Pu-238 3.41E-02 

Pu-239 5.83E-03 

Pu-240 9.48E-03 

Pu-241 6.87E-01 

Pu-242 3.01E-05 

Am-241 5.00E-02 

Cm-244 1.76E-02 

Co-60 2.27E-02 

Sr-90 6.77E-01

Y-90 6.77E-01 

Cs-137 1.00E+00 

Ba-137m 9.46E-01 

(4) The DTC Correlation was evaluated and found to be technically adequate. 

 

The DTC correlation was based on the following assumptions: 

• The waste density was uniform within the liner. 

• All liners were nearly completely filled with waste material. 

• An iron matrix is the most representative, i.e., photon attenuation is primarily a function 

of the matrix density rather than composition. 

• The vast majority of the measured external exposure rate consists of 137Cs and/or 60Co. 

Using Microshield®

, SRS-CCP developed a DTC correlation for the drum liner configuration 

illustrated in Figure 1 and expressed it in terms of Roentgen per hour per curie of 137Cs (R/hr/Ci 

of 137Cs). This was based in large part on the shielding calculations for a BCLDP liner filled 

with RH TRU waste assuming a 1curie source of either 

137Cs or 60Co uniformly distributed about 

the waste. Figure 3, below, shows the results of these calculations and the polynomial fit to the 

calculated data for 137Cs and 60Co as a function of waste density. This plot is a composite of 

Figures 3 and 4 from SRS-RH-02, Revision 1, and is also presented in CCP-AK-SRS-501 as 

Figure 7-3. 
40 

Figure 3. DTC Correlations as a Function of Waste Density at a Distance of 1 meter 

Centered on a RH TRU Drum Liner 

The DTC calculations were performed using an EXCEL spreadsheet using the container’s gross 

weight, the estimated fill percentages, and the two dose rate measurements as input. An example 

of the DTC spreadsheet is shown in Figure 4 for an actual BCLDP RH-TRU waste drum liner, 

using measured dose rates and container weights from 2002 and the more recently developed 

radionuclide scaling factors described above. The uncertainties shown in the spreadsheet are 

associated with this drum liner and indicate the relative magnitude of the overall uncertainties in 

each of the radionuclide quantities listed on the spreadsheet. 

y = 20.615x2 - 107.2x + 197.8

R

2

 = 0.9995

y = 57.41x2 - 349.19x + 794.6

R

2

 = 0.9999

0

100

200

300

400

500

600

700

800

0 0.5 1 1.5 2 2.5

Waste Density in Grams/cm3

Dose 

Rate, 

R/hr

One Meter Cs-137 Dose Rate, mR/hr/Ci One Meter Co-60 Dose Rate, mR/hr/Ci

Poly. (One Meter Cs-137 Dose Rate, mR/hr/Ci) Poly. (One Meter Co-60 Dose Rate, mR/hr/Ci)
41 

 Waste Container Dose-to-Curie Conversion Record 

 DTC Spreadsheet Version 1 102307 

 

Date of Survey 8/22/2002 

Waste Stream Designation SR-RL-BCLDP.001 

Container Number BC00AA 

Container Gross Weight 147.4 kg 

Estimate Fill Percentages 100 % 

Container Net Weight 46.7 

Measured Container Dose Rate 

 Detector #1 100 mR/hr 

 Detector #2 100 mR/hr 

Calculated Average Dose Rate 100 mR/hr 

 

