DOCKET NO:  A-98-49, II-A4-99

WASTE CHARACTERIZATION INSPECTION REPORT

PROPOSED 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 17 – 19, July 31 – August 2, and December 4 – 5, 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

May 2008

TABLE OF CONTENTS

Section	Page

  TOC \o "1-3" \h \z    HYPERLINK \l "_Toc195696816"  1.0	Executive
Summary	  PAGEREF _Toc195696816 \h  1  

  HYPERLINK \l "_Toc195696817"  2.0	Purpose of Inspection	  PAGEREF
_Toc195696817 \h  3  

  HYPERLINK \l "_Toc195696818"  3.0	Purpose of This Report	  PAGEREF
_Toc195696818 \h  5  

  HYPERLINK \l "_Toc195696819"  4.0	Scope of Inspection	  PAGEREF
_Toc195696819 \h  5  

  HYPERLINK \l "_Toc195696820"  5.0	Inspection-Related Definitions	 
PAGEREF _Toc195696820 \h  6  

  HYPERLINK \l "_Toc195696821"  6.0	Personnel	  PAGEREF _Toc195696821 \h
 6  

  HYPERLINK \l "_Toc195696822"  6.1	EPA Inspection Team	  PAGEREF
_Toc195696822 \h  6  

  HYPERLINK \l "_Toc195696823"  6.2	Personnel Contacted	  PAGEREF
_Toc195696823 \h  7  

  HYPERLINK \l "_Toc195696824"  7.0	Performance of the Inspection	 
PAGEREF _Toc195696824 \h  8  

  HYPERLINK \l "_Toc195696825"  8.0	Technical Evaluation	  PAGEREF
_Toc195696825 \h  9  

  HYPERLINK \l "_Toc195696826"  8.1	Acceptable Knowledge Process
Overview and Analysis	  PAGEREF _Toc195696826 \h  21  

  HYPERLINK \l "_Toc195696827"  8.2	Radiological Characterization	 
PAGEREF _Toc195696827 \h  33  

  HYPERLINK \l "_Toc195696828"  8.3	Physical Form and Prohibited Item
Characterization – Visual Examination	  PAGEREF _Toc195696828 \h  46  

  HYPERLINK \l "_Toc195696829"  8.4	WIPP Waste Information System	 
PAGEREF _Toc195696829 \h  48  

  HYPERLINK \l "_Toc195696830"  8.5	Attainment of Data Quality
Objectives	  PAGEREF _Toc195696830 \h  49  

  HYPERLINK \l "_Toc195696831"  9.0	Response to Comments	  PAGEREF
_Toc195696831 \h  50  

  HYPERLINK \l "_Toc195696832"  10.0	Summary of Results	  PAGEREF
_Toc195696832 \h  50  

  HYPERLINK \l "_Toc195696833"  10.1	EPA Findings and Concerns	  PAGEREF
_Toc195696833 \h  50  

  HYPERLINK \l "_Toc195696834"  10.2	Conclusions	  PAGEREF _Toc195696834
\h  50  

  HYPERLINK \l "_Toc195696835"  10.3	Baseline Approval	  PAGEREF
_Toc195696835 \h  50  

  HYPERLINK \l "_Toc195696836"  11.0	References	  PAGEREF _Toc195696836
\h  52  

 

ATTACHMENTS

Attachment A 	EPA Inspection Issue Tracking Form, EPA Issue No.
SRS-CCP-RH-AK-07-001F

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

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

m3	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

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Executive Summary

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection
Agency (EPA or the Agency) conducted Baseline Inspection
No. EPA-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.   

Presently, SRS-CCP stores RH waste from Battelle Columbus Laboratory
Decommissioning Project (BCLDP) at SRS, and the WC activities discussed
in this report occurred at the Battelle Columbus Laboratory prior to
shipment of the BCLDP RH waste to SRS for interim storage.  SRS-CCP is
responsible for characterizing this waste for its disposal at WIPP.  The
SRS-CCP TRU WC personnel are located all over the country and SRS-CCP
maintains files for TRU waste information for all CCP TRU waste sites
including this waste at CCP headquarters in Carlsbad, New Mexico.  For
this inspection SRS-CCP was not performing any actual radiological
measurements or physical contents determination but was using the
historical BCLDP-generated data to develop acceptable knowledge (AK)
records, thus negating any need to conduct this baseline inspection at
SRS.  As a practical matter EPA opted to conduct AK record review and
discussions with SRS-CCP’s AK and radiological characterization staff
in Denver, Colorado.  Additionally, EPA decided to evaluate the
remaining WC components, namely, non-destructive examination (NDE) and
waste database in CCP’s Carlsbad office.  EPA may continue this
inspection approach for other CCP RH sites, as necessary. 

