­
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11/
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iii
REVISION
LOG
Revision
Number
Date
Approved
Pages
Affected
Description
of
Revision
0
08/
01/
02
All
Initial
issue.
DCR­
1230.
Document
issue
date
was
07/
17/
02.
DOE/
WIPP
approval
was
received
07/
30/
02
thus
the
change
in
effective
date
to
08/
01/
02.

1
12/
19/
02
Various
DCR­
1820.
Correct
procedure
titles
and
numbers.
Added
verbiage
to
include
manual
data
review.
Added
DOE­
ID
to
the
Document
Approval
Sheet
in
accordance
with
MP­
DOCS­
18.4.
Document
issue
date
was
12/
19/
02.
DOE/
WIPP
approval
was
received
01/
14/
03
thus
the
change
in
effective
date
to
02/
06/
03.

2
06/
11/
03
Various
DCR­
2117:
Incorporate
WIPP
WAC
Rev.
0.1
and
QAPD
Rev.
4
requirements.
Correct
procedure
references
in
Section
4.
Document
issue
date
was
03/
20/
03.
DOE/
WIPP
approval
was
received
04/
03/
03.
The
original
signature
page
was
lost
and
was
resigned,
thus
the
change
in
effective
date
is
06/
11/
03.
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11/
03
Certification
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Waste
iv
TABLE
OF
CONTENTS
1.0
INTRODUCTION......................................................................................................
1
2.0
RESPONSIBILITIES.................................................................................................
4
2.1
DOE
Headquarters............................................................................................
4
2.2
DOE
Carlsbad
Field
Office
..............................................................................
4
2.3
DOE
Field
Elements
.........................................................................................
5
2.4
TRU
Waste
Sites...............................................................................................
5
3.0
WIPP
WASTE
ACCEPTANCE
REQUIREMENTS
AND
CRITERIA
...................
6
3.1
Summary
of
WIPP
Authorization
Basis
...........................................................
6
3.1.1
DOE
Operations
and
Safety
Requirements
for
WIPP
.................................
7
3.1.2
NRC
Transportation
Safety
Requirements
for
the
TRUPACT­
II................
7
3.1.3
NMED
Hazardous
Waste
Facility
Permit
Requirements.............................
8
3.1.4
EPA
Compliance
Certification
Decision
Requirements
..............................
8
3.1.5
Land
Withdrawal
Act
Requirements
...........................................................
9
3.2
Container
Properties
.......................................................................................
10
3.2.1
Description.................................................................................................
10
3.2.2
Weight
Limits
and
Center
of
Gravity
........................................................
11
3.2.3
Assembly
Configurations...........................................................................
13
3.2.4
Removable
Surface
Contamination
...........................................................
13
3.2.5
Identification/
Labeling...............................................................................
14
3.2.6
Dunnage
.....................................................................................................
15
3.2.7
Filter
Vents.................................................................................................
16
3.3
Radiological
Properties...................................................................................
16
3.3.1
Radionuclide
Composition.........................................................................
17
3.3.2
239Pu
Fissile
Gram
Equivalent
........................................................................
18
3.3.3
TRU
Alpha
Activity
Concentration...........................................................
20
3.3.4
239Pu
Equivalent
Activity................................................................................
20
3.3.5
Radiation
Dose
Equivalent
Rate
................................................................
22
3.3.6
Decay
Heat.................................................................................................
22
3.4
Physical
Properties..........................................................................................
23
3.4.1
Residual
Liquids
........................................................................................
23
3.4.2
Sealed
Containers.......................................................................................
24
3.5
Chemical
Properties........................................................................................
24
3.5.1
Pyrophoric
Materials..................................................................................
24
3.5.2
Hazardous
Waste
.......................................................................................
25
3.5.3
Chemical
Compatibility.............................................................................
26
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3.5.4
Explosives,
Corrosives,
and
Compressed
Gases........................................
26
3.5.5
Headspace
Gas
Concentrations..................................................................
27
3.5.6
Polychlorinated
Biphenyl
Concentration...................................................
27
3.6
Data
Package
Contents
...................................................................................
28
3.6.1
Characterization
and
Certification
Data.....................................................
28
3.6.2
Shipping
Data.............................................................................................
28
4.0
QUALITY
ASSURANCE
REQUIREMENTS
.......................................................
30
4.1
Waste
Characterization
QA
Requirements.....................................................
30
4.2
Waste
Certification
QA
Requirements
...........................................................
30
4.3
Waste
Transportation
QA
Requirements........................................................
31
4.4
Quality
Assurance
Program............................................................................
31
4.4.1
AMWTP
TRU
Program
Organization
.......................................................
33
4.4.2
AMWTP
QA
Program
Description
...........................................................
37
4.4.3
Implementation
of
the
CBFO
QA
Program...............................................
38
4.4.4
Graded
Approach.......................................................................................
39
4.5
Personnel
Qualification
And
Training............................................................
39
4.5.1
Qualification
..............................................................................................
39
4.5.2
Training......................................................................................................
39
4.6
Quality
Improvement......................................................................................
40
4.6.1
Conditions
Adverse
To
Quality
.................................................................
40
4.6.2
Controlling
Conditions
Adverse
To
Quality..............................................
41
4.6.3
Nonconforming
Items
................................................................................
41
4.6.4
Corrective
Action
and
Planning
Follow­
up
...............................................
43
4.6.5
Improvement
Analysis...............................................................................
43
4.7
Documents
and
Records
.................................................................................
44
4.7.1
Document
Control......................................................................................
44
4.7.2
Document
Preparation,
Review,
Approval
and
Issuance...........................
45
4.7.3
Document
Distribution
and
Use.................................................................
46
4.7.4
Records
......................................................................................................
46
4.8
Performance
Requirements.............................................................................
47
4.9
Design
Control................................................................................................
48
4.10
Procurement
...............................................................................................
48
4.10.1
Procurement
Document
Control
................................................................
48
4.10.2
Control
of
Purchased
Items
and
Services
..................................................
48
4.10.3
Control
of
Subcontractors
..........................................................................
49
4.11
Inspection
and
Testing
...............................................................................
49
4.12
Assessment
Requirements
.........................................................................
51
4.12.1
Management
Assessments
.........................................................................
51
4.12.2
Independent
Assessments
..........................................................................
51
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4.12.3
Surveillances..............................................................................................
52
4.12.4
CBFO
Audits
.............................................................................................
52
4.12.5
Reports
to
Management
.............................................................................
52
4.13
Sample
Control
Requirements
...................................................................
53
4.14
Scientific
Investigation
Requirements
.......................................................
53
4.15
Software
Requirements..............................................................................
54
5.0
REFERENCES.........................................................................................................
55
APPENDIX
A.................................................................................................................
A­
1
A.
1
Introduction.................................................................................................
A­
2
A.
2
Radionuclide
Isotopic
Ratios
......................................................................
A­
3
A.
2.1
Methods
for
Confirmation
of
Isotopic
Ratio
AK....................................
A­
3
A.
2.2
Acceptable
Knowledge
(
AK)
Documentation
........................................
A­
5
A.
2.2.1
Required
Elements
..................................................................................
A­
5
A.
2.2.2
Supplemental
Acceptable
Knowledge
Information
................................
A­
6
A.
2.2.3
Discrepancy
Resolution
..........................................................................
A­
7
A.
3
Data
Quality
Objectives..............................................................................
A­
7
A.
4
Quality
Control
.........................................................................................
A­
10
A.
4.1
General
Requirements...........................................................................
A­
11
A.
4.2
NDA
QC
Requirements
........................................................................
A­
11
A.
4.3
Radiochemistry
QC
Requirements
.......................................................
A­
13
A.
5
Data
Management
.....................................................................................
A­
13
A.
5.1
Data
Review
and
Validation
.................................................................
A­
14
A.
5.2
Data
Reporting......................................................................................
A­
14
A.
5.3
Data
and
Records
Retention..................................................................
A­
15
A.
6
Quality
Characteristics
Assessment..........................................................
A­
15
A.
6.1
Data
Accuracy.......................................................................................
A­
16
A.
6.2
Data
Precision
.......................................................................................
A­
16
A.
6.3
Data
Representativeness
.......................................................................
A­
16
A.
6.4
Data
Completeness................................................................................
A­
16
A.
6.5
Data
Comparability...............................................................................
A­
17
Appendix
A
References
......................................................................................
A­
18
APPENDIX
B..................................................................................................................
B­
1
B.
1
Appendix
B
References
...............................................................................
B­
3
APPENDIX
C..................................................................................................................
C­
1
APPENDIX
D
.......................................................................................................
D­
1
­
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Contact­
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Waste
vii
LIST
OF
ACRONYMS
AND
ABBREVIATIONS
AEA
Atomic
Energy
Act
ACMM
Analytical
Chemistry
Methods
Manual
AK
acceptable
knowledge
ALD
Analytical
Laboratories
Department
AMWTF
Advanced
Mixed
Waste
Treatment
Facility
AMWTP
Advanced
Mixed
Waste
Treatment
Project
ASTM
American
Society
for
Testing
and
Materials
ANSI
American
National
Standards
Institute
CAR
Corrective
Action
Report
CBFO
Carlsbad
Field
Office
CCA
Compliance
Certification
Application
CFR
Code
of
Federal
Regulations
CH
contact­
handled
CH­
TRU
contact­
handled
TRU
waste
CH­
WAC
contact­
handled
waste
acceptance
criteria
Ci
curie
CPR
cellulose,
plastic,
and
rubber
DAS
drum
assay
system
DDA
differential
die­
away
DCR
document
change
request
DOE
U.
S.
Department
of
Energy
DOT
U.
S.
Department
of
Transportation
DR
Deficiency
Report
DSDD
detailed
software
design
description
DQO
data
quality
objective
EDF
Engineering
Design
File
EPA
U.
S.
Environmental
Protection
Agency
FGE
fissile
gram
equivalent
FRC
Federal
Records
Center
HSGS
headspace
gas
sampling
ID
Idaho
INEL
Idaho
National
Engineering
Laboratory
INEEL
Idaho
National
Engineering
and
Environmental
Laboratory
INST
Instruction
LCS
laboratory
control
sample
LLD
lower
limit
of
detection
LWA
Land
Withdrawal
Act
MP
Management
Procedure
­
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03
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03
Certification
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INEEL
Contact­
Handled
Transuranic
Waste
viii
MS
matrix
spike
MSD
matrix
spike
duplicate
nCi/
g
nanocuries
per
gram
NCR
nonconformance
report
NDA
nondestructive
assay
NIST
National
Institute
of
Standards
and
Technology
NMED
New
Mexico
Environment
Department
NMMA
nuclear
material
management
area
NRC
U.
S.
Nuclear
Regulatory
Commission
OPCTCD
overpack
payload
container
transportation
certification
document
PATCD
payload
assembly
transportation
certification
document
PCTCD
payload
container
transportation
certification
document
PCB
polychlorinated
biphenyl
PDAS
In­
plant
Drum
Assay
System
PDP
performance
demonstration
program
PE­
Ci
plutonium­
239
equivalent
curies
QA
quality
assurance
QAO
quality
assurance
objective
QAP
Quality
Assurance
Plan
QAPD
Quality
Assurance
Program
Document
QAPjP
quality
assurance
project
plan
QC
quality
control
RC
radiochemistry
RCRA
Resource
Conservation
and
Recovery
Act
RDAS
retrieval
drum
assay
system
RH
remote­
handled
(
waste)
RIDS
records
inventory
and
disposition
schedule
%
R
percent
recovery
RPD
relative
percent
difference
RSD
relative
standard
deviation
RT
Radiological
Technician
RTR
real­
time
radiography
SAR
Safety
Analysis
Report
SATR
Site
Acceptance
Test
Reports
SNM
special
nuclear
material
SPM
Site
Project
Manager
SPO
Site
Project
Office
SQAO
Site
Quality
Assurance
Officer
SWB
standard
waste
box
TCO
Transportation
Certification
Official
­
ix
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Handled
Transuranic
Waste
ix
TDOP
ten­
drum
overpack
TMU
total
measurement
uncertainty
TRAMPAC
TRUPACT­
II
Authorized
Methods
for
Payload
Control
TRU
transuranic
TRUCON
TRUPACT­
II
Content
Codes
TRUPACT­
II
Transuranic
Package
Transporter­
Model
II
TSDF
Treatment,
Storage,
and
Disposal
Facility
VE
Visual
Examination
VOC
volatile
organic
compound
WAC
Waste
Acceptance
Criteria
WAP
Waste
Analysis
Plan
WCL
waste
component
limits
WCO
Waste
Certification
Official
WIPP
Waste
Isolation
Pilot
Plant
WSPF
Waste
Stream
Profile
Form
WTS
Waste
Tracking
System
WWIS
WIPP
Waste
Information
System
­
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INEEL
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Transuranic
Waste
1
1.0
INTRODUCTION
The
purpose
of
this
document
is
to
summarize
the
methods
and
procedures
used
by
the
Idaho
National
Engineering
and
Environmental
Laboratory
(
INEEL)
Advanced
Mixed
Waste
Treatment
Project
(
AMWTP)
to
certify
defense
generated
waste
as
compliant
to
the
waste
acceptance
criteria
applicable
to
the
transportation,
storage,
and
disposal
of
contact­
handled
transuranic
(
CH­
TRU)
waste
at
the
Waste
Isolation
Pilot
Plant
(
WIPP).
These
criteria
serve
as
the
U.
S.
Department
of
Energy's
(
DOE)
primary
directive
for
ensuring
that
CH­
TRU
waste
is
managed
and
disposed
of
in
a
manner
that
protects
human
health
and
safety
and
the
environment.