Nuclide 

Curie 

Scaling 

Factors 

Activity 

(Ci) Grams FGE PECi Watts Uncertainty 

Uncertainty 

in Curies 

Uncertainty 

in Grams 

U-233 5.12E-05 2.81E-05 2.88E-03 2.59E-03 7.21E-06 8.18E-07 164.41% 4.62E-05 4.73E-03 

U-234 2.59E-05 1.42E-05 2.25E-03 0.00E+00 0.00E+00 4.09E-07 85.55% 1.22E-05 1.92E-03 

U-235 3.58E-07 1.96E-07 8.97E-02 5.77E-02 0.00E+00 5.42E-09 101.10% 1.99E-07 9.07E-02 

U-238 5.89E-06 3.24E-06 9.52E+00 0.00E+00 0.00E+00 8.20E-08 65.33% 2.11E-06 6.22E+00 

Pu-238 3.41E-02 1.87E-02 1.08E-03 1.22E-04 1.70E-02 6.20E-04 76.34% 1.43E-02 8.26E-04 

Pu-239 5.83E-03 3.20E-03 5.09E-02 5.09E-02 3.20E-03 9.92E-05 64.30% 2.06E-03 3.27E-02 

Pu-240 9.48E-03 5.21E-03 2.27E-02 5.10E-04 5.21E-03 1.62E-04 62.80% 3.27E-03 1.42E-02 

Pu-241 6.87E-01 2.90E-01 2.79E-03 6.28E-03 5.69E-03 9.23E-06 79.63% 2.31E-01 2.22E-03 

Pu-242 3.01E-05 1.65E-05 4.16E-03 3.12E-05 1.50E-05 4.87E-07 88.12% 1.46E-05 3.67E-03 

Am-241 5.00E-02 3.04E-02 8.76E-03 1.64E-04 3.04E-02 1.02E-03 76.10% 2.31E-02 6.66E-03 

Cm-244 1.76E-02 7.85E-03 9.60E-05 8.64E-06 4.13E-03 2.70E-04 152.91% 1.20E-02 1.47E-04 

Cs-137 1.00E+00 4.85E-01 5.51E-03 0.00E+00 0.00E+00 5.36E-04 54.30% 2.63E-01 2.99E-03 

Ba-137m 9.46E-01 4.59E-01 8.53E-10 0.00E+00 0.00E+00 1.81E-03 54.30% 2.49E-01 4.63E-10 

Sr-90 6.77E-01 3.26E-01 2.36E-03 0.00E+00 0.00E+00 3.78E-04 55.75% 1.82E-01 1.32E-03 

Y-90 6.77E-01 3.26E-01 5.99E-07 0.00E+00 0.00E+00 1.80E-03 55.75% 1.82E-01 3.34E-07 

Totals 1.95E+00 9.71E+00 1.18E-01 6.57E-02 6.70E-03 

 

 Value (one Sigma) 

TRU Alpha Activity Concentration 1.23E+03 6.55E+02 nCi/g 

TRU Alpha Activity 5.75E-02 3.06E-02 Ci 

Total Pu-239 Equiv Activity 6.57E-02 3.57E-02 Ci 

Total Pu-239 Fissile Gram Equiv 1.18E-01 7.39E-02 g 

Total Decay Heat 6.70E-03 3.62E-03 W 

Volume Activity 1.72E-02 9.69E-03 Ci/L 

Figure 4. Example Waste Drum DTC Conversion Record
42 

(5) The definition of this RH waste stream was assessed and found to be adequate. 

This inspection focused on a group of 87 drum liners of RH wastes that SRS-CCP stated were 

contained in a single waste stream, all of which were generated from the D&D of the JN-1 HCL 

under the BCLDP. The EPA inspection team concluded that the assignment of all 87 RH drum 

liners to a single waste stream was technically supportable. 

(6) Several technical aspects of the radiological characterization process were evaluated and 

were found to be acceptable. 

Fourteen calculation packages were prepared and reviewed by Jene Vance, Jim Holderness, Rob 

Tayloe and Larry Porter to document development of the scaling factors and the DTC correlation 

discussed above. These packages provide the technical basis for several aspects, including: 

• Application and verification of Microshield®

 and ORIGEN2.2 

• Evaluation of all potential contributors to a container’s dose rate, specifically 137Cs and

60Co, and addressing contribution of other fission products 

• Development and comparison of scaling factors for three fuel types: LWR, thorium uel, 

and HEU 

• The nature and history of the LWR fuels examined in the JN-1 facility 

• Decay correction of the BCLDP swipe data used to confirm the ORIGEN2.2 LWR 

calculations 

• Potential sources of uncertainty [see total measurement uncertainty (TMU), below] 

The EPA inspection team members reviewed these 14 packages during the July 2007 inspection 

and discussed them with the documents’ authors and other SRS-CCP personnel. During these 

discussions, the EPA inspection team questioned several aspects and identified instances where 

modifications to the calculation packages were required. Some of the modifications required a 

formal revision of the calculation package (see “Documents Reviewed” in Section 8.0, above). 

The EPA inspection team reviewed the revised documents at the December 2007 meeting and 

also had the opportunity to discuss all technical concerns and discrepancies with SRS-CCP 

personnel. The EPA inspection team found the revised calculation packages to adequately 

document the technical activities upon which the radionuclide scaling factors were based. All 

technical issues related to the documentation of technical aspects of the SRS-CCP RH WC 

approach were resolved. 

(7) Evaluation of TMU was performed and found to be adequate following revision of 

specific SRS-CCP documents. 

 

The development of TMU for the 87 drum liners in Waste Stream SR-RL-BCLDP.001 is based 

on the propagation of uncertainties present in all aspects of the determination of the radiological 

constituents of RH TRU waste. The TMU determination included the contributions of: 
43 

• Drum liner weight measurement 

•

137Cs measurement uncertainty 

• Scaling factor uncertainty 

• MicroShield®

 issues 

• Other gamma emitters

• Individual fuel pin contribution to the total in waste liner

• Burnup history 

• Internal code issues 

• Modeling 

The treatment of TMU is presented in CCP-AK-SRS-501, Revision 1, and Calculation Package 

No. SRS-RH-06, Revision 0, “Uncertainty Analysis.” During the July 2007 inspection, the EPA 

inspection team determined that these documents did not adequately present the technical basis 

for the TMU related to the SRS-CCP BCLDP wastes, as discussed below. Additionally, 

operational aspects of the TMU process were not adequately documented. This issue was 

discussed with SRS-CCP personnel during the July 2007 inspection and was included as one 

aspect of Issue (d) in EPA Finding No.SRS-RH-AK-07-001F (see Attachment A of this report 

for a copy of this form). The other aspect of Issue (d) is addressed in Section (7), below. 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d): The technical basis for the characterization 

of these RH wastes with respect to the documentation of Total Measurement Uncertainty (TMU) 

was not adequately documented in CCP-AK-SRS-501, Revision 1 and Calculation Package No. 