This inspection’s sole focus was to evaluate the 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 Battelle Columbus Laboratory
Demolition Project (BCLDP) RH debris Waste Stream SR-RL-BCLDP.001.  Like
the RH debris waste in 16 canisters from the Los Alamos National
Laboratory (LANL) that EPA approved in February 2008 (see Air Docket No.
A-98-49, II-A4-89), this is a discrete waste stream.  There will be no
further waste generation and characterization activities relative to
this waste.  This proposed approval, hence, is directed to a discrete
set of 87 drum liners within this RH debris waste stream that are
currently stored at SRS, as supported by the documentation the EPA
inspection team evaluated during this inspection.  

Although these wastes are currently stored at SRS, the waste generation
and characterization activities covered by this proposed approval were
performed at the BCLDP, as stated previously.  This proposed approval is
limited to RH debris waste from BCLDP only.  Note that this is a
retrospective approval of the RH debris waste from BCLDP, and no
additional RH debris waste from BCLDP remains to be characterized for
WIPP disposal.  Any BCLDP-related RH waste that SRS-CCP may characterize
upon the approval of WC activities discussed in this report will require
EPA approval as a Tier 1 (T1) change.  Upon approval of the RH TRU WC
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.

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 Jefferson North facility, which operated from
1955 until D&D began in 1988, under the BCLDP.  (See page 8 for
additional details of the waste generation in Section 8.0 of this
report.) 

The EPA inspection team identified one finding during the July 2007
inspection (see Attachment A).  SRS-CCP revised specific documents to
address the finding and submitted them for EPA review following the
initial July 2007 inspection.  The EPA inspection team reviewed the
revised documents and subsequently met with SRS-CCP personnel in
December 2007 to discuss the changes to WC documents addressing the EPA
finding and examine additional objective evidence.  Upon completing
their reviews, the EPA inspection team determined that the revised
documents adequately addressed all aspects of the EPA finding. 
Accordingly, EPA has determined that the records documenting SRS-CCP’s
RH WC program represented activities that were technically adequate and
the finding has been resolved.  EPA, therefore, is proposing to approve
the SRS-CCP RH WC program for the 87 RH TRU drum liners in SRS RH Waste
Stream SR-RL-BCLDP.001 evaluated during this baseline inspection that is
described and documented in this report.  The proposed approval includes
the following:

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

The radiological characterization process using dose-to-curie (DTC) and
modeling-derived 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.

The visual examination (VE) process to identify waste material
parameters and the physical form of the waste

The WIPP Waste Information System (WWIS) to submit data for both
characterization and certification to WWIS for RH TRU waste

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, no changes to the WC activities
evaluated during the baseline inspection are anticipated.  EPA,
therefore, does not expect SRS-CCP to make additional revisions to the
documents that were reviewed as part of this inspection and proposed
approval limited to the WC processes specific to the 87 drum liners
evaluated during the July, August and December 2007 inspections.  In the
event that SRS-CCP makes changes to the WC components proposed for
approval or 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 waste liners and the WC components proposed for the
approval at this time.  

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 AK 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 of this section.  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 such as plutonium that must be tracked for compliance, 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 not relevant.  Accordingly, no formal
tiering is proposed for the SRS-CCP RH WC program at this time.  As
stated previously, EPA’s proposed approval is limited to the 87 drum
liners of RH TRU wastes whose characterization is documented in the
records evaluated during the inspection, as detailed in this report. 
The rule applying to this baseline inspection can be found in the FR
(Vol. 69, No. 136, pp. 42571–42583, July 16, 2004).  EPA doesn’t
expect to conduct additional SRS-CCP RH waste inspections specific to
this waste stream in the future.  If, for DOE, SRS-CCP characterizes RH
waste not originating at BCLDP for WIPP disposal, a new EPA baseline
inspection and approval will be necessary under the authority of 40 CFR
194.8. 