The
authorization
basis
of
WIPP
for
the
disposal
of
CH­
TRU
waste
includes
the
U.
S.
Department
of
Energy
National
Security
and
Military
Applications
of
Nuclear
Energy
Authorization
Act
of
1980
(
reference
20)
and
the
WIPP
Land
Withdrawal
Act
(
LWA;
reference
21).
Included
in
this
document
are
the
requirements
and
associated
criteria
imposed
by
these
acts
and
the
Resource
Conservation
and
Recovery
Act
(
RCRA,
reference
22),
as
amended,
on
the
TRU
waste
destined
for
disposal
at
WIPP.

The
AMWTP
must
certify
CH­
TRU
waste
payload
containers
to
the
contact­
handled
waste
acceptance
criteria
(
CH­
WAC)
identified
in
this
document.
As
shown
in
figure
1.0,
the
flow­
down
of
applicable
requirements
to
the
CH­
WAC
is
traceable
to
several
higher­
tier
documents,
including
the
WIPP
operational
safety
requirements
derived
from
the
WIPP
CH
Safety
Analysis
Report
(
SAR;
reference
14),
the
transportation
requirements
for
CH­
TRU
wastes
derived
from
the
Transuranic
Package
Transporter­
Model
II
(
TRUPACT­
II)
Certificate
of
Compliance
(
reference
43),
the
WIPP
LWA
(
reference
21),
the
WIPP
Hazardous
Waste
Facility
Permit
(
reference
42),
and
the
U.
S.
Environmental
Protection
Agency
(
EPA)
Compliance
Certification
Decision
(
reference
27).
The
solid
arrows
shown
in
figure
1.0
represent
the
flow­
down
of
all
applicable
payload
container­
based
requirements.
The
two
dotted
arrows
shown
in
figure
1.0
represent
the
flow­
down
of
summary
level
requirements
only;
i.
e.,
the
sites
must
reference
the
regulatory
source
documents
from
the
U.
S.
Nuclear
Regulatory
Commission
(
NRC)
and
the
New
Mexico
Environment
Department
(
NMED)
for
a
comprehensive
and
detailed
listing
of
the
requirements.

The
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste,
also
referred
to
as
the
Certification
Plan,
does
not
address
requirements
or
shippability
of
waste
in
DOE
Type
B
casks
or
the
subject
of
waste
characterization
relating
to
a
determination
of
whether
the
waste
is
hazardous;
rather,
the
AMWTP
refers
to
the
Waste
Analysis
Plan
(
WAP)
contained
in
the
WIPP
Hazardous
Waste
Facility
Permit
for
details
of
the
sampling
and
analysis
protocols
to
be
used
in
determining
compliance
with
the
required
physical
and
chemical
properties
of
the
waste.
Requirements
and
associated
criteria
pertaining
to
a
determination
of
the
radiological
properties
of
the
waste,
however,
are
addressed
in
appendix
A
of
this
document.
The
collective
information
obtained
from
waste
characterization
records
and
acceptable
knowledge
(
AK)
serves
as
the
basis
for
sites
to
certify
that
their
CH­
TRU
waste
satisfies
the
WIPP
CHWAC
­
2
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03
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03
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INEEL
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Transuranic
Waste
2
Section
2.0
of
this
document
identifies
the
responsible
organizations
and
associated
activities
for
ensuring
that
the
CH­
TRU
waste
is
managed
in
a
manner
that
protects
human
health
and
safety
and
the
environment.

Section
3.0
identifies
the
authorization
basis
of
the
requirements
and
lists
the
associated
waste
acceptance
criteria
and
compliance
methods
relating
to
the
physical,
chemical,
and
radiological
attributes
of
the
waste
as
well
as
the
properties
of
the
applicable
containers
themselves.

Section
4.0
summarizes
the
AMWTP
Quality
Assurance
(
QA)
requirements
relating
to
waste
characterization,
certification,
and
transportation
that
meet
all
applicable
requirements
of
the
Carlsbad
Field
Office
(
CBFO)
Quality
Assurance
Program
Document
(
QAPD;
reference
7).
Characterization
of
CH­
TRU
waste
must
be
in
accordance
with
the
performance
requirements
of
the
WIPP
WAP
and
is
implemented
in
the
AMWTP
Quality
Assurance
Project
Plan
(
QAPjP).
Certification
of
payload
containers
for
shipment
in
the
TRUPACT­
II
shall
be
performed
under
a
CBFO
approved
QA
program
that
provides
confidence
for
both
the
shipper
and
the
receiver
that
the
TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
TRAMPAC;
reference
45)
requirements
have
been
met.

The
appendices
provide
supplemental
information
relating
to
radioassay
(
appendix
A)
and
radiotoxic
inhalation
hazard
analyses
(
appendix
B).
A
glossary
is
provided
in
appendix
C.
Appendix
D
addresses
the
visual
examination
requirements
and
compliance
criteria
for
payload
containers.

The
CH­
WAC
is
a
controlled
document.
The
most
current
version
of
the
CH­
WAC
(
including
any
Interim
Changes)
is
available
for
downloading
from
the
CBFO
Web
Page
at
http://
www.
wipp.
ws/
library/
wac/
ch­
wacrev0.
pdf.
This
Internet
link
is
provided
for
informational
purposes
only
and
may
change.
­
3
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
3
NRC
TRUPACT­
II
CERTIFICATE
OF
COMPLIANCE1
NMED
WIPP
HAZARDOUS
WASTE
FACILITY
PERMIT1
DOE/
CBFO
WIPP
CH
SAFETY
ANALYSIS
REPORT
(
FEIS,
SEIS
I,
SEIS
II)
EPA
WIPP
COMPLIANCE
CERTIFICATION
DECISION
CONGRESS
WIPP
LAND
WITHDRAWAL
ACT
WIPP
CH­
TRU
WASTE
ACCEPTANCE
CRITERIA
SITE
TRAMPAC2
SITE
QUALITY
ASSURANCE
PROJECT
PLAN2
SITE
WASTE
CERTIFICATION
PLAN2
SITE
DATA
INPUT
(
REQUIREMENTS)

(
CRITERIA)

Figure
1.0
Regulatory
Basis
of
CH­
TRU
Waste
Acceptance
Criteria
Note
1:
The
TRAMPAC
and
the
WIPP
Hazardous
Waste
Facility
Permit
provide
detailed
requirements.
The
CH­
WAC
only
provides
an
overview
of
these
requirements.

Note
2:
All
work
performed
by
the
site
for
the
CBFO
must
be
performed
under
an
approved
QA
program.
­
4
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
4
2.0
RESPONSIBILITIES
This
section
identifies
the
responsibilities
of
organizations
that
develop
and
approve
the
WIPP
CH­
WAC
and
of
those
that
oversee
the
implementation
of
the
requirements
defined
herein.
The
responsibilities
of
the
AMWTP
to
which
these
requirements
apply
are
also
identified
in
this
section.

2.1
DOE
Headquarters
The
Assistant
Secretary
for
Environmental
Management
(
EM­
1)
provides
policy
and
guidance
for
DOE
environmental
management
sites,
facilities,
and
operations.

2.2
DOE
Carlsbad
Field
Office
The
CBFO
is
responsible
for
the
day­
to­
day
management
and
direction
of
strategic
planning
and
related
activities
associated
with
the
characterization,
certification,
transportation,
and
disposal
of
defense
TRU
waste.
The
CBFO
holds
the
applicable
permits,
certifications,
and
records
of
decision
necessary
for
the
operation
and
closure
of
the
WIPP
facility.

The
CBFO
assists
the
sites
in
resolving
issues
about
the
management
of
TRU
waste
as
requested.
The
CBFO
provides
policy
and
oversight
direction
for
TRU
waste
program
activities
related
to
site
certification
of
waste
for
disposal
at
WIPP.
The
CBFO
is
also
responsible
for
the
following:

 
Ensuring
that
the
sites
prepare
implementation
documentation
and
programs
to
meet
the
requirements
and
criteria
in
the
CH­
WAC
 
Overseeing
activities
associated
with
the
­
characterization
and
certification
of
CH­
TRU
waste
­
proper
use
of
approved
transportation
packaging
­
receipt,
management,
and
disposal
of
CH­
TRU
waste
in
WIPP
 
Providing
a
fleet
of
NRC­
approved
Type
B
transportation
packages
for
shipment
of
CH­
TRU
waste
from
the
sites
to
WIPP
 
Ensuring
that
CH­
TRU
waste
accepted
for
management
and
disposal
at
WIPP
complies
with
the
WIPP
Hazardous
Waste
Facility
Permit,
applicable
laws,
and
regulations
as
described
in
this
CHWAC
­
5
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
5
 
Reviewing
and
approving
proposed
revisions
to
the
CH­
WAC
to
ensure
that
environmental
impacts
associated
with
any
revision
are
bounded
by
existing
WIPP
National
Environmental
Policy
Act
documentation
including
the
Final
Environmental
Impact
Statement
(
reference
10),
Final
Supplemental
Environmental
Impact
Statement
I
(
reference
11),
and
the
Final
Supplemental
Environmental
Impact
Statement
II
(
reference
12)

 
Reviewing
and
approving
the
site's
waste
certification
plan,
TRAMPAC,
QA
plan,
and
QAPjP
 
Performing
site
certification
audits
and
surveillances
 
Granting
transportation
and
waste
certification
authority
to
sites
2.3
DOE
Field
Elements
Each
DOE
Field
Element
is
responsible
for
overseeing
the
management
of
the
site
TRU
waste
program
in
compliance
with
established
CBFO
requirements,
policies,
and
guidelines,
and
for
providing
liaison
between
the
CBFO
and
the
management
and
operating
contractors.

2.4
TRU
Waste
Sites
The
AMWTP
is
responsible
for
developing
and
implementing
site­
specific
TRU
waste
program
documents
(
plans)
that
address
applicable
requirements
and
criteria
pertaining
to
packaging,
characterization,
certification,
and
shipping
of
defense
TRU
waste
to
WIPP
for
disposal.
Methods
of
compliance
with
each
requirement
and
associated
criterion
to
be
implemented
is
described
or
specifically
referenced
and
include
procedural
and
administrative
controls
consistent
with
the
CBFO
QAPD.
The
AMWTP
will
certify
that
each
CH­
TRU
waste
payload
container
meets
the
waste
acceptance
criteria
contained
in
section
3.
The
AMWTP
QA
requirements
relating
to
waste
characterization,
certification,
and
transportation
are
contained
in
section
4.0.
The
following
AMWTP
site­
specific
TRU
waste
program
documents
will
be
submitted
to
CBFO
for
review
and
approval
prior
to
implementation:

 
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
 
MP­
TRUW­
8.2,
Quality
Assurance
Project
Plan
(
QAPjP)

 
MP­
TRUW­
8.3,
TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
TRAMPAC)

The
AMWTP
TRU
Program
organization,
project
level
positions,
and
their
primary
responsibilities
are
described
in
Section
4.4.1
of
this
document.
­
6
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
6
3.0
WIPP
WASTE
ACCEPTANCE
REQUIREMENTS
AND
CRITERIA
The
requirements
and
associated
criteria
for
acceptance
of
defense
TRU
waste
at
WIPP
for
disposal
are
identified
in
the
CH­
WAC.
The
acceptance
criteria
of
the
CH­
WAC
describe
the
controlling
(
i.
e.,
the
most
restrictive)
requirements
to
be
used
by
the
AMWTP
in
preparing
their
waste
for
transportation
to
and
disposal
at
the
WIPP.
In
some
instances
the
acceptance
criteria
and
regulatory
requirements
are
synonymous.
The
CH­
WAC
requirements
are
derived
from
several
source
documents:
the
WIPP
Safety
Analysis
Report
(
reference
14),
the
TRUPACT­
II
Certificate
of
Compliance
(
reference
43),
the
WIPP
LWA
(
reference
21),
the
WIPP
Hazardous
Waste
Facility
Permit
(
reference
42),
and
the
Compliance
Certification
Decision
(
reference
27).
Definitions
of
terms
used
in
the
CH­
WAC
are
included
in
Appendix
C.

3.1
Summary
of
WIPP
Authorization
Basis
The
purpose
of
section
3.0
is
to
present
the
requirements
and
associated
criteria
that
must
be
met
for
CHTRU
waste
to
be
transported
to,
managed
at,
and
disposed
of
in
the
WIPP.
The
requirements
and
associated
criteria
are
organized
under
five
major
headings:
Container
Properties,
Radiological
Properties,
Physical
Properties,
Chemical
Properties,
and
Data
Package
Contents.
Only
CH­
TRU
waste
from
a
properly
characterized
and
approved
waste
stream
may
be
certified
as
meeting
the
requirements
and
associated
criteria
contained
in
this
CH­
WAC.
Any
waste
payload
container
from
a
waste
stream
that
has
not
been
preceded
by
an
appropriate
certified
Waste
Stream
Profile
Form
(
WSPF)
is
not
acceptable
for
disposal
at
WIPP
(
reference
42,
module
II,
section
II.
C.
3.
k).