SRS-RH-06, Revision 0. 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Resolution: Following the July 2007 

inspection, SRS-CCP produced Revision 2 of CCP-AK-SRS-501, and Revision 1 of SRS-RH06, both of which were reviewed by the EPA inspection team member assessing radiological 

characterization during the December 2007 meeting. Both documents had been modified to 

better present the technical basis for the TMU determination and to appropriately document the 

process. They included contributions of all pertinent aspects of the TMU, which are summarized 

in CCP-AK-SRS-501, Table 8-3, and reproduced as Table 6, below. Upon reviewing the revised 

documents the EPA inspection team determined that the treatment of TMU for the BCLDP RH 

wastes was technically adequate and appropriately documented and that the aspect of this issue 

related to TMU was addressed. 

 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Status: This issue is closed. 
44 

Table 6. Overall Uncertainty Listed by Radionuclide at a Density of 1.0 g/cm3

Radionuclide 

Dose Rate 

Measurement 

Uncertainty 

Other 

Gamma 

Emitters 

Microshield®

Code 

Uncertainty 

Microshield®

Model 

Uncertainty 

Scaling 

Factor 

Uncertainty 

Total 

Uncertainty 

233U 25.0% 45.6% 10.0% 31.4% 155.2% 167.0% 

234U 25.0% 45.6% 10.0% 31.4% 66.1% 90.4% 

235U 25.0% 45.6% 10.0% 31.4% 85.3% 105.2% 

238U 25.0% 45.6% 10.0% 31.4% 36.3% 71.5% 

238Pu 25.0% 45.6% 10.0% 31.4% 53.7% 81.7% 

239Pu 25.0% 45.6% 10.0% 31.4% 34.4% 70.6% 

240Pu 25.0% 45.6% 10.0% 31.4% 31.6% 69.2% 

241Pu 25.0% 45.6% 10.0% 31.4% 58.2% 84.8% 

242Pu 25.0% 45.6% 10.0% 31.4% 69.4% 92.8% 

241Am 25.0% 45.6% 10.0% 31.4% 53.3% 81.5% 

244Cm 25.0% 45.6% 10.0% 31.4% 143.0% 155.7% 

90Sr 25.0% 45.6% 10.0% 31.4% 12.6% 62.9% 

137Cs 25.0% 45.6% 10.0% 31.4% N/A 61.6% 

 

(8) Radionuclide Documentation in lieu of BDRs was assessed and found to be adequate 

upon revision of specific SRS-CCP documents. 

The 87 drum liners of SRS-CCP RH TRU waste were not documented in BDRs, as is typically 

done at TRU waste sites. Instead, the formal documentation for each canister’s radionuclide 

values was presented in CCP-AK-SRS-501, Revision 1, Attachment 3, pages 47 through 134. 

The EPA inspection team verified that the data sheet for each RH TRU liner contained the 

following information: 

• Container number 

• Waste stream designation 

• Net waste weight 

• Waste material type 

• Measured dose rates from two detectors and the calculated average dose rate in mR/hr 

• Scaling factor in grams or curies per mR/hr 

• Activity values and uncertainties for the 10 WIPP-tracked radionuclides in nCi/g 

• TRU alpha activity and concentration 

• Plutonium equivalent curies (PE Ci) in curies 

• Fissile gram equivalents (FGE) in grams 
45 

• Decay heat in watts 

• Volume activity in curies per liter 

There were several aspects of CCP-AK-SRS-501, Revision 1, that required clarification, and 

these prevented a complete technical evaluation of the radiological characterization of the 87 RH 

TRU drum liners during the Denver inspection. These aspects were discussed with SRS-CCP 

personnel during the inspection, and were included as the second aspect of Issue (d) in EPA 

Finding No. SRS-RH-AK-07-001F, part of which is discussed in Section (6), above (see 

Attachment A of this report for a copy of this form). The other aspects of this finding related to 

radiological characterization are discussed below. 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d): The general issue was that 

CCP--AK-SRS-501 did not adequately document the technical basis for the characterization of 

these RH wastes with respect to the development of radionuclide scaling factors. The specific 

issues are as follows: 

• CCP-AK-SRS-501 provides the technical basis of the derivation of the radionuclides 

values for each of the 87 RH TRU drum liners. This document is based on statistical 

treatments of various data sets that are presented in the calculation packages listed in 

Section 8.0 above. However, the statistical approaches incorporate both simple 

arithmetical means and standard deviations, as well as geometric mean and standard 

deviations, and the documentation of which statistic is used is often unclear. It appears 

the incorrect statistic is used in some cases, but the calculation packages are not 

sufficiently clear to allow their technical evaluation. 