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:

Describes the characterization systems proposed for approval

Delineates a specific set of RH wastes proposed for approval

Provides objective evidence of the proposed approval basis for 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 proposed approval decision

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  
HYPERLINK "http://www.epa.gov/radiation/WIPP" 
http://www.epa.gov/radiation/WIPP . 

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, SRS-CCP 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
WIPP-tracked 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 that were performed by SRS-CCP more
recently.

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 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 was 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.

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.)

Personnel

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.



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



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
facilities began in 1988 under the BCLDP, whose objective was to
decontaminate the West Jefferson buildings and associated grounds such
that they suitable for unrestricted use, i.e., use without radiological
restrictions.  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 but 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
conducted the review of AK records and discussions with SRS-CCP
personnel in Denver, CO.  Additionally, EPA decided to evaluate the
non-destructive examination (NDE) and the WWIS in CCP’s Carlsbad
office.  

Inspection Process Overview

EPA 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:

Obtaining and reviewing site procedures, reports, and other technical
information related to RH WC activities used to characterize these
wastes at BCLDP previously

Preparing technical questions specific to the various aspects of AK
prior to the inspection based on the activities cited in the previous
bullet

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

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 conducted at BCLDP previously

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 conducted at BCLDP previously

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)

Communicating all pertinent information with CBFO and SRS-CCP personnel

Pursuing resolution of all identified issues prior to completion of the
inspection, when feasible 

Conducting entrance, exit, and daily briefings for CBFO and SRS-CCP
management personnel

Obtaining and reviewing SRS-CCP documents that were revised in response
to the EPA finding after the inspection

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

Issuing the inspection report and proposed approval

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 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 where
there are multiple sections named for each WC process, i.e., AK, NDA,
NDE, and WWIS that can be found in other EPA baseline inspection
reports.  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.

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.
 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.  The remaining
87 drums of waste that are subject of this inspection are composed of 82
individual 55-gallon drums and five additional 55-gallon drums that are
contained in two 72B RH Casks, three drums in one cask and two 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 percent 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.  

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

The approval of additional BCLDP drum liners at Hanford or any other
location will require a separate baseline inspection as such time that
the site decides to characterize these wastes for disposal at WIPP.  The
wastes to which this proposed 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 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 proposed 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

AK 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)

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.   

Radiological information available for this waste stream includes the
radiochemical analytical results of 69 swipe 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) measurements were taken at the time
of packaging for all drum liners.  The determination of several DQOs was
achieved through use of radionuclide-specific 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 ORIGEN2.2 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 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

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 JN-1A, 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

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

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 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

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: SR-BL-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 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-RL-BCLDP.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

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

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

Acceptable Knowledge Process Overview and Analysis

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 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 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 has the proceeding 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 such as U014 contain worthwhile information.  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 burn-up and decay values used as input to ORIGEN2.2
modeling in SRS-CCP documents.  EPA 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, that 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 and
Table 3, below, indicates where each issue is addressed, the information
provided by SRS-CCP for their resolution is discussed, and 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:

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, 513,
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 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 was followed, with emphasis on the
following:

Guidance that was followed to develop and execute the sample collection,
e.g., DOE Order, CBFO Procedure or other guidance 

Sample protocols (reference the procedure(s) followed)

Reason for initial sample collection and the use of 69 samples to
characterize the waste, i.e., why 69 samples were considered sufficient

Rationale why the selected samples were considered representative, i.e.,
selected from a variety of surfaces, certain number from each area,
anticipated contamination in the areas

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

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 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
that “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
“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 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: samples
were collected randomly from a variety of surfaces to capture the
maximum potential isotopic distribution that may be present 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): e.g.: “…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 future, EPA, however, 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 as a T1 change another
BCLDP RH waste stream (e.g., BCLDP solids and soil/gravel) for EPA
evaluation and approval, the CCP must provide  rigorous and detailed
sampling and analysis information when CCP cannot fulfill the S&A plan
requirement of the WCPIP for EPA evaluation.  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
acceptable knowledge.