Site­
specific
plans
and
procedures
shall
contain
details
of
the
processes,
controls,
techniques,
tests,
and
other
actions
to
be
applied
to
each
TRU
payload
container,
waste
stream,
and
shipment.
Methods
of
compliance
with
each
requirement
shall
be
described
and
the
specific
procedure
cited.
These
methods
of
compliance
shall
include
procedural
controls,
administrative
controls,
and
waste
generation
process
controls.
The
QA
requirements
applicable
to
waste
characterization,
certification,
and
transportation
are
addressed
in
various
sections
of
this
CH­
WAC
and
are
briefly
summarized
in
section
4.0.
The
data
resulting
from
the
implementation
of
the
plans
and
procedures
will
form
the
basis
for
verifying
that
CHTRU
waste
to
be
sent
to
WIPP
is
certified
to
meet
the
CH­
WAC
by
the
responsible
site
certifying
official(
s).
­
7
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
7
Sites
shall
transmit
required
characterization,
certification,
and
shipping
data
to
WIPP
using
the
WIPP
Waste
Information
System
(
WWIS).
The
WWIS
is
an
electronic
database
equipped
with
edit/
limit
checks
to
ensure
that
the
data
representing
the
waste
payload
containers
are
in
compliance
with
this
CHWAC
The
WWIS
also
incorporates
the
automated
TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
e­
TRAMPAC)
software,
which
is
used
to
evaluate
containers
and
assemblies
of
CH­
TRU
waste
for
compliance
with
each
of
the
TRAMPAC
requirements.
Before
shipping
TRU
waste
payload
containers
from
a
WIPP­
accepted
waste
stream,
the
site
shall
transmit
the
required
waste
characterization,
certification,
and
shipping
data
via
WWIS
to
WIPP.
Sites
may
periodically
be
requested
to
transmit
payload
container
radiography
reports
or
other
data
to
WIPP.
WIPP
will
not
accept
any
waste
shipments
for
disposal
if
the
waste
payload
container
information
has
not
been
correctly
submitted
and
approved
for
shipment
by
the
WWIS
Data
Administrator.
The
WWIS
User's
Manual
(
reference
9)
provides
the
information
needed
by
TRU
waste
sites
to
perform
tasks
associated
with
transmittal
of
the
payload
container's
characterization,
certification,
and
shipment
information
to
WIPP.

Sites
will
be
notified
of
revisions
to
external
regulatory
requirements
by
CBFO.
Revisions
of
requirements
in
referenced
documents
not
controlled
by
the
DOE
(
but
by,
for
example,
the
EPA,
NRC,
or
NMED)
shall
have
precedence
over
the
values
specified
here
if
they
are
more
restrictive.
These
changes
will
be
incorporated
in
future
revisions
of
the
CH­
WAC.

3.1.1
DOE
Operations
and
Safety
Requirements
for
WIPP
The
WIPP
SAR
(
reference
14)
addresses
CH­
TRU
waste
handling
and
emplacement
operations.
The
waste
accepted
for
emplacement
in
the
WIPP
must
conform
to
the
SAR
and
the
associated
technical
safety
requirements
(
reference
15).
The
SAR
documents
the
safety
analyses
that
develop
and
evaluate
the
adequacy
of
the
WIPP
safety
bases
necessary
to
ensure
the
safety
of
workers,
the
public,
and
the
environment
from
the
hazards
posed
by
WIPP
waste
receiving,
handling,
and
emplacement
operations.
The
SAR
establishes
and
evaluates
the
adequacy
of
the
safety
bases
in
response
to
plant
normal
and
abnormal
operations
and
postulated
accident
conditions.

3.1.2
NRC
Transportation
Safety
Requirements
for
the
TRUPACT­
II
Acceptable
methods
for
payload
compliance
are
defined
in
the
TRUPACT­
II
Certificate
of
Compliance
and
implemented
by
the
TRAMPAC
(
reference
45).
For
shipments
to
WIPP,
each
site
must
prepare
a
site­
specific
TRAMPAC
describing
how
it
will
ensure
compliance
with
each
payload
parameter.
This
technical
plan
shall
contain
sufficient
detail
to
allow
reviewers
to
adequately
understand
and
evaluate
the
compliance
methodology
for
each
payload
parameter.

Sites
shall
have
a
packaging
QA
program
that
defines
the
QA
activities
that
apply
to
the
use
of
NRCapproved
transportation
packaging
equivalent
to
Title
10
of
the
Code
of
Federal
Regulations
(
10
CFR)
Part
71,
Subpart
H.
(
reference
29)
­
8
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
8
3.1.3
NMED
Hazardous
Waste
Facility
Permit
Requirements
TRU
waste
is
classified
as
TRU
mixed
waste
if
it
contains
hazardous
constituents
regulated
under
the
New
Mexico
Hazardous
Waste
Act.
Only
TRU
mixed
waste
and
TRU
waste
that
have
been
characterized
in
accordance
with
the
WIPP
WAP
and
that
meet
the
treatment,
storage,
and
disposal
facility
(
TSDF)
waste
acceptance
criteria
as
presented
in
permit
conditions
II.
C.
3.
a
through
II.
C.
3.
k
of
the
WIPP
Hazardous
Waste
Facility
Permit
will
be
accepted
at
the
WIPP
facility
for
disposal
in
the
permitted
underground
hazardous
waste
disposal
unit.

Prior
to
disposal,
each
participating
site
shall
develop
and
implement
a
QAPjP
that
addresses
all
the
applicable
requirements
specified
in
the
WIPP
WAP.
In
accordance
with
attachment
B5
of
the
WIPP
WAP,
the
QAPjP
will
include
the
qualitative
or
quantitative
criteria
for
making
a
hazardous
waste
determination.
All
site
QAPjPs
will
be
reviewed
and
approved
by
the
CBFO.

3.1.4
EPA
Compliance
Certification
Decision
Requirements
Title
40
CFR
§
194.24(
c)
states
that
the
DOE
shall
specify
the
limiting
values
for
waste
components
to
be
emplaced
in
the
repository
(
reference
33).
Appendix
WCL
(
Waste
Component
Limits)
of
the
Compliance
Certification
Application
(
CCA;
reference
8)
identifies
the
repository
limits
for
several
waste
components
including
free
water,
metals,
and
cellulose,
plastic,
and
rubber
(
CPR).
Although
the
CCA
does
not
specifiy
limiting
values
for
the
activities
and
masses
of
specific
radionuclides.
Table
4­
6
of
the
CCA
identifies
the
listed
values
for
a
number
of
radionuclides
that
are
considered
in
the
Performance
Assessment.
To
demonstrate
that
the
cumulative
total
activities
of
the
specified
radionuclides
(
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
234U,
238U,
90Sr,
and
137Cs)
are
consistent
with
the
levels
used
for
the
Performance
Assessment
and
the
compliance
certification
decision,
reporting,
and
tracking
of
the
specified
radionuclides
(
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
234U,
238U,
90Sr,
and
137Cs)
is
necessary,
as
required
by
Table
4­
10
of
the
CCA.
TRU
waste
payload
containers
shall
contain
more
than
100
nanocuries
per
gram
of
waste
(
nCi/
g)
of
alpha­
emitting
TRU
isotopes
with
half­
lives
greater
than
20
years,
as
specified
in
section
3.3.3
of
the
CH­
WAC.

The
repository
limit
for
free
water
is
a
maximum
of
1684
m3
and
is
met
by
the
residual
liquid
criterion
specified
in
section
3.4.1
of
the
CH­
WAC.

The
limits
for
metals
are
a
minimum
of
2
X
107
kg
for
ferrous
metals
and
2
X
103
kg
for
nonferrous
metals.
These
limits
will
be
met
in
the
total
repository
inventory
by
the
metals
that
constitute
the
payload
containers
alone;
thus,
WIPP
tracks
the
number
and
type
of
payload
containers
emplaced
in
the
repository
as
reported
in
the
WWIS
by
the
sites
(
see
section
3.2.1).
­
9
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
9
The
repository
limit
for
CPR
is
a
maximum
of
2
X
107
kg.
Sites
are
required
to
estimate
the
CPR
weights
and
report
these
estimates
in
the
WWIS
on
a
payload
container
basis
as
required
by
section
3.6.1.
Waste
generators
must
quantify
and
report
the
activities
and
masses
of
specific
radionuclides
for
the
purpose
of
tracking
the
total
radionuclide
inventory
of
the
repository
as
specified
in
section
3.3.1
of
the
CH­
WAC.
The
presence
or
absence
of
these
specific
radionuclides
is
determined
from
AK,
radioassay,
or
both
in
accordance
with
appendix
A
of
the
CH­
WAC.
The
results
of
this
determination
are
reported
in
the
WWIS
on
a
payload
container
basis.

3.1.5
Land
Withdrawal
Act
Requirements
The
term
"
WIPP"
means
the
Waste
Isolation
Pilot
Plant
project
authorized
under
section
213
of
the
Department
of
Energy
National
Security
and
Military
Applications
of
Nuclear
Energy
Authorization
Act
of
1980
(
Pub.
L.
96­
164;
93
Stat.
1259­
1265)
to
demonstrate
the
safe
disposal
of
radioactive
waste
materials
generated
by
atomic
energy
defense
activities
(
reference
20,
section
2[
19]).
Hence,
by
law,
WIPP
can
accept
only
radioactive
waste
generated
by
atomic
energy
defense
activities
of
the
United
States
(
reference
21,
section
2[
19]).

The
DOE
and
its
predecessor
agencies
were
engaged
in
a
broad
range
of
activities
that
fall
under
the
heading
of
atomic
energy
defense
activities.
A
TRU
waste
is
eligible
for
disposal
at
WIPP
if
it
has
been
generated
in
whole
or
in
part
by
one
or
more
of
the
following
functions
(
references
23
and
24):

 
Naval
reactors
development
 
Weapons
activities,
including
defense
inertial
confinement
fusion
 
Verification
and
control
technology
 
Defense
nuclear
materials
productions
 
Defense
nuclear
waste
and
materials
by­
products
management
 
Defense
nuclear
materials
security
and
safeguards
and
security
investigations
 
Defense
research
and
development
Using
AK,
DOE
sites
must
determine
that
each
waste
stream
to
be
disposed
of
at
WIPP
is
"
defense"
TRU
waste.

High­
level
radioactive
waste
or
spent
nuclear
fuel
shall
not
be
transported,
emplaced,
nor
disposed
of
at
WIPP
(
reference
20,
section
12).
Also,
no
transuranic
waste
may
be
transported
by
or
for
the
DOE
to
or
from
WIPP,
except
in
packages
(
1)
the
design
of
which
has
been
certified
by
the
NRC,
and
(
2)
that
have
been
determined
by
the
NRC
to
satisfy
its
quality
assurance
requirements
(
reference
21,
section
16).
­
10
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
10
3.2
Container
Properties
3.2.1
Description
Acceptance
Criterion.
Each
payload
container
shall
be
assigned
to
a
payload
shipping
category.
(
reference
45,
section
5.1)
Authorized
payload
containers
include:

 
55­
gallon
drums
(
either
direct
loaded
or
containing
a
pipe
component)

 
Standard
waste
boxes
(
SWBs,
either
direct
loaded,
or
containing
up
to
four
direct
loaded
55­
gallon
drums,
or
containing
one
bin)

 
Ten
drum
overpacks
(
TDOPs,
either
containing
up
to
ten
direct
loaded
55­
gallon
drums,
six
85­
gallon
drum
overpacks,
or
one
SWB)

Payload
containers
shall
meet
U.
S.
Department
of
Transportation
(
DOT)
Specification
7A,
Type
A,
packaging
requirements
(
reference
15,
section
5.9.12;
reference
42,
attachment
M1,
section
M1­
1b).
Payload
containers
must
be
made
of
steel
and
be
in
good
and
unimpaired
condition
prior
to
shipment
from
the
generator/
storage
sites.
To
demonstrate
compliance
with
the
requirement
that
payload
containers
be
in
good
and
unimpaired
condition,
the
exterior
of
all
payload
containers
shall
undergo
100%
visual
examination
(
VE)
prior
to
loading
into
a
TRUPACT­
II.
The
results
of
this
visual
examination
shall
be
documented
using
the
payload
container
integrity
checklist
contained
in
appendix
D.
A
payload
container
in
good
and
unimpaired
condition
1)
does
not
have
significant
rusting,
2)
is
of
sound
structural
integrity,
and,
3)
does
not
leak.
Significant
rusting
is
a
readily
observable
loss
of
metal
due
to
oxidation
(
e.
g.,
flaking,
bubbling,
or
pitting)
that
causes
degradation
of
the
payload
container's
structural
integrity.
Rusting
that
causes
discoloration
of
the
payload
container
surface
or
consists
of
minor
flaking
is
not
considered
significant.
A
payload
container
is
not
of
sound
structural
integrity
if
it
has
breaches
or
significant
denting/
deformation.
Breaching
is
defined
as
a
penetration
in
the
payload
container
that
exposes
the
internals
of
the
container.
Significant
denting/
deformation
is
defined
as
damage
to
the
payload
container
that
results
in
creasing,
cracking,
or
gouging
of
the
metal,
or
damage
that
affects
payload
container
closure.
Dents
or
deformations
that
do
not
result
in
creasing,
cracking,
or
gouging
or
affect
payload
container
closure
are
not
considered
significant.
Generator
sites
will
report
to
the
WWIS
the
number
and
types
of
payload
containers
planned
for
shipment
to
the
WIPP
(
reference
8,
appendix
WCL).