• CCP-AK-SRS-501 contains several areas that require rewriting to accurately document 

the technical basis of a specific aspect of the radiological characterization process. 

Examples include: clarification that the uncertainty for 233U is based on the standard 

deviation of the 234U; treatment of the LLD; inclusion of references for specific activity, 

decay heat, etc.; and addressing where in the process the TRU determination is 

performed. 

 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Resolution: CCP-AK-SRS-501 and other 

calculation packages were revised appropriately and were provided to EPA at a December 2007 

meeting (see “Documents Reviewed” in Section 8.0, above). The statistical inconsistencies in 

CCP-AK-SRS-501 and the accompanying calculation packages were corrected, as documented 

in the revised documents the EPA inspection team reviewed. Clarification regarding the 233U 

uncertainty, additional details regarding the LLD, and the appropriate references for specific 

activity, decay heat and other derived quantities were included (CH-TRAMPAC) in the revised 

documents made available to EPA at the December 2007 meeting in Carlsbad, New Mexico. 

The treatment of TMU presented in Revision 2 of CCP-AK-SRS-501 provides details that were 

missing from Revision 1 that was evaluated at the July 2007 meeting in Denver. Revision 2 of 

CCP-AK-SRS-501 and the revisions of the accompanying calculation packages discussed earlier 

contained sufficient technical details to adequately address the EPA concern. 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Status: This issue is closed. 
46 

(9) RH and TRU determinations were evaluated and found to be adequate. 

The records addressing the determination that the 87 RH TRU drum liners met the definition of 

TRU wastes (TRU alpha activity concentration greater than 100 nCi/g) and RH waste (contact 

dose equivalent rate in excess of 200 mrem/hr) were examined, as discussed below. 

• TRU definition: As stated previously, BDRs were not prepared for the 87 RH TRU drum 

liners in this waste stream. The radionuclide values that were determined for the liners 

are contained in CCP-AK-SRS-501, Attachment 3, pages 47 through 134. All liners 

indicate TRU concentrations greater than 100 nCi/gram. 

• RH definition: The external exposure rate (dose rate) measurements of each of the RH 

TRU liners were made at the time the liners were filled, and the measured values are 

recorded on Health Physics Survey Reports Form DDO-138 in mR/hr. All measurements 

were made at a distance of 1 meter at the midpoint of the liner’s height in two locations 

180o degrees apart, i.e., at the three o’clock and nine o’clock positions, and the value 

recorded for each liner was the arithmetical average of both measurements. The 

documentation examined during the inspection shows that radiation surveys were 

controlled by a formal, written procedure, HP-OP-019, “Radiation and Contamination 

Survey Techniques”; survey procedures cite the appropriate consensus standard, 

ANSI/NCSL Z540-1; all dose rate measurements were made with the appropriate type of 

instrument; the serial number for each instrument was listed; all instruments had a current 

calibration at the time of measurement; and all surveys were performed under a radiation 

work permit that was identified. The measurement records for the liners indicate external 

dose rates greater than 200 mR/hr in all cases. 

There were no concerns regarding the TRU and RH determinations for Waste Stream 

SR-RL-BCLDP.001. 

8.3 Physical Form and Prohibited Item Characterization – Visual Examination 

From July 31 through August 1, 2007, EPA performed an inspection of SRS-CCP’s VE activities 

for RH TRU waste from the BCLDP in storage at SRS. SRS-CCP possesses both written and 

audio/video records of packaging of 87 drum liners from Waste Stream SR-RL-BCLDP.001. 

During this inspection EPA’s focus was on independent verification of the acceptability of VE 

data contained within the historic records. The review took place at the CBFO offices located in 

the Skeen Whitlock Building in Carlsbad, New Mexico. 

The VE data reviewed were generated between late 1999 and late 2002, in accordance with 

procedure TC-OP-01.4 and work instructions WI-956 and 958. The procedure had been revised 

during this time period and SRS-CCP had retrieved Revisions 1 and 2 but did not possess 

Revision 0. Training of VE personnel was performed in accordance with TCP-98-05 and 

TRU-100. 
47 

(1) Training of VE personnel was assessed and found to be adequate. 

All of the personnel who performed VE were contract employees, and all had been trained to 

applicable site procedures. How these employees were used is documented in the interface 

document TCP-98-04. The practice at the time the RH drum liners were packaged was to 

destroy old training records as new ones were generated. Consequently, SRS-CCP could not 

obtain complete training records for all VE personnel that were involved in the BCLDP project. 

However, EPA was able to review some training records from the packaging time period, 

approximately 1999 to 2002. 

Procedure TC-OP-01.4 refers to a Visual Examination Expert (VEE) performing the 

examinations. From the activities performed, EPA concluded that at the time of packaging 

Waste Certification Officials (WCOs) were equivalent to present day VEEs and VEEs were 

equivalent to present day VE operators. VE operators and VEEs were required to read 

procedures and be re-qualified every three years. 

(2) Audio/video and written records were reviewed and found to be adequate. 