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. 
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 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:

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-SRS-500 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)

CCP-AK-SRS-501, Appendix 3, Waste Container Dose to Curie Conversion
Records (All 87 Drum Liners)

Calculation Packages P729, P7353, 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 AK
Sections (1) and (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 the references
examined to date address the element or issue that is referenced 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.  

 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 

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 meeting the requirements stated in the WCPIP, but care
should be exercised in the 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. 

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: 

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, if any, relevant to each DQO 

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 percent 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

A complete AK summary 

A complete listing of all container identification numbers used to
generate the 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 being that for the
WIPP Performance Assessment performed in conjunction with the WIPP
Repository Recertifcation every five years, identification and
quantification of the 10 WIPP-tracked 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, drum-specific 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 was 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 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 when available for review.

(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-RL-BCLDP.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
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.

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:

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 thorium; 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 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 241Pu 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) 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.

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 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.

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

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.

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. 

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

(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
hazard.  

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, that 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 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).

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



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.

(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.  

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.  

 

Figure 3.  DTC Correlations as a Function of Waste Density at a Distance
of 1 meter Centered on a RH TRU Drum Liner





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

(4)	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.

 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.

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:

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-RH-06, 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.

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%

 

(7)	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

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.

(8)	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.

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.  

(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 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.

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.  

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.

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.

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.  

Response to Comments	

This section is reserved for public comments.

Summary of Results 

EPA Findings and Concerns

The one EPA finding identified during the July 2007 inspection and
SRS-CCP’s responses are discussed in the preceding sections of this
report.  A copy of the EPA Inspection Issue Tracking Form that captures
the finding is included in Attachment A of this report.  All open issues
were adequately addressed and no EPA issues remain open at this time.

Conclusions

EPA’s inspection team determined that SRS-CCP’s RH WC program
activities were technically adequate.  EPA is proposing to approve the
SRS-CCP-RH WC program as supported in the documentation examined during
this inspection, as described in this report.  The proposed approval
includes the AK process for one RH retrievably-stored TRU debris waste
stream, SR-RL-BCLDP.001, that was generated by the BCLDP and consists 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 ten 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

There are no outstanding issues related to the SRS-CCP RH WC program
that EPA evaluated during this inspection.  The documents that EPA
reviewed during the inspection that are listed in Section 8 of this
report adequately support the characterization of SRS RH Waste Stream
SR-RL-BCLDP.001.  The waste stream proposed for approval is of a finite
nature (i.e., 87 TRU RH drum liners) generated and packaged in the past
and no additional waste containers from BCL belonging to this waste
description exist at SRS or would be subjected to the WC techniques
described in the report in the future.  Hence, when approved, this
baseline approval remains applicable to the debris waste from BCL
consisting of 87 TRU RH drum liners and will not be implemented to
characterize any additional waste containers from this waste stream.  

The wastes to which this proposed 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.  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 apart from the 87 liners that may be eligible
for WIPP disposal, EPA notification and approval would be necessary as a
T1 change.  This report does not list any specific T1 or T2 designations
relative to these 87 waste liners and the WC components inspected and
proposed for approval by EPA at this time.  

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 

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?    FORMCHECKBOX   YES      FORMCHECKBOX   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?     FORMCHECKBOX  YES    FORMCHECKBOX   NO

   Site Response Due Date: August 13, 2007



	 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.

 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.

 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.”

 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.

 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.

	 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.

	 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.

	 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.

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

 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.

 241Pu is not one of the 10 WIPP-tracked radionuclides but it may be
useful in developing radionuclide scaling factors.

 Although they are technical different, in this context the term LLD is
taken to be synonymous with Minimum Detectable Activity (MDA).

 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.

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A-  PAGE  1 

Poly. (One Meter     Co-60 Dose Rate, mR/hr/Ci)

Poly. (One Meter     Cs-137 Dose Rate, mR/hr/Ci)

One Meter     Co-60 Dose Rate, mR/hr/Ci

One Meter     Cs-137 Dose Rate, mR/hr/Ci

Dose Rate, R/hr

Waste Density in Grams/cm3

2.5

2

1.5

1

0.5

0

800

700

600

500

400

300

200

100

0

 = 0.9999

2

R

 - 349.19x + 794.6

2

y = 57.41x

 = 0.9995

2

R

 - 107.2x + 197.8

2

y = 20.615x