Compliance:
Each
payload
container
is
assigned
a
shipping
category
and
is
verified
in
the
WTS
or
WIPP
Waste
Information
System
(
WWIS).
Authorized
payload
containers
are
controlled
and
verified
in
accordance
with
work
instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly.
Payload
container
visual
inspections
detailed
in
Appendix
D
are
performed
and
documented
per
work
instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly.
Payload
containers
that
do
not
meet
the
container
integrity
visual
examination
are
overpacked
prior
to
shipment.
The
numbers
and
types
of
payload
containers
planned
for
shipment
to
WIPP
are
reported
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.
­
11
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
11
3.2.2
Weight
Limits
and
Center
of
Gravity
Acceptance
Criterion.
Each
payload
container,
payload
assembly,
and
loaded
TRUPACT­
II
shall
comply
with
the
weight
limits
shown
in
table
3.2.2.
Weight
calculations
for
the
payload
assembly
must
include
the
measurement
error.
The
total
weight
of
the
top
seven
55­
gallon
drums
or
SWB
of
the
payload
assembly
shall
be
less
than
or
equal
to
the
total
weight
of
the
bottom
seven
55­
gallon
drums
or
SWB,
respectively.
The
total
weight
of
the
top
five
55­
gallon
drums
or
three
85­
gallon
drum
overpacks
in
a
TDOP
shall
be
less
than
or
equal
to
the
total
weight
of
the
bottom
five
55­
gallon
drums
or
three
85­
gallon
drum
overpacks,
respectively.
Calibrations
of
the
scales
used
to
make
these
weight
determinations
shall
be
in
accordance
with
the
National
Institute
of
Standards
and
Technology
(
NIST)
Handbook
44,
Specifications,
Tolerances,
and
Other
Technical
Requirements
for
Weighing
and
Measuring
Devices,
or
an
equivalent
standard.
(
reference
45,
section
2.3;
reference
41)

Table
3.2.2
Weight
Limits
Container
Maximum
Gross
Weight
(
lbs)
55­
gallon
drum
<
1,000
55­
gallon
drum
containing
a
six­
inch­
diameter
standard
pipe
component
(
i.
e.,
a
standard
pipe
overpack)
<
328
55­
gallon
drum
containing
a
twelve­
inch­
diameter
standard
pipe
component
(
i.
e.,
a
standard
pipe
overpack)
<
547
55­
gallon
drum
containing
an
S100
pipe
component
(
i.
e.,
an
S100
pipe
overpack)
<
650
55­
gallon
drum
containing
an
S200
pipe
component
(
i.
e.,
an
S200
pipe
overpack)
<
547
SWB
<
4,000
TDOP
<
6,700
Payload
assembly
of
fourteen
55­
gallon
drums
<
7,265
Payload
assembly
of
two
SWBs
<
7,265
TRUPACT­
II
<
19,250
Truck
(
tractor/
trailer)
<
80,000
­
12
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
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correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
12
Compliance:
Each
drum
is
weighed
on
a
calibrated
scale
at
one
of
the
drum
assay
systems
(
DAS)
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations
The
payload
container
weight
is
evaluated
by
the
WTS
or
WWIS
for
compliance
with
the
requirement
listed
in
Table
3.2.2.
This
evaluation
compares
the
payload
container
weight
including
its
associated
measurement
error
(
expressed
in
terms
of
one
standard
deviation).
Calibrations
of
the
scales
are
done
in
accordance
with
the
NIST
Handbook
44,
Specifications,
Tolerances,
and
Other
Technical
Requirements
for
Weighing
and
Measuring
Devices,
or
an
equivalent
standard.
The
weight
is
reported
to
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

Additional
weight
limits
may
be
implemented
based
on
restrictions
identified
by
procurement
specifications
and
testing.
These
restrictions
will
also
be
addressed
in
the
applicable
work
instructions
as
they
are
identified.

The
WTS
or
WWIS
evaluates
the
TRUPACT­
II
payload
assembly
for
compliance
with
the
weight
requirements
using
the
location
and
weight
of
the
individual
payload
containers.
The
total
weight
of
the
top
seven
55­
gallon
drums
or
SWB
of
the
payload
assembly
is
less
than
or
equal
to
the
total
weight
of
the
bottom
seven
55­
gallon
drums
or
SWB,
respectively.
The
total
weight
of
the
top
five
55­
gallon
drums
or
three
85­
gallon
drum
overpacks
in
a
TDOP
is
be
less
than
or
equal
to
the
total
weight
of
the
bottom
five
55­
gallon
drums
or
three
85­
gallon
drum
overpacks,
respectively.
Evaluations
of
the
TRUPACT­
II
and
truck
weights
for
compliance
with
the
requirements
listed
in
Table
3.2.2
are
performed
using
the
calculated
payload
assembly
weights,
reported
TRUPACT­
II
weights,
and
the
reported
truck
weight.
Work
Instructions,
INST­
OI­
20,
TRUPACT­
II
Operations,
and
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly,
ensure
compliance.
­
13
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
13
3.2.3
Assembly
Configurations
Acceptance
Criterion.
Payload
container
assembly
configurations
authorized
for
shipment
in
the
TRUPACT­
II
shall
be
in
accordance
with
table
3.2.3.

Table
3.2.3
Payload
Container
Assembly
Configurations
Number
of
Payload
Containers
in
Assembly
Payload
Container
Configuration
14
55­
gallon
drums
14
55­
gallon
drums,
each
containing
one
standard
pipe
component
14
55­
gallon
drums,
each
containing
one
S100
pipe
component
14
55­
gallon
drums,
each
containing
one
S200
pipe
component
2
SWBs
2
SWBs,
each
containing
one
bin
2
SWBs,
each
containing
up
to
four
55­
gallon
drums
1
TDOP
containing
up
to
10
55­
gallon
drums
1
TDOP
containing
up
to
six
85­
gallon
drums
(
each
85­
gallon
drum
containing
one
55­
gallon
drum)
1
TDOP
containing
one
SWB
1
TDOP
containing
one
bin
within
an
SWB
1
TDOP
containing
up
to
four
55­
gallon
drums
within
an
SWB
Although
85­
gallon
drum
overpacks
are
acceptable
at
WIPP,
they
are
not
authorized
for
transport
in
a
TRUPACT­
II
as
individual
payload
containers.

Compliance:
Work
instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly,
controls
the
maximum
number
of
containers
per
TRUPACT­
II
and
the
authorized
packaging
configurations.

3.2.4
Removable
Surface
Contamination
Acceptance
Criterion.
Removable
surface
contamination
on
CH­
TRU
waste
payload
containers,
payload
assemblies,
and
packaging
shall
not
exceed
20
dpm/
100
cm2
alpha
and
200
dpm/
100
cm2
beta­
gamma
(
reference
15,
section
5.9.12;
reference
42,
attachment
M1,
section
M1­
1d[
2];
reference
37;
and
reference
31).
The
fixing
of
surface
contamination
to
meet
these
criteria
is
not
allowed
by
WIPP
in
accordance
with
best
management
practices
for
ensuring
worker
radiation
dose
as
low
as
reasonable
achievable.
­
14
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
14
Compliance:
A
radiological
technician
(
RT)
surveys
each
container
which
is
documented
per
the
work
instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly.
Containers
that
exceed
allowable
surface
contamination
levels
are
decontaminated
and/
or
overpacked.
Surveys
on
the
loaded
TRUPACT­
II
are
performed
in
accordance
with
work
instructions,
INST­
0I­
20,
TRUPACT­
II
Operations.
Results
are
reported
to
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

3.2.5
Identification/
Labeling
Acceptance
Criterion.
Each
payload
container
shall
be
labeled
with
a
unique
container
identification
number
using
bar
code
labels
permanently
attached
in
conspicuous
locations.
The
payload
container
identification
number
shall
be
in
medium
to
low
density
Code
39
bar
code
symbology
as
required
by
American
National
Standards
Institute
(
ANSI)
standard
ANSI/
AIM
BC1­
1995
(
reference
40)
in
characters
at
least
one
inch
high
and
alphanumeric
characters
at
least
one­
half
inch
high.
In
the
case
of
55­
gallon
drums,
the
bar
code
identification
labels
shall
be
placed
at
three
locations
approximately
120
degrees
apart
so
that
at
least
one
label
is
clearly
visible
when
the
drums
are
assembled
into
a
seven­
pack
(
i.
e.,
a
label
must
be
visible
after
slip
sheets
and
wrapping
are
applied).
In
the
case
of
SWBs,
bar
code
labels
are
required
on
the
flat
sides
of
the
SWB
(
reference
4).
For
TDOPs,
a
minimum
of
one
bar
code
is
required.

Payload
containers
shall
be
marked
"
Caution
Radioactive
Material"
using
a
yellow
and
magenta
label
as
specified
in
10
CFR
Part
835
(
reference
31).
Those
payload
containers
whose
contents
are
also
RCRA
regulated
(
mixed­
TRU)
shall
be
additionally
marked
"
Hazardous
Waste"
as
specified
in
40
CFR
§
262.32
(
reference
34).

If
an
empty
55­
drum
is
used
as
dunnage
to
complete
a
payload
configuration,
the
dunnage
container
shall
be
labeled
with
the
following
information:

 
Unique
container
identification
number
 
"
EMPTY"
or
"
DUNNAGE
If
a
seven­
pack
of
only
dunnage
55­
gallon
drums
or
a
dunnage
SWB
is
used
in
the
TRUPACT­
II,
the
container(
s)
shall
be
labeled
only
"
EMPTY"
or
"
DUNNAGE."
The
unique
container
identification
number
label
is
not
required
for
a
seven­
pack
of
dunnage,
55­
gallon
drums,
or
a
dunnage
SWB.
(
reference
45,
section
2.4.1)

Compliance:
Payload
containers
certified
for
shipment
by
the
AMWTP,
are
labeled
in
medium
to
low
density
Code
39
bar
code
symbology
as
required
by
American
National
Standards
Institute
(
ANSI)
standard
ANSI/
AIM
BC1­
1995
(
reference
40)
in
characters
at
least
one
inch
high
and
alphanumeric
characters
at
least
one­
half
inch
high
in
the
following
format:
BNXXXXXXXXXXX,
where
BN
represents
BNFL,
Inc.
AMWTP
and
XXXXXXXXXXX
represents
a
sequential
number
generated
by
the
WTS.
The
WTS
also
verifies
that
the
identification
number
is
unique
and
that
a
duplicate
container
identification
number
does
not
exist.
Empty
containers
used
as
dunnage
are
labeled
"
EMPTY"
or
"
DUNNAGE".
­
15
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
15
Payload
containers
are
marked
"
Caution
Radioactive
Material"
using
a
yellow
and
magenta
label
as
specified
in
10
CFR
Part
835
(
reference
31).
Those
payload
containers
whose
contents
are
also
RCRA
regulated
(
mixed­
TRU)
are
additionally
marked
"
Hazardous
Waste".

55­
gallon
drums
are
labeled
as
they
are
retrieved
from
storage
in
accordance
with
Work
Instruction,
INST­
OI­
09,
Retrieval
Enclosure
Waste
Container
Extraction,
or
Work
Instruction,
INST­
OI­
11,
Waste
Container
Handling.

Work
instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly,
prepares
the
labels
used
when
containers
are
placed
into
a
TDOP
or
SWB
and
ensure
that
labels
attached
to
all
payload
containers
are
correct
prior
to
shipment.

3.2.6
Dunnage
Acceptance
Criterion.
A
shipper
shall
use
empty
55­
gallon
drums
or
a
SWB
as
dunnage
to
complete
a
payload
configuration
if
too
few
payload
containers
are
available
that
meet
transportation
requirements.
The
dunnage
container(
s)
must
meet
the
specifications
of
appendix
2.1
of
the
TRAMPAC
with
the
exception
that
dunnage
containers
shall
have
open
vent
ports
(
i.
e.,
not
filtered
or
plugged).
(
reference
45,
section
2.2.1)

To
maximize
the
efficiency
of
disposal
operations
at
the
WIPP,
the
use
of
dunnage
drums
should
be
minimized.
In
the
event
the
use
of
dunnage
drums
cannot
be
avoided,
the
preferred
practice
for
maximizing
the
efficiency
of
waste
handling
and
the
utilization
of
disposal
room
capacity
is
to
ship
them
in
assemblies
(
i.
e.,
a
seven­
pack
assembly
of
55­
gallon
drums).
The
use
of
dunnage
drums
is
reviewed
and
approved
concurrently
with
the
review
and
approval
of
shipment
assemblies
by
the
WWIS
Data
Administrator
on
a
case­
by­
case
basis.