The EPA inspection team selected a random sample of four RH drum liners containers to review 

during this inspection, Nos. BC0035, BC0051, BC0070, and BC012. Because drum liners were 

filled over extended periods of time, the recordings for many containers were recorded on 

multiple tapes. For example, the VE of container No. BC0035 is recorded on tapes E00025, 

E00034, E00035, E00036, E0038, E00038, E00039, and E00040. Two types of recordings were 

made, one from a movable focus/angle camera and one from a fixed camera. Although the 

movable camera images are required to review the VE event, the fixed camera image shows a 

much wider field of view and provides a superior overview of the process. For the purpose of 

this inspection, EPA reviewed the movable camera audio/visual tapes for selected packages. 

They were evaluated as follows: 

• BC0035, packages 15, 29, 59, and 66: The EPA inspection team did briefly review the 

static video for this drum liner but it was not possible to verify the waste items placed in 

the receiving container using this recording. However, using the movable camera 

recording the EPA inspection team verified that the waste items individually placed into 

the receiving container were correctly identified and recorded. The waste items in this 

drum liner included plastic, rubber, cloth, and paper. The original packaging took place 

in November 2000 and was reviewed in October 2002. The revision date for the TRU 

Waste Packaging Loading Record, Loading – Itemized Data record was February 1999. 

• BC0051, packages 7 and 17: The majority of waste in this drum liner was steel and other 

metals. The original packaging took place during July and August 2000 and review of 

the paper and visual records was performed in February 2003. The EPA inspection team 

did not identify any discrepancies between the written and visual/audio records. The 

revision date for the TRU Waste Packaging Loading Record, Loading – Itemized Data 

record was February 1999. 

• BC0070, packages 11 and 14: The revision date for the TRU Waste Packaging Loading 

Record, Loading – Itemized Data record was August 2001. This revision of the sheet 
48 

required additional information to be recorded, including the number of the liner filter, 

drum filter number and seal, and WMC. This drum liner arrived in the processing area 

already full of waste. The waste was tipped onto the sorting tray, identified, and then 

loaded. Similar waste items were loaded into opaque, white buckets, which were then 

emptied into the receiving container. Placing of items in the white buckets was not 

recorded, but the items from each bucket were called out (identified orally), as it was 

loaded. This was discussed with SRS-CCP and the EPA inspection team agreed that this 

method of drum liner loading did not compromise the technical adequacy of the VE data. 

Packaging took place in June 2002 and the records were reviewed in November 2002. 

• BC0120, packages 4 and 7: This bucket was empty when first viewed on the audio/visual 

recording. The VE process for this container was similar to the process used for BC0070, 

because the placing of items in white buckets was not recorded. Waste items were 

identified as they were tipped into the receiving container. Packaging took place in 

December 2001, and the records were reviewed in January 2002 and November 2002. 

The absence of prohibited items was verified during packaging and review of records and no 

discrepancies between the written and visual/audio records for these drum liners were identified. 

The EPA inspection team determined that WMPs were correctly identified and the physical form 

of the waste was verified. There are no issues related to the use of VE for SRS-CCP RH TRU 

wastes as a result of this inspection. 

8.4 WIPP Waste Information System 

From July 31 through August 1, 2007 EPA reviewed SRS-CCP’s WWIS activities for RH TRU 

waste in Carlsbad, New Mexico because access to the WWIS database and CCP personnel 

responsible for maintaining the database were readily available at that location. 

EPA previously approved this process and the purpose of this review was to ensure continued 

compliance with the requirements of the WCPIP. At the time of the review, a total of 132 RH 

waste containers from INL and ANLE had been emplaced in the WIPP repository, and an 

additional 68 RH waste containers had been approved for shipment. The EPA inspection team 

interviewed a CCP WCO and investigated the CCP WWIS procedure by reviewing data for 

Canister No. ID0051. The canister housed three containers of RH waste, Container Nos. 

001131, 001141, and 001143, from RH Waste Stream ID-ANLE-S5000. The same CCP WWIS 

procedure is used for RH wastes from all DOE sites.

Since EPA approval, CCP has successfully submitted characterization and certification data into 

WWIS for RH waste from INL and ANL. EPA had conducted a baseline inspection at both sites 

and approved them for RH WC activities previously. The DTC, VE, or RTR data sheets are used 

to populate a WWIS Data Entry Summary spreadsheet. The WCO interviewed was able to 

retrieve the spreadsheet and characterization data sheets for container No. 001131. The EPA 

inspection team verified that the spreadsheet information matched that in the WIPP Waste 

Container Report for this container. No discrepancies were identified. The WIPP Waste 

Container Report for Canister No. ID0051 was also retrieved and reviewed. Using the WIPP 

Waste Container Reports for the internal containers, the EPA inspection team verified that there 

were no data errors or discrepancies between these reports. 
49 

The EPA inspection team verified that all WMPs for each RH container were reported to WWIS 

as plastic. EPA calculated the material parameter weights provided in the Waste Container Data 

Report for each of the inner containers of Canister No. ID0051 and ensured that value was the 

same as the reported container gross weight. No discrepancies were found for the three 

containers the EPA inspection team reviewed. 