Compliance:
Work
Instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly,
verifies
that
empty
55­
gal
drums
or
SWBs
used,
as
dunnage
to
complete
payload
configurations
are
labeled
"
Empty"
or
"
Dunnage".
Dunnage
containers
are
inspected
in
accordance
with
Work
Instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly,
to
demonstrate
compliance
with
the
U.
S.
Department
of
Transportation
(
DOT)
Specification
7A,
Type
A,
packaging
requirements(
reference
15,
section
5.9.12;
reference
42,
attachment
M1,
section
M1­
1b)
that
payload
containers
be
in
good
and
unimpaired
condition,
the
exterior
of
all
payload
containers
are
inspected
prior
to
loading
into
a
TRUPACT­
II.
Payload
containers
are
also
inspected
to
ensure
that
containers
have
open
vent
ports
(
i.
e.,
not
filtered
or
plugged).
These
containers
are
reported
in
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.
­
16
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
16
3.2.7
Filter
Vents
Acceptance
Criterion.
Payload
containers
that
have
been
stored
in
an
unvented
condition
(
i.
e.,
no
filter
and/
or
unpunctured
liner)
shall
be
aspirated
for
a
specific
length
of
time
as
described
in
the
TRAMPAC
to
ensure
equilibration
of
any
gases
that
may
have
accumulated
in
the
closed
payload
container.
(
reference
45,
section
5.3.1
and
appendix
5.9)

Each
payload
container
shall
have
one
or
more
filter
vents
that
meet
the
specifications
of
appendix
2.5
of
the
TRAMPAC
(
reference
15,
section
5.9.12;
reference
45,
section
2.5.1).
The
model
number
of
each
filter
vent
or
combination
of
filter
vents
installed
on
a
payload
container
shall
be
reported
to
the
WWIS.
A
listing
of
available
CBFO
filter
vent
models
is
provided
on
the
CBFO
Web
Page
(
http://
www.
wipp.
ws/
transport.
htm).
This
Internet
link
is
provided
for
informational
purposes
only
and
may
change.

Compliance:
QA
procedures
provide
protocol
for
procuring
and
inspecting
filters
to
ensure
compliance
with
appendix
2.5
of
the
TRAMPAC
specifications
for
filter
vents,
which
are
performed
in
accordance
with
management
procedure,
MP­
PCMT­
15.3,
Purchase
Order/
Subcontract
Preparation
and
Control
and
MP­
Q&
SI­
5.7,
Quality
Inspections.

Payload
containers
that
have
been
stored
in
an
unvented
condition
(
i.
e.,
no
filter
and/
or
unpunctured)
liner
are
vented
and
aspirated
in
accordance
with
work
instruction,
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations.

Work
instruction,
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly,
verifies
that
each
payload
container
contains
the
minimum
number
of
filters
as
specified
in
Appendix
2.5
of
the
TRAMPAC.
The
model
number
of
each
filter
or
combination
of
filters
installed
in
a
payload
container
is
recorded
and
stored
in
the
WTS
and
reported
to
the
WWIS
in
accordance
with
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

3.3
Radiological
Properties
With
respect
to
the
required
radiological
properties
identified
within
this
section,
they
can
be
divided
into
two
distinct
groups.

The
first
group
includes
the
activities
and
masses
of
the
ten
WIPP­
tracked
radionuclides
(
i.
e.,
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
234U,
238U,
90Sr,
and
137Cs)
and
the
TRU
alpha
activity
concentration
(
i.
e.,
>
100
nCi/
g
of
alpha­
emitting
TRU
isotopes
with
half
lives
greater
than
20
years)
of
the
waste.
This
set
of
radiological
properties
is
regulated
by
the
EPA
in
accordance
with
40
CFR
Parts
191
and
194
(
references
32
and
33).
Estimates
of
their
activities
and
masses
shall
be
derived
from
a
system
of
controls
certified
by
CBFO
that
includes
AK,
computations,
measurements,
sampling,
etc.
(
reference
8,
appendix
WCL).
Appendix
A
provides
the
methods
and
requirements
by
which
to
characterize
the
radiological
composition
of
the
CH­
TRU
waste
utilizing
radioassay
techniques.
­
17
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
17
The
second
group
includes
the
remaining
radionuclides
contributing
to
the
fissile
gram
equivalent
(
FGE),
the
plutonium­
239
equivalent
curies
(
PE­
Ci),
and
the
decay
heat
of
the
payload
container.
This
set
of
radiological
data
is
regulated
both
by
the
NRC
as
specified
in
the
TRAMPAC
(
reference
45)
and
the
CBFO
as
required
by
the
WIPP
Technical
Safety
Requirements
(
reference
15).
PE­
Ci
quantities
shall
be
calculated
for
each
payload
container
in
accordance
with
appendix
B.
Any
TRAMPAC
compliant
method
may
be
used
to
quantify
the
remaining
radiological
properties
at
the
discretion
of
the
shipping
facility.
Appendix
A
provides
recommended
radioassay
methods
by
which
to
characterize
the
remaining
radiological
properties.
However,
the
resulting
data
(
e.
g.,
AK
from
Safeguards
and
Security
data),
the
source/
method
from
which
the
data
was
generated,
and
the
basis
for
the
reliability
of
the
data
shall
be
submitted
to
and
approved
by
CBFO
prior
to
use.

3.3.1
Radionuclide
Composition
Acceptance
Criterion.
The
activities
and
masses
of
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
234U,
238U,
90Sr,
and
137Cs
shall
be
established
on
a
payload
container
basis
for
purposes
of
tracking
their
contributions
to
the
total
WIPP
radionuclide
inventory
(
reference
8,
appendix
WCL).
The
estimated
activities
and
masses,
including
their
associated
total
measurement
uncertainties
(
TMU)
expressed
in
terms
of
one
standard
deviation,
for
these
ten
radionuclides
shall
be
reported
to
the
WWIS
on
a
payload
container
basis.
For
any
of
these
ten
radionuclides
whose
presence
can
be
substantiated
from
AK,
direct
measurement,
computations,
or
a
combination
thereof,
and
whose
measured
data
are
determined
to
be
below
the
lower
limit
of
detection
(
LLD)
for
that
radionuclide,
the
site
shall
report
the
character
string
"<
LLD"
to
the
WWIS
for
the
activity
and
mass
of
that
radionuclide;
otherwise
a
value
of
zero
shall
be
reported.
See
appendix
A,
section
A.
3,
for
information
pertaining
to
the
development
and
application
of
LLD.

In
addition,
all
radionuclides
other
than
the
ten
WIPP­
tracked
radionuclides
(
i.
e.,
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
234U,
238U,
90Sr,
and
137Cs)
that
contribute
to
95%
of
the
radioactive
hazard
for
the
payload
container
shall
be
reported
on
the
TRUPACT­
II
bill
of
lading
or
manifest
in
accordance
with
49
CFR
§
172.203
and
49
CFR
§
173.433
(
reference
35,
reference
36).
The
activities
and
masses
of
these
other
radioisotopes
shall
also
be
reported
to
the
WWIS
along
with
their
associated
TMU,
expressed
in
terms
of
one
standard
deviation
for
each
waste
container
(
reference
8).
­
18
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
18
Compliance:
The
quantity
of
radionuclides
in
each
payload
container
along
with
the
associated
TMU
values
(
expressed
in
terms
of
one
standard
deviation)
is
determined
using
the
nondestructive
assay
(
NDA)
method
described
in
appendix
A
and
is
performed
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
Each
radionuclide
quantity
and
its
associated
TMU
are
transferred
from
the
DAS
to
the
WTS.
The
method
used
to
perform
the
calculations
for
the
radionuclides
and
associated
TMU
values
are
documented
in
the
Canberra
Industries,
Genie
2000
Spectroscopy
System
Customization
Tools,
ICN
9230847F4,
NDA
2000
Technical
Reference
Manual,
ICN
9231595C,
and
Total
Measurement
Uncertainty
for
the
AMWTP
Integrated
Waste
Assay
Systems,
CI­
IDA­
NDA­
0055.
For
the
ten
radionuclides
(
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
235U,
90Sr,
and
137Cs)
whose
presence
can
be
substantiated
from
AK,
direct
measurement,
computations,
or
a
combination
thereof,
and
whose
measured
data
are
determined
to
be
below
the
lower
limit
of
detection
(
LLD)
for
that
radionuclide,
WTS
reports
the
character
string
"<
LLD"
to
the
WWIS
for
the
activity
and
mass
of
that
radionuclide,
otherwise
a
value
of
zero
is
reported.

In
addition
to
the
ten
WIPP­
tracked
radionuclides,
235U
is
also
quantified,
if
present
above
its
LLD,
in
order
to
calculate
the
239Pu
Fissile
Gram
Equivalent
(
FGE)
for
compliance
with
the
TRUPACT­
II
requirements
(
see
section
3.3.2).
All
radionuclides
other
than
the
ten
WIPP­
tracked
radionuclides
that
contribute
to
95%
of
the
radioactive
hazard
for
each
container
are
also
stored
in
the
WTS.

The
quantity
of
each
radionuclide
comprising
95%
of
the
radioactive
hazard
whose
value
is
above
the
LLD
and
its
associated
TMU
expressed
in
terms
of
one
standard
deviation
are
reported
to
the
WWIS
for
each
payload
container
and
on
the
TRUPACT­
II
bill
of
lading
or
manifest
for
each
shipment.

3.3.2
239Pu
Fissile
Gram
Equivalent
Acceptance
Criterion.
For
each
payload
container
and
loaded
TRUPACT­
II,
the
sum
of
239Pu
FGE
plus
two
times
its
associated
TMU,
expressed
in
terms
of
one
standard
deviation,
shall
comply
with
the
limits
in
table
3.3.2
(
reference
15,
sections
5.9.11
and
5.9.12;
reference
45,
section
3.1.1).
The
values
calculated
for
239Pu
FGE
and
its
associated
TMU
(
expressed
in
terms
of
one
standard
deviation)
shall
be
reported
to
the
WWIS
for
each
payload
container.
­
19
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
19
Table
3.3.2
239Pu
FGE
Limits
Container
Type
239Pu
FGE
Limit
55­
gallon
drum
(
including
all
pipe
overpacks)
<
200
SWB
<
325
TDOP
<
325
TRUPACT­
II
(
containing
either
14
55­
gallon
drums,
2
SWBs,
or
1
TDOP)
<
325
TRUPACT­
II
(
containing
either
14
standard,
14
S100,
or
14
S200
pipe
overpacks)
<
2800
Compliance:
The
239Pu
FGE
quantities
in
each
drum
container
along
with
the
associated
TMU
values
(
expressed
in
terms
of
one
standard
deviation)
is
calculated
for
each
container
using
the
radionuclide
values
determined
by
the
DAS
described
in
appendix
A
and
the
associated
239Pu
FGE
values
tabulated
in
the
American
National
Standards
Institute/
American
Nuclear
Society
(
ANSI/
ANS)
Standard
8.15­
1981,
"
Nuclear
Criticality
control
of
Special
Actinide
Elements".
The
method
that
is
used
to
perform
the
calculations
for
the
239Pu
FGE
and
its
associated
TMU
is
documented
in
the
Canberra
Industries,
Genie
2000
Spectroscopy
System
Customization
Tools,
ICN
9230847F4,
NDA
2000
Technical
Reference
Manual,
ICN
9231595C,
and
Total
Measurement
Uncertainty
for
the
AMWTP
Integrated
Waste
Assay
Systems,
CI­
IDA­
NDA­
0055.
The
calculated
239Pu
along
with
its
associated
TMU
are
transferred
from
the
DAS
in
accordance
with
work
instruction
INST­
OI­
14,
Drum
Assay
Operations,
and
is
stored
in
the
WTS.
The
WTS
evaluates
each
payload
container
and
loaded
TRUPACT­
II
for
compliance
with
the
limits
in
table
3.3.2.
The
values
calculated
for
239Pu
FGE
and
its
associated
TMU
(
expressed
in
terms
of
one
standard
deviation)
are
reported
to
the
WWIS
for
each
payload
container
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.
­
20
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
20
3.3.3
TRU
Alpha
Activity
Concentration
Acceptance
Criterion.
TRU
waste
payload
containers
shall
contain
more
than
100
nCi/
g
of
alphaemitting
TRU
isotopes
with
half­
lives
greater
than
20
years.
Without
taking
into
consideration
the
TMU,
the
TRU
alpha
activity
concentration
for
a
payload
container
is
determined
by
dividing
the
TRU
alpha
activity
of
the
waste
by
the
weight
of
the
waste.
The
weight
of
the
waste
is
the
weight
of
the
material
placed
into
the
payload
container
(
i.
e.,
the
net
weight
of
the
container).
The
weight
of
the
waste
is
typically
determined
by
subtracting
the
tare
weight
of
the
payload
container
(
including
the
weight
of
the
rigid
liner
and
any
shielding
external
from
the
waste,
if
applicable)
from
the
gross
weight
of
the
payload
container.
In
the
event
waste
containers
(
e.
g.,
55­
gallon
drums)
that
have
been
radioassayed
are
overpacked
in
a
payload
container
(
e.
g.,
in
an
SWB),
sites
shall
sum
the
individual
TRU
alpha
activity
values
of
the
individual
waste
containers
and
divide
by
the
sum
of
the
individual
net
waste
weights
(
i.
e.,
less
container,
shielding,
and
liner
weights
as
appropriate)
to
determine
the
activity
per
gram
for
the
payload
container.
Loading
a
55­
gallon
pipe­
overpack
with
cans
is
considered
direct
loading
­
not
overpacking
for
the
purposes
of
calculating
the
weight
of
the
container.
The
TRU
alpha
activity
concentration
shall
be
reported
to
the
WWIS;
however,
there
are
no
reporting
requirements
for
its
associated
TMU.
(
reference
21,
section
2[
18];
reference
8,
chapter
4)

Compliance.
The
TRU
alpha
activity
in
each
drum
is
determined
from
the
alpha­
emitting
TRU
isotopes
with
half­
lives
greater
than
20
years.
The
TRU
alpha
activity
is
determined
using
the
DAS
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
The
TRU
alpha
activity
concentration
for
each
payload
container
is
calculated
by
dividing
the
TRU
alpha
activity
by
the
net
weight
of
the
container
(
weight
of
the
waste).
The
net
weight
of
the
container
is
determined
by
subtracting
the
tare
weight
of
the
container
(
including
the
weight
of
the
rigid
liner
and
any
shielding
external
to
the
waste,
if
applicable)
from
the
gross
weight
of
the
container.
The
method
used
to
determine
the
gross
weight
of
the
container
is
described
in
section
3.2.2.
The
TRU
alpha
activity
concentration
is
transferred
from
the
DAS
and
stored
on
the
WTS.
In
the
event
a
waste
drum
is
overpacked
in
a
payload
container,
the
reported
TRU
alpha
activity
concentration
for
the
overpacked
payload
container
is
determined
by
summing
the
TRU
alpha
activity
values
of
the
individual
waste
containers
and
dividing
by
sum
of
the
net
waste
weights
of
the
individual
waste
containers.

The
WTS
software
evaluates
each
payload
container
for
compliance
with
the
TRU
alpha
activity
concentration
limit
(>
100nCi/
g).
The
TRU
alpha
activity
concentration
and
the
associated
TMU
is
reported
to
the
WWIS
for
payload
containers
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

3.3.4
239Pu
Equivalent
Activity
Acceptance
Criterion.
Plutonium­
239
equivalent
curie
(
PE­
Ci)
limits
are
shown
in
table
3.3.4.
PE­
Ci
quantities
shall
be
calculated
for
each
payload
container
(
see
Appendix
B)
and
reported
to
WIPP
using
the
WWIS.
There
are
no
reporting
requirements
for
the
associated
TMU.
(
reference
15,
section
5.9.12)
­
21
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
21
Table
3.3.4
PE­
Ci
Limits
Waste
Container
Packing
Configuration
239Pu
PE­
Ci
Limit
Direct
load
 
all
approved
waste
forms
<
80
Direct
load
 
solidified/
vitrified
waste
only
<
1,800
Overpacked
into
a
85­
gallon
drum,
SWB,
or
TDOP
 
all
approved
waste
forms
<
1,100
55­
gallon
drum
in
good
condition
Overpacked
into
a
85­
gallon
drum,
SWB,
or
TDOP
 
solidified/
vitrified
waste
only
<
1,800
Overpacked
into
a
85­
gallon
drum,
SWB,
or
TDOP
 
all
approved
waste
forms
<
80,
 
130,
 
130
respectively
55­
gallon
drum
in
damaged
condition
Overpacked
into
a
85­
gallon
drum,
SWB,
or
TDOP
 
solidified/
vitrified
waste
only
<
1,800
55­
gallon
pipe
component
in
good
condition
Direct
load
 
all
approved
waste
forms
<
1,800
Overpacked
into
a
TDOP
 
all
approved
waste
forms
<
1,100
85­
gallon
drum
in
good
condition
Overpacked
into
a
TDOP
 
solidified/
vitrified
waste
only
<
1,800
Overpacked
into
a
TDOP
 
all
approved
waste
forms
<
130
85­
gallon
drum
in
damaged
condition
Overpacked
into
a
TDOP
 
solidified/
vitrified
waste
only
<
1,800
Direct
load
(
or
a
bin)
 
all
approved
waste
forms
<
130
Direct
load
(
or
a
bin)
 
solidified/
vitrified
waste
only
<
1,800
Overpacked
into
a
TDOP
 
all
approved
waste
forms
<
1,100
SWB
in
good
condition
Overpacked
into
a
TDOP
 
solidified/
vitrified
waste
only
<
1,800
Overpacked
into
a
TDOP
 
all
approved
waste
forms
<
130
SWB
in
damaged
condition
Overpacked
into
a
TDOP
 
solidified/
vitrified
waste
only
<
1,800
­
22
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
22
Compliance:
The
plutonium
equivalent
curies
(
PE­
Ci)
for
each
drum
are
determined
using
the
DAS
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
Appendix
B
describes
the
methodology
for
calculating
the
PE­
Ci
value
based
on
the
radionuclide
values
determined
by
the
DAS
as
described
in
appendix
A.
The
PE­
Ci
value
for
overpack
containers
is
calculated
by
the
WTS
based
on
the
combined
drum
data.
PE­
Ci
values
are
transferred
from
the
DAS
and
stored
in
the
WTS.

The
WTS
software
evaluates
each
payload
container
for
compliance
with
the
PE­
Ci
limits
in
table
3.3.4.
The
PE­
Ci
value
is
reported
to
the
WWIS
for
each
payload
container
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

3.3.5
Radiation
Dose
Equivalent
Rate
Acceptance
Criterion.
The
external
radiation
dose
equivalent
rate
of
individual
payload
containers
shall
be
 
<
200
mrem/
h
at
the
surface.
The
external
radiation
dose
equivalent
rate
of
the
TRUPACT­
II
shall
be
<

 
200
mrem/
h
at
the
surface
and
<
10
mrem/
h
at
2
m.
Additional
internal
payload
container
shielding,
beyond
that
identified
in
appendix
2.1
of
the
TRAMPAC
as
an
integral
component
of
the
payload
container,
shall
not
be
used
to
meet
this
criterion.
Total
dose
equivalent
rate
and
the
neutron
contribution
to
the
total
dose
equivalent
rate
shall
be
reported
for
each
payload
container
in
the
WWIS.
(
reference
15,
section
5.9.12;
reference
42,
module
I,
section
I.
D.
1;
reference
45,
section
3.2.1)

Compliance:
Each
container
is
survey
by
a
Radiological
Technician
(
RT)
and
documented
per
work
instructions,
INST­
OI­
20,
TRUPACT­
II
Operations,
and
INST­
OI­
21,
TRUPACT­
II
Payload
Assembly.
The
highest
measured
combined
dose
rate
at
the
drum
surface
is
entered
in
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.
The
TRUPACT­
II
is
also
surveyed
and
the
combined
dose
rate
at
the
surface
and
2
m
from
any
side
(
excluding
the
top
and
bottom)
is
recorded
on
the
shipping
documentation
and
reported
in
WWIS.
Dose
rates
for
beta­
gamma
and
neutron
dose
are
reported
separately.

3.3.6
Decay
Heat
Acceptance
Criterion.
The
sum
of
the
decay
heat
for
each
payload
container
plus
its
TMU
shall
be
less
than
or
equal
to
the
limits
of
the
assigned
shipping
category
specified
in
table
5.5­
1
of
appendix
5.5
of
the
TRAMPAC.
For
those
payload
containers
that
exceed
the
decay
heat
limit,
a
determination
of
compliance
with
the
unified
flammable
(
gas/
VOC)
concentration
limit
as
specified
in
the
TRAMPAC
allows
the
payload
container
to
be
shipped
in
the
TRUPACT­
II
package
under
test
category
(
see
section
3.5.5).
The
values
calculated
for
decay
heat
and
its
associated
TMU
(
expressed
in
terms
of
one
standard
deviation)
shall
be
reported
to
the
WWIS
for
each
payload
container.
(
reference
45,
section
5.2
and
appendix
1.2
and
5.5).
­
23
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
23
Compliance:
The
decay
heat
is
determined
using
the
DAS
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
The
total
decay
heat
from
the
radioactive
decay
of
the
radioisotopes
within
an
individual
payload
container,
and
the
total
decay
heat
from
all
payload
containers
in
a
TRUPACT­
II,
is
determined
by
calculations
using
isotopic
inventory
information
for
fissile
and
nonfissile
TRU
radionuclides
and
for
any
non­
TRU
radionuclides
present
in
the
payload
container.
The
values
for
total
decay
and
its
TMU
are
determined
using
the
method
described
in
appendix
A.
The
sum
of
the
calculated
value
of
the
decay
heat
and
the
total
measurement
uncertainty
at
one
standard
deviation
is
transferred
from
the
DAS
and
stored
in
the
WTS.

The
WTS
or
WWIS
performs
an
evaluation
to
determine
if
the
payload
container
exceeds
the
analytical
decay
heat
limit
derived
from
the
decay
heat
limit
for
shipping
categories
presented
in
Appendix
5.5
of
the
TRAMPAC.
As
defined
in
Table
5­
2
of
Section
5.0
of
the
TRAMPAC,
payload
containers
of
Waste
Material
Type
II.
1
and
Waste
Type
III
that
meet
the
criteria
for
the
application
of
dose­
dependent
G
values
(
watt*
year>
0.012)
are
assigned
a
shipping
category
that
uses
a
dose­
dependent
G
value.
This
assignment
revises
the
four­
digit
G
value
notation
used
in
the
numeric
shipping
category
otherwise
assigned
to
the
payload
container.
For
containers
that
exceed
the
decay
heat
limit,
a
determination
of
compliance
with
the
unified
flammable
(
gas/
VOC)
concentration
limit
specified
in
the
TRAMPAC
allows
the
payload
container
to
be
shipped
under
the
test
category
requirements
(
see
section
3.5.5).
The
decay
heat
value
and
the
associated
TMU
is
reported
to
the
WWIS
per
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

The
evaluation
of
payload
containers
and
programmed
reassignment
of
shipping
category
will
be
evaluated
by
WWIS.

3.4
Physical
Properties
3.4.1
Residual
Liquids
Acceptance
Criterion.
Liquid
waste
is
prohibited
at
WIPP.
Waste
shall
contain
as
little
residual
liquid
as
is
reasonably
achievable
by
pouring,
pumping,
and/
or
aspirating.
Internal
containers
shall
also
contain
no
more
than
1
inch
or
2.5
cm
in
the
bottom
of
the
internal
containers.
The
total
residual
liquid
in
any
payload
container
shall
not
exceed
1
percent
by
volume
of
that
payload
container.
If
visual
examination
methods
are
used
in
lieu
of
radiography,
then
the
detection
of
any
liquids
in
non­
transparent
internal
containers
will
be
addressed
by
using
the
total
volume
of
the
internal
container
when
determining
the
total
volume
of
liquids
within
the
payload
container.
(
reference
15,
section
5.9.12;
reference
42,
module
II,
section
II.
C.
3.
a;
reference
42,
attachment
B,
sections
B­
1c
and
B­
3c;
reference
45,
section
2.6.1;
reference
8,
appendix
WCL)
­
24
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
24
Compliance:
Radiography
(
INST­
OI­
12,
Real
Time
Radiography
Operations)
and
VE
(
INST­
OI­
16,
Drum
Coring
Operations,
and
INST­
OI­
34,
VE
Operating
Procedures
and
Data
Reporting)
are
used
to
detect
the
presence
of
liquids
in
payload
containers.
Residual
liquid
in
well­
drained
bottles,
cans
or
similar
rigid
containers
is
restricted
to
less
than
1
in
(
2.5cm)
of
liquid
per
container
as
estimated
during
the
examination
process.
When
the
sum
of
all
liquids
exceeds
one
percent
of
the
payload
container
volume
or
liquids
have
been
identified
in
rigid
containers
above
specified
limits,
the
container
is
segregated
and
sent
to
the
AMWTF
for
future
treatment.
The
WTS
stores
a
description
of
the
location
of
any
liquid
detected
and
an
estimate
of
the
volume.

When
VE
is
used
in
lieu
of
radiography,
the
liquids
identified
will
be
removed
and/
or
absorbed
at
the
AMWTF.
An
independent
verification
(
by
a
second
operator)
is
performed
and
documented
before
closing
the
container.

3.4.2
Sealed
Containers
Acceptance
Criterion.
Payload
containers
shall
be
verified
to
be
free
of
sealed
containers
greater
than
4
liters.
(
reference
42,
attachment
B1,
section
B1­
1a)

Compliance:
Radiography
(
INST­
OI­
12,
Real
Time
Radiography
Operations)
and
VE
(
INST­
OI­
16,
Drum
Coring,
and
INST­
OI­
34,
VE
Operating
Procedures
and
Data
Reporting)
are
used
to
detect
the
presence
of
sealed
containers
greater
than
4L.
Radiography
is
used
to
nondestructively
confirm
the
absence
of
prohibited
items.
Payload
containers
with
sealed
containers
greater
than
4L
will
be
segregated
and
sent
to
the
AMWTF.