Prior to submitting container data to the WWIS for certification, the NCR and Corrective Action 

Report (CAR) status of each container was verified. Container data were uploaded to WWIS 

after this check, based on information that was obtained from CCP QA personnel. EPA verified 

this process by reviewing an email verifying the NCR/CAR status for containers in INL RH 

Lot 9. If data were rejected by WWIS, actions were taken to correct and resubmit the data. EPA 

verified this process by reviewing the history for Container No. 001117 that was rejected by 

WWIS on June 7, 2007. CCP resolved the data issue and successfully resubmitted the container 

to WWIS on July18, 2007. As required by the WCPIP, all WMPs are reported to WWIS as 

plastic. CCP continues to successfully submit RH TRU data for both characterization and 

certification to WWIS. There were no issues relative to CCP’s implementation of the WWIS for 

RH TRU wastes identified during this audit. 

8.5 Attainment of Data Quality Objectives 

 

(1) Verification methods for each DQO were assessed and found to be compliant with the 

WCPIP. 

SRS-CCP-BCLDP representatives indicated that AK is the basis for all characterization, and AK 

will be qualified entirely through demonstration of an equivalent QA program. As indicated 

previously, this approach comports with requirements set forth in the WCPIP. 

 

(2) Attainment of DQOs was evaluated and found be adequate. 

As a result of the analyses presented in Sections 8.1 through 8.4, above, the EPA inspection team 

assessed how each DQO was addressed. As required in the WCPIP, the following DQOs must 

be addressed: 

• Defense determination 

• TRU waste determination 

• RH waste determination 

• Activity determination (TRU alpha activity per drum liner, including identification and 

quantification of 10 WIPP-tracked radionuclides) 

• Residual liquids 

• Physical form, including metals and cellulosics, plastic and rubber 

All DQOs are based on AK that is verified through demonstration of an equivalent QA program, 

and EPA has assessed each element for its technical merit based on the AK record. EPA 

concludes that SRS-CCP-BCLDP has adequately presented how DQOs will be obtained. 
50 

9.0 RESPONSE TO COMMENTS 

On May 21, 2008, EPA issued an FR notice (73 FR 29504-29507) proposing approval of the RH 

TRU debris waste from BCLDP and WC processes SRS-CCP used when characterizing this 

waste. EPA received one comment that was sent to Docket ID No. EPA-HQ-OAR-2008-0410. 

The actual comment was an enclosure to a July 3, 2008 letter and is included below verbatim, 

followed by EPA’s response to the comment. 

Comment:

Comments concerning the United States Environmental Protection Agency (EPA) 

Proposed Approval of the Central Characterization Project’s Remote-Handled Waste 

Characterization Program at the Savannah River Site published in the Federal Register 

on Wednesday May 21, 2008, Volume 73, No. 99, starting on page 29504. 

Within the Federal Register Notice, EPA states that, “Upon approval of the RH TRU 

waste characterization processes discussed in this report, if SRS-CCP embarks on 

characterizing RH waste other than that generated at BCLDP for WIPP disposal, a 

separate baseline inspection and approval will be necessary. That is, any SRS RH waste 

destined for WIPP disposal characterized by SRS-CCP or another program remains 

subject to EPA’s baseline inspection and approval” (page 29506, third column). 

The Carlsbad Field Office (CBFO) disagrees with the assertion that a new baseline would 

be necessary if additional RH waste were characterized at SRS by CCP. 

The Code of Federal Regulations, 40 CFR, Part 194, Section 194.8, subsection b(2) 

states, “The Agency (EPA) will verify the compliance of waste characterization 

programs and processes. . .” [emphasis added]. By publishing the proposed approval of 

the SRS-CCP Remote-Handled Waste Characterization Program in the Federal Register, 

EPA has memoralized its determined [sic] that the following CCP processes in place at 

SRS are compliant with 40 CFR, Part 194, Section 194.8, subsection b(1). 

(1) The acceptable knowledge process (page 29506, third column) 

(2) The radiological characterization process using dose-to-curie (page 29507, 

first column) 

(3) The visual examination process (page 29507, first column) 

(4) The WIPP Waste Information System (page 28507, first column) 

(5) The attainment of pertinent Data Quality Objectives (page 29507, first 

column) 

Therefore, The Department of Energy (DOE) contends that the adequacy of these 

processes has been successfully implemented in accordance with 40 CFR, Part 194, 

Section 194.8, subsection b(1) as demonstrated by CCP at SRS during the baseline 

inspection and as indicated in the pending approval. A requirement to re-demonstrate the 

same processes, should they be used at SRS, would not be a judicious use of either EPA’s 
51 

or DOE’s resources and would not be good stewardship of the finite resources available 

for the TRU program. 

EPA Response to Comment: 

EPA agrees with the commenter that CCP had successfully implemented the above listed 

waste characterization processes demonstrated to EPA during the baseline inspection. 