When
VE
is
used
in
lieu
of
radiography,
the
VE
operators
remove
and/
or
vent
sealed
containers.
An
independent
verification
(
by
a
second
operator)
is
performed
and
documented
before
closing
the
container.

3.5
Chemical
Properties
3.5.1
Pyrophoric
Materials
Acceptance
Criterion.
Pyrophoric
radioactive
materials
shall
be
present
only
in
small
residual
amounts
(<
1
percent
by
weight)
in
payload
containers
and
shall
be
generally
dispersed
in
the
waste.
Radioactive
pyrophorics
in
concentrations
>
1
percent
by
weight
and
all
nonradioactive
pyrophorics
shall
be
reacted
(
or
oxidized)
and/
or
otherwise
rendered
nonreactive
prior
to
placement
in
the
payload
container.
Nonradionuclide
pyrophoric
materials
are
not
acceptable
at
WIPP.
(
reference
15,
section
5.9.12;
reference
42,
module
II,
section
II.
C.
3.
b;
reference
45,
section
4.1.1)
­
25
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
25
Compliance:
Nonradionuclide
pyrophoric
material
is
subject
to
the
same
controls
as
explosives
(
e.
g.,
procurement
controls
and
safety
assessments).
In
general,
pyrophoric
materials
are
not
permitted
in
TRU
process
areas.
Processes
that
require
the
use
of
pyrophoric
materials
require
a
safety
analysis
that
is
used
to
determine
the
applicable
controls.
Generator
sites
administrative,
operational
and
QA
procedures
dictate
the
quantity
of
pyrophoric
materials
that
enter
processes,
which
are
limited
and
controlled.
Operating
procedures
require
that
pyrophoric
materials
be
rendered
chemically
safe
by
processing
before
being
placed
in
payload
containers
(
e.
g.,
oxidation
at
high
temperature
in
the
presence
of
oxygen).

No
pyrophoric
materials
or
pyrophoric
radionuclides
exceeding
one
percent
of
the
waste
weight
have
been
identified
in
any
of
the
AK
documentation,
content
code
evaluations,
or
sampling
programs.

3.5.2
Hazardous
Waste
Acceptance
Criterion.
Hazardous
wastes
not
occurring
as
co­
contaminants
with
TRU
wastes
(
non­
mixed
hazardous
wastes)
are
not
acceptable
at
WIPP.
Each
CH­
TRU
mixed
waste
container
shall
be
assigned
one
or
more
EPA
hazardous
waste
codes
as
appropriate.
Only
EPA
hazardous
waste
codes
listed
as
allowable
in
the
Hazardous
Waste
Facility
Permit
may
be
managed
at
WIPP.
Wastes
exhibiting
the
characteristic
of
ignitability,
corrosivity,
or
reactivity
(
EPA
hazardous
waste
numbers
of
D001,
D002,
or
D003)
are
not
acceptable
at
WIPP.
(
reference
42,
module
II,
section
II.
C.
3.
g)
Hazardous
waste
codes
are
synonymous
with
hazardous
waste
numbers.
(
reference
42,
module
II,
sections
II.
C.
3.
c
and
II.
C.
4)

Compliance:
AK
documentation
identifies
physical
and
chemical
properties
of
the
waste
that
is
confirmed
by
radiography
(
INST­
OI­
12,
Real
Time
Radiography
Operations),
VE
(
INST­
OI­
16,
Drum
Coring
Operations
and
INST­
OI­
34,
VE
Operating
Procedure
and
Data
Reporting),
headspace
gas
sampling
(
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sampling),
and
homogeneous
waste
sampling
and
analysis
(
INST­
OI­
16,
Drum
Coring
Operations,
Analytical
Chemistry
Methods
Manual
(
ACMM)­
2900,
Determination
of
Trace
Elements
by
ICP
Atomic
Emission
Spectrometry,
ACMM­
7802,
Determination
of
Mercury
by
Cold­
Vapor
Fluorscence
Spectrophotometry,
ACMM­
8909,
Microwave
Assisted
Digestion
of
Homogeneous
Solids
and
Soil/
Gravel,
ACMM­
9260,
Volatile
Organic
Compounds
by
Gas
Chromatography/
Mass
Spectrometry
(
GC/
MS),
ACMM­
9270,
Semivolatile
Organic
Compounds
by
Gas
Chromatography/
Mass
Spectrometry,
ACMM­
9441,
Determination
of
Nonhalogenated
Volatile
Organic
Compounds
by
Gas
Chromatography,
and
ACMM
Method
9500,
Sample
Preparation
for
Semivolatile
Organic
Compounds
and
Polychlorinated
Biphenyls)
per
the
AMWTP
QAPjP,
provides
the
basis
for
EPA
hazardous
waste
code
assignment.
Each
Waste
Stream
Profile
Form
(
WSPF)
documents
the
applicable
hazardous
waste
codes
for
each
payload
container
in
that
waste
stream.
EPA
hazardous
waste
codes
are
reported
in
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer.
­
26
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
26
3.5.3
Chemical
Compatibility
Acceptance
Criterion.
TRU
waste
containing
incompatible
materials
or
materials
incompatible
with
payload
container
and
packaging
materials,
shipping
container
materials,
other
wastes,
repository
backfill,
or
seal
and
panel
closure
materials
are
not
acceptable
for
transport
in
the
TRUPACT­
II
and
disposal
at
the
WIPP.
Chemical
constituents
shall
conform
to
the
lists
of
allowable
materials
in
tables
4­
1
through
4­
8
of
the
TRAMPAC.
Other
chemicals
or
materials
not
identified
in
these
tables
are
allowed
provided
that
they
meet
the
requirements
for
trace
constituents
as
specified
in
section
4.3
of
the
TRAMPAC.
(
reference
42,
module
II,
section
II.
C.
3.
d;
reference
45,
sections
4.3
and
4.4)

Compliance:
Chemical
compatibility
studies
of
the
waste
and
the
packaging
ensure
that
the
chemical
processes
do
not
threaten
the
safe
transport
of
the
TRUPACT­
II.
Only
waste
listed
in
the
TRUPACT­
II
Content
Codes
(
TRUCON),
DOE/
WIPP
89­
004,
will
be
shipped
in
the
TRUPACT­
II.
Potential
chemical
incompatibilities
were
evaluated
by
the
NRC
for
each
content
code,
between
one
content
code
and
another
and
between
each
content
code
and
the
TRUPACT­
II
inner
containment
vessel
(
ICV)
and
the
oring
seals.
Waste
generated
by
new
processes,
or
an
existing
process
that
has
changed,
will
be
evaluated
by
the
WIPP
TRUPACT­
II
Cognizant
Engineer
to
ensure
that
compliance
with
the
transportation
requirements
of
the
TRAMPAC
can
be
demonstrated.
New
or
revised
TRUCON
codes
will
not
be
shipped
without
written
notification
indicating
approval
by
the
WIPP
TRUPACT­
II
Cognizant
Engineer.
Waste
compatibilities
with
backfill,
seal,
and
panel
closure
materials
are
verified
through
the
use
of
approved
TRUCON
codes.

All
payload
containers
selected
for
shipment
to
WIPP
are
evaluated
in
accordance
with
management
procedure
,
MP­
TRUW­
8.5,
TRU
Waste
Certification,
and
the
e­
TRAMPAC
software
to
ensure
that
waste
that
is
shipped
belongs
to
an
approved
TRUCON
Content
Code.

3.5.4
Explosives,
Corrosives,
and
Compressed
Gases
Acceptance
Criterion.
Waste
shall
contain
no
explosives,
corrosives,
or
compressed
gases
(
pressurized
containers).
(
reference
15,
section
5.9.12;
reference
42,
module
II,
section
II.
C.
3.
g;
reference
45,
section
4.2.1)

Compliance:
Most
generator
sites
did
not
allow
explosives
in
the
same
facility
as
TRU
waste.
Waste
generating
processes
were
assessed
for
safety
hazards
such
as
potential
explosive
hazards
and
potential
inadvertent
production
of
explosive
materials.
Corrosive
liquids
were
neutralized
or
absorbed
by
the
generator
sites
before
being
shipped
to
the
INEEL.
Content
code
assessments
have
been
performed
to
ensure
liquids
have
been
adequately
neutralized.

AK
documentation
identifies
physical
and
chemical
properties
of
the
waste
that
is
confirmed
by
radiography
(
INST­
OI­
12,
Real
Time
Radiography
Operations),
VE
(
INST­
OI­
16,
Drum
Coring
Operations,
and
INST­
OI­
34,
VE
Operating
Procedure
and
Data
Reporting),(
for
liquids,
pressurized
containers,
and
compressed
gases),
and
continuing
intrusive
characterization
per
the
AMWTP
QAPjP
confirm
the
absence
of
corrosives
and
explosives.
­
27
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
27
Payload
containers
that
are
suspected
to
contain
explosives
or
compressed
gases
will
be
segregated
and
sent
to
the
AMWTF
for
corrective
action.

3.5.5
Headspace
Gas
Concentrations
Acceptance
Criterion.
The
headspace
gas
of
payload
containers
shall
be
sampled
and
analyzed
in
accordance
with
an
approved
site­
specific
QAPjP,
as
defined
in
the
WIPP
WAP,
to
determine
volatile
organic
compound
(
VOC)
concentrations.
(
reference
42,
module
II,
section
II.
C.
3.
I)

Flammable
VOCs
are
restricted
to
<
500
ppm
in
the
payload
container
headspace.
For
those
payload
containers
that
exceed
the
flammable
VOC
limit,
a
determination
of
compliance
with
the
unified
flammable
(
gas/
VOC)
concentration
limit
as
described
in
the
TRAMPAC
allows
the
payload
container
to
be
shipped
in
the
TRUPACT­
II
under
a
test
category.
(
reference
45,
section
5.2
and
appendix
5.7)
Test
category
payload
containers
shall
be
tested
to
quantify
the
hydrogen/
methane,
VOC,
and
total
gas
generation
rates
(
as
appropriate)
for
purposes
of
determining
if
all
applicable
limits
are
met.
(
reference
45,
section
5.2,
appendix
1.2
and
5.7)

Compliance:
All
payload
containers
selected
for
shipment
to
WIPP
will
undergo
headspace
gas
sampling
in
accordance
with
work
instruction,
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sampling,
to
determine
volatile
organic
compound
(
VOC)
concentrations
and
demonstrate
the
total
flammable
VOC
concentrations
are
<
500
ppm.

When
payload
containers
exceed
the
analytical
decay
heat
limit
and
the
concentration
of
flammable
VOCs
exceeds
500
ppm,
the
container
belongs
to
the
test
category.
Full
drum
testing
in
accordance
with
work
instruction,
INST­
OI­
18,
Gas
Generation
Testing
Operations,
and/
or
e­
TRAMPAC
evaluation
is
performed
to
verify
that
all
applicable
limits
are
met.

3.5.6
Polychlorinated
Biphenyl
Concentration
Acceptance
Criterion.
Waste
shall
contain
no
polychlorinated
biphenyl
(
PCB)
concentrations
equal
to
or
greater
than
50
parts
per
million
(
ppm).
(
reference
42,
module
II,
section
II.
C.
3.
f)

Compliance:
AK
documentation
verified
by
homogeneous
waste
sampling
and
analysis
(
for
organic
sludge
forms
suspected
of
containing
PCBs)
in
accordance
with
work
instruction,
INST­
OI­
16,
Drum
Coring
,
ACMM
Method
9080,
Determination
of
Polychorinated
Biphenyls
by
Gas
Chromatography,
and
ACMM
Method
9500,
Sample
Preparation
for
Semivolatile
Organic
Compounds
and
Polychorinated
Biphenyls,
are
used
to
confirm
that
payload
containers
contain
less
than
50
ppm
PCBs.
­
28
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
28
Radiography
(
INST­
OI­
12,
Real
Time
Radiography
Operations)
or
VE
(
INST­
OI­
16,
Drum
Coring
Operations
or
INST­
OI­
34,
VE
Operating
Procedure
and
Data
Reporting)
is
used
to
confirm
the
absence
of
prohibited
waste
items.
If
there
is
any
reason
to
suspect
that
an
item
(
i.
e.,
ballasts,
transformers)
may
contain
PCBs,
the
item
will
be
identified
as
such
and
the
payload
container
segregated
and
sent
to
AMWTF
until
the
correct
disposition
can
be
ascertained.