EPA, however, disagrees that a re-demonstration of implemented waste characterization 

processes is not necessary and is not a judicious use of resources for the TRU program 

available to DOE and EPA. 

To date, EPA has inspected and evaluated CCP’s RH WC program for debris waste from 

Idaho National Laboratory (INL), Argonne National Laboratory (ANL), Los Alamos 

National Laboratory (LANL), Battelle Columbus Laboratory (BCL), and Oak Ridge 

National Laboratory (ORNL). The experience from these five inspections indicates that 

CCP has customized their radiological characterization and acceptable knowledge WC 

processes to address unique aspects of RH debris waste at each generator site. 

The radiological characterization processes observed at these five CCP RH sites have 

varied. For example, INL and ANL used real-time measured external dose-rate (gamma) 

and DTC on large populations of containers with ORIGEN-based scaling factors 

expressed in curies of TRU radionuclides per curie of 137Cs based on fuel characteristics 

and burn up. At LANL, the 137Cs content for each container was calculated in mass and 

the 137Cs activity was then derived using a curie-to-dose scaling factor based on 

historical passive-active neutron measurements from the 1980s for a small, discreet set of 

wastes. At SRS (BCL), radiological characterization is based on historical dose-rate 

measurements and the agreement between scaling factors derived from LWR fuel data 

and the radiochemical results of the 69 swipe samples discussed in Section 8.2 of this 

report. At ORNL, ORIGEN was not used and scaling factors were instead based on 

radiochemical and non-destructive analyses of samples that contained predominantly 

exotic transcurium radionuclides and negligible amounts of plutonium. While there are 

broad similarities among these five RH WC programs, the differences in the specific 

techniques are pronounced and the radiological characterization approaches have been 

largely site-specific. The only RH WC aspects that were common among these sites are 

non-destructive examination to confirm the absence of prohibited items (free liquid and 

aerosol cans) and tracking of waste container contents in the WWIS. 

Given these substantial differences in WC procedures, EPA concludes there is no basis 

for EPA to determine that SRS-CCP could effectively implement the WC processes used 

for the BCL debris waste to characterize other RH waste. Therefore, the proposed 

approval stated that a new baseline would be necessary if SRS-CCP were to apply the 

processes described in EPA’s inspection report to characterize other non-BCLDP RH 

waste. EPA maintains that position in this final approval. Also, as stated previously, 

implementation of the RH WC processes described in this report for characterizing nondebris BCLDP waste and/or BCLDP wastes other than the 87 RH drum liners is a T1 

change. 
52 

10.0 CONCLUSIONS 

EPA’s inspection team determined that SRS-CCP’s RH WC program activities were technically 

adequate. EPA is approving the SRS-CCP-RH WC program as supported by the documentation 

examined during this inspection and described in this report. The approval includes the AK 

process for one RH retrievably stored TRU debris waste stream, SR-RL-BCLDP.001, that was 

generated by the BCLDP consisting of 87 drum liners that are currently stored at SRS. All 

aspects of the SRS-CCP documentation in support of this RH waste stream are technically 

adequate. 

EPA requires that all site-specific CCRs at RH TRU sites must address the 10 WIPP-tracked 

radionuclides, as discussed in Section 8.1 (8) of this report. SRS-CCP must provide to EPA a 

copy of the WWIS controlled spreadsheet showing the manual data entries that were downloaded 

from CCP-AK-SRS-501 upon completion. In the future, when sample collection plays as 

important a role in a site’s RH WC program as it does for this BCLDP waste stream, EPA will 

require that the site provide a sampling plan prior to EPA approval. 

Baseline Approval 

The documents that EPA reviewed during the inspection that are listed in Section 8 of this report 

adequately support the characterization of SRS-CCP RH Waste Stream SR-RL-BCLDP.001. 

The waste stream being approved by EPA is of a finite nature (i.e., 87 TRU RH drum liners) that 

was generated and packaged in the past, and no additional waste containers from BCL belonging 

to this waste stream exist at SRS or would be subjected in the future to the WC techniques 

described in the report. Hence, this baseline approval remains applicable only to the debris 

waste from BCL consisting of 87 TRU RH drum liners and cannot be implemented to 

characterize any additional waste containers from this waste stream. As stated in Section 9.0, 

should SRS-CCP request approval of any non-BCL RH waste generated at SRS or waste brought 

to SRS for characterization, a new baseline inspection will be necessary. 

The wastes to which this approval applies are discussed in this report and were generated at the 

BCLDP; the fact that they are stored at SRS has no bearing on characterization activities 

performed on any other CH or RH TRU materials at SRS or any other DOE site. This report 

does not list any specific T1 or T2 designations relative to these 87 waste liners and the WC 

components inspected and approved by EPA at this time. However, should DOE identify 

additional containers of RH TRU wastes (e.g., solids or soil/gravel) associated with the D&D of 

the Building JN-1 HCL at the Jefferson North Facility as being eligible for WIPP disposal apart 

from the 87 liners that are discussed in this report, EPA notification and approval would be 

necessary as a T1 change. This report does not list specific T1 or Tier 2 (T2) designations 

relative to these 87 drum liners containing RH TRU debris waste from BCLDP and the WC 

components approved at this time. SRS-CCP, however, must provide to EPA a copy of the 

WWIS controlled spreadsheet showing the manual data entries that were downloaded from CCPAK-SRS-501 upon completion as a one-time T2 change.
53 

11.0 REFERENCES 

U.S. Department of Energy, Carlsbad Area Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, “Environmental 

Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level 

and Transuranic Radioactive Wastes.” 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for the 

Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, Carlsbad Area Field Office, “Remote Handled TRU Waste 

Characterization Program Implementation Plan”, DOE/WIPP-02-3214, Revision 0D, Carlsbad, 

New Mexico, October 30, 2003. 

U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the 

Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C, Compliance 

Recertification Application 2004, DOE/WIPP/2004-3231. 

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program 

Description (QAPD)”, DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control (CH-TRAMPAC).” 
Attachment A 

EPA Inspection Issue Tracking Form, 

EPA Issue No. SRS-CCP-RH-AK-07-001F
 

A-1 

Attachment A 

EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-RH-AK-07-001F

Inspection No. EPA-SRS-CCP-RH-07.07-8 Issue Number: SRS-RH-AK-07-001F, Revision 3 

Date: July 19, 2007 

Inspectors: C. Walker/P. Kelly 

Attachments? YES NO 

Sample Size: RH Documentation 

Population size (if known): NA 

Description of Issue: In August 2001, EPA conducted a surveillance of the Battelle Columbus (BC) Remote-Handled 

(RH) Waste Characterization Program. In the report sent to DOE (cited below), EPA stated that: “BC’s RH Program could 

be improved through more diligent acquisition and integration of AK-based radionuclide information to determine isotopic 

distributions.” EPA also questioned the representativeness of swipe samples collected that were later used as part of scaling 

factor/JN-1 isotopic mix development. EPA concluded that the “AK program data assembly/compilation elements were not 

complete” (EPA’s Technical and Regulatory Support Document for RH Waste Determination, February 2004, transmitted 

to DOE by Frank Marcinowski, March 26, 2004). EPA also concluded that while the radioassay approach had merit, 

characterization activities performed to support the approach at the time of the 2001 Surveillance “were not technically 

adequate.” EPA’s current inspection identifies the following issues related to the completeness and adequacy of AK and 

radiological characterization documents, many of which are related to issues identified in our August 2001 surveillance: 

a. Isotopic ratio/composition information from two primary sources was used to develop scaling factors (also the JN-1 

Standard Isotopic Mix). The factors were derived from a combination of swipe sample and modeling results, with input 

data to the model (ORIGEN2.2) covered in a memorandum of a meeting in 1999. In order for this to serve as an auditable 

record additional information and rationale supporting the approach are required for both the isotopic swipe data and the 

recommended burn up, enrichment, and decay data contained in the 1999 meeting memorandum. Documentation of the 

references and data sources reviewed and evaluated during the 1999 meeting is necessary to support conclusions. With 

regard to the swipe data, the sampling plan, collection, number, results and other relevant information must be summarized 

to show that the sample data are sufficiently representative of the wastes within waste stream SR-RL-BCLDP.001. 

b. CCP-AK-SRS-500 must be revised to address the following: 

• Only describe the SRS waste stream of 87 liners subject to this inspection. 

• The document states that there are wastes in this stream that exhibit both “standard” and “non-standard” isotopic 

distributions and that non-standard waste will undergo separate sampling and analysis. However, the AKE 

indicated that only “standard” isotopic mix wastes are included in the stream, and there are no wastes that 

underwent the alternative sampling and analysis approach discussed in the text. 

• Include a thorough presentation of general radiological characteristics of wastes. Information such as types of 

radionuclides handled in JN-1 in the various cells/areas, origin of radionuclides (e.g., LWR), outliers, and other 

information necessary to provide a general overview of the radionuclides handled through the course of JN-1 

operations are necessary. 

c. Through the course of the AK information acquisition and interpretation process, the number of waste streams identified 

in JN-1 has changed over time. Specifically, the current SR-RL-BCLDO.001 stream was originally identified as four 

separate waste streams. There is no information given to show these waste streams were combined into a single stream. 

d. CCP-AK-SRS-501 does not adequately document the technical basis for the characterization of these RH wastes with 

respect to the development of radionuclide scaling factors and Total Measurement Uncertainty.

B. Regulatory Reference: 40 CFR 194.24(c) 

C. Site requirement(s): 

D. Discussed with: J.R. Stroble, Eric D’Amico, Larry Porter, K. Peters, S. Schafer, R. Tayloe, M. Doherty 

E. Additional Comments: Item c above is resolved as a result of the preparation of reference C509. As a result of 

changes made to primary documents to resolve items b and d above, there may be a need to make changes to other primary 

or secondary documents. EPA expects to receive revised copies of these documents with the response to this finding. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: August 13, 2007