3.6
Data
Package
Contents
3.6.1
Characterization
and
Certification
Data
Acceptance
Criterion.
Sites
shall
prepare
a
WSPF
for
each
waste
stream.
Each
WSPF
shall
be
approved
by
the
CBFO
prior
to
the
first
shipment
of
that
waste
stream.
Characterization
and
certification
information
for
each
payload
container
shall
be
submitted
to
the
WWIS
and
approved
by
the
Data
Administrator.
Sites
are
required
to
estimate
the
CPR
weights
and
report
these
estimates
in
the
WWIS
on
a
payload
container
basis.
Any
payload
container
from
a
waste
stream
that
has
not
been
preceded
by
an
appropriate
certified
WSPF
is
not
acceptable
at
WIPP.
(
reference
42,
attachment
B,
section
B­
4b[
2])

Compliance:
The
SPM
or
designated
alternate
prepares
and
approves
the
WSPF
and
Data
Summary
Reports
in
accordance
with
management
procedure,
MP­
TRUW­
8.14,
Preparation
of
Waste
Stream
Profile
Forms.
A
hard
copy
of
the
WSPF
and
Data
Summary
Report
are
then
transmitted
to
WIPP
for
approval.
This
transmittal
is
coordinated
with
the
initial
characterization
data
transfer
to
the
WWIS
in
accordance
with
management
procedure,
MP­
TRUW­
8.16,
WWIS
Data
Transfer,
for
the
Data
Administrator
review
and
approval.
Payload
containers
from
a
waste
stream
that
does
not
have
an
approved
WSPF,
will
not
be
certified
and
shipped.

3.6.2
Shipping
Data
Acceptance
Criterion.
Sites
shall
prepare
either
a
bill
of
lading
or
a
uniform
hazardous
waste
manifest
for
CH­
TRU
waste
shipments
as
required
by
the
transportation
requirements.
The
land
disposal
restriction
notification
for
CH­
TRU
mixed
waste
shipments
shall
state
that
the
waste
is
not
prohibited
from
land
disposal.
For
shipment
in
TRUPACT­
II,
the
following
documents
shall
be
prepared
for
containers
and
assemblies,
as
appropriate:
payload
container
transportation
certification
document
(
PCTCD);
overpack
payload
container
transportation
certification
document
(
OPCTCD);
and
payload
assembly
transportation
certification
document
(
PATCD).
(
reference
42,
attachment
B,
section
B­
4b(
2);
reference
45,
section
6,
appendices
6.1
and
6.2)

Compliance:
The
Transportation
Certification
Official
(
TCO)
will
review
and
sign,
as
appropriate,
the
PCTCD,
OPCTCD,
and
PATCD
generated
by
the
WTS
or
WWIS.
The
TCO
verifies
that
all
requirements
for
the
transportation
parameters
have
been
met
and
completion
of
the
signature
authorizes
payload
containers
for
shipment
in
the
TRUPACT­
II
in
accordance
with
management
procedure,
MPTRUW
8.5,
TRU
Waste
Certification.
­
29
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
29
The
AMWTP
will
coordinate
the
preparation
of
either
a
bill
of
lading
or
a
uniform
hazardous
waste
manifest
for
each
CH­
TRU
waste
shipment
in
accordance
with
management
procedure,
MP­
TRUW­
8.12,
Waste
Receipt
and
Shipping
Inspection.
The
land
disposal
restriction
notification
for
CH­
TRU
mixed
waste
shipments
that
the
waste
is
prohibited
from
land
disposal.
­
30
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
30
4.0
QUALITY
ASSURANCE
REQUIREMENTS
Quality
assurance
is
an
integral
part
of
TRU
waste
characterization,
certification,
transportation,
and
operation
activities.
This
section
defines
the
QA
program
requirements
that
assure
TRU
waste
characterization,
certification,
and
transportation
activities
are
performed
satisfactorily.
The
QA
requirements
applicable
to
WIPP
are
addressed
in
the
QAPD
(
reference
7).

The
AMWTP
is
responsible
for
developing,
documenting,
and
implementing
a
site­
specific
QA
plan
that
address
the
elements
of
the
QAPD
that
govern
TRU
waste
characterization,
certification,
and
transportation
activities.
This
section
defines
the
QA
program
requirements
for
TRU
waste
characterization,
certification,
and
transportation
activities
performed
by
the
AMWTP.
This
Certification
Plan
will
be
submitted
to
the
CBFO
for
approval
before
TRU
wastes
are
characterized,
certified,
or
shipped
to
WIPP.
The
CBFO
and
AMWTP
will
conduct
audits
and
surveillances
to
ensure
compliance
with
this
plan.
When
the
QAPD
is
revised,
AMWTP
QA
plan,
procedures,
and
activities
will
be
evaluated
for
changes
to
requirements,
and
revisions
will
be
initiated
and
implemented,
as
appropriate.

4.1
Waste
Characterization
QA
Requirements
The
Quality
Assurance
Project
Plan
(
QAPjP),
MP­
TRUW­
8.2,
documents
the
QA
and
quality
control
(
QC)
activities
applicable
to
TRU
characterization.
Analytical
laboratories
analyzing
WIPP
waste
characterization
samples
for
the
AMWTP
have
established,
documented
QA/
QC
programs.

Data
quality
objectives
are
qualitative
and
quantitative
statements
that
specify
WIPP
program
technical
and
quality
objectives;
they
are
determined
through
the
data
quality
objective
process
(
reference
25).
The
data
quality
objectives
for
waste
characterization
activities
relating
to
physical
and
chemical
properties
of
the
waste
are
contained
in
the
WAP
of
the
WIPP
Hazardous
Waste
Facility
Permit
(
reference
42,
attachment
B3).
The
radioassay
data
quality
objectives
are
given
in
appendix
A
of
this
document.

Payload
containers
with
unresolved
discrepancies
associated
with
hazardous
waste
characterization
will
not
be
managed
or
disposed
of
at
WIPP
until
discrepancies
are
resolved
(
reference
42,
attachment
B4,
section
B4­
4).
Corrective
action
reports
applicable
to
WIPP
WAP
requirements
shall
be
resolved
prior
to
waste
shipment
(
reference
42,
attachment
B6,
section
B6­
4).

4.2
Waste
Certification
QA
Requirements
The
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste,
MP­
TRUW­
8.1,
describes
the
QA
and
QC
activities
applicable
to
certification
of
TRU
waste
to
the
CH­
WAC
that
comply
with
the
requirements
of
the
QAPD
(
reference
7).

The
TRU
Waste
Program
Procedures
Matrix
for
the
DOE­
CBFO­
QAPD,
MP
TRUW­
04­
IM,
identifies
applicable
documents
for
each
organization
or
project
that
implement
each
applicable
requirement
of
the
QAPD.
The
matrix
pertains
to
all
AMWTP
waste
characterization,
certification,
and
transportation
activities.
This
matrix
will
be
updated
as
implementation
procedures
are
revised.
­
31
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
31
4.3
Waste
Transportation
QA
Requirements
Quality
assurance
requirements
for
the
transportation
of
TRU
waste
involve
two
elements:
compliance
with
TRUPACT­
II
payload
control
requirements
and
compliance
with
TRUPACT­
II
usage
requirements.
The
QA
requirements
for
payload
control
compliance
derived
from
the
certificate
of
compliance
for
the
TRUPACT­
II
issued
by
the
NRC
(
reference
43).
The
certificate
of
compliance
references
the
TRAMPAC
(
reference
45).
The
QA
requirements
for
compliance
with
TRUPACT­
II
usage
requirements
are
derived
from
10
CFR
Part
71,
49
CFR,
Part
173
(
references
28
and
36),
the
TRUPACT­
II
certificate
of
compliance
(
reference
43),
DOE
Orders
460.1
and
460.2
(
references
5
and
6),
and
the
CH
Packaging
Program
Guidance
(
reference
17).

The
TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
TRAMPAC),
MP­
TRUW­
8.3,
describes
the
QA
and
QC
activities
applicable
to
the
specific
parameters
of
the
transportation
packaging
methods
for
payload
control
and
the
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste,
MP­
TRUW­
8.1,
describes
the
QA
and
QC
activities
applicable
to
the
usage
of
the
TRUPACT­
II.
These
documents
control
the
used
of
the
NRC­
certified
packaging
(
TRUPACT­
II)
and
comply
with
the
CH
Packaging
Program
Guidance
(
reference
17).

4.4
Quality
Assurance
Program
The
AMWTP
Quality
Assurance
Program
(
QAP)
is
based
on
the
QAPD
(
reference
7)
elements
outlined
below.
Table
4.0.1
provides
a
cross­
reference
of
identical
or
related
QA
requirement
elements
from
10
CFR
830
Subpart
A
(
reference
30)
and
10
CFR
71
(
reference
29).

 
Organization
and
QA
Program
(
QAP)
documents
the
organizational
structure,
primary
interfaces,
functional
responsibilities,
levels
of
authority,
and
lines
of
communication
for
activities
affecting
quality,
and
identifies
the
activities
and
items
to
which
the
QA
program
applies.

 
Personnel
Qualification
and
Training
identifies
the
AMWTP
qualification
and
training
programs
and
plans
established
to
ensure
personnel
are
provided
training
to
perform
their
assignments
and
maintain
job
proficiency.

 
Quality
Improvement
describes
the
processes
to
detect
and
prevent
conditions
adverse
to
quality,
pursue
continuous
quality
improvement,
and
control
and
correct
nonconforming
items.

 
Documents
and
Records
describes
the
processes
for
preparation,
review,
approval,
issue,
use,
revision,
and
control
of
the
AMWTP
documents
and
records.

 
Work
Processes
identifies
the
processes
by
which
work
conditions,
equipment,
and
special
processes
are
controlled
to
ensure
quality.

 
Procurement
identifies
the
technical
and
QA
requirements
for
procured
items
and
services.

 
Inspection
and
Testing
identifies
the
processes
for
inspection
and
testing.
­
32
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
32
 
Assessment
Requirements
describes
the
requirements
for
conducting
management
and
independent
assessments
to
measure
management
effectiveness,
item
quality,
and
process
effectiveness
and
to
promote
improvement.

 
Sample
Control
Requirements
identifies
the
requirements
for
the
control
of
waste
samples,
including
identification,
handling,
storing,
shipping,
and
archiving.

 
Scientific
Investigation
Requirements
describes
the
requirements
for
defining,
controlling,
verifying,
and
documenting
scientific
investigations.

 
Software
Requirements
specifies
the
requirements
for
developing,
procuring,
maintaining,
and
using
software.

Table
4.0.1.
Quality
assurance
requirements
cross­
reference
table.

QAPD
and
Certification
Plan
Section
Equivalent
Section
in
10
CFR
830.
Subpart
A,
Nuclear
Safety
Management
Equivalent
Section
in
10
CFR
Part
71,
Subpart
H,
Quality
Assurance
Organization
and
QA
Program
Program
QA
Organization
QA
Program
Personnel
Qualification
and
Training
Personnel
Training
and
Qualification
QA
Program
Quality
Improvement
Quality
Improvement
Corrective
Action
Nonconforming
Materials,
Parts,
or
Components
Documents
Records
Documents
and
Records
Document
Control
QA
Records
Work
Processes
Work
Processes
Instructions,
Procedures,
and
Drawings
Identification
and
Control
of
Materials,
Parts,
and
Components
Control
of
Special
Processes
Procurement
Procurement
Procurement
Document
Control
Control
of
Purchased
Material,
Equipment,
and
Services
Inspection
and
Testing
Work
Process
and
Acceptance
Testing
Internal
Inspection
Test
Control
Control
of
Measuring
and
Test
Equipment
­
33
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
33
QAPD
and
Certification
Plan
Section
Equivalent
Section
in
10
CFR
830.
Subpart
A,
Nuclear
Safety
Management
Equivalent
Section
in
10
CFR
Part
71,
Subpart
H,
Quality
Assurance
Inspection,
Test,
and
Operating
Status
Handling,
Storage,
and
Shipping
Assessment
Requirements
Management
Assessment
Independent
Assessment
Audits
Sample
Control
Requirements
Work
Processes
Not
applicable
Scientific
Investigation
Requirements
Not
applicable
Not
applicable
Software
Requirements
Not
applicable
Not
applicable
4.4.1
AMWTP
TRU
Program
Organization
The
TRU
Program
organization
is
part
of
the
overall
AMWTP
organization
as
defined
in
MP­
ADMN­
1.19,
AMWTP
Organization
Charts.
This
section
describes
the
principal
organizations
involved,
the
project
level
positions,
and
their
primary
responsibilities.
Data
generation
organizations
also
support
the
AMWTP.
The
central
organizational
structure
is
depicted
in
Figure
4.1.

AMWTP
General
Manager
has
overall
responsibility
for
all
aspects
of
the
AMTWP,
which
includes
permitting,
designs
to
construction,
commissioning,
operations,
waste
certification,
packaging,
and
transportation.

AMWTP
Operations
Manager
is
responsible
for
the
safe,
efficient
production
of
acceptable
waste
packaged
for
disposal
at
WIPP.
Provides
commissioning
and
operations
planning
and
strategies.
Ensures
planning
and
execution
of
the
WIPP
certification
program.
Reports
to
the
AMWTP
General
Manager.

TRU
Waste
Program
Manager
is
responsible
for
the
planning,
execution,
implementation,
and
coordination
of
activities
associated
with
the
characterization,
certification,
packaging
and
transportation
of
waste
for
disposal
in
the
WIPP,
and
ensures
compliance
with
applicable
requirements.
Reports
to
the
Operations
Manager.

BNFL
Inc.
Corporate
Quality
Assurance
Manager,
is
responsible
for
providing
qualified
quality
professionals
to
the
AMWTP.
The
Corporate
QA
Manager
provides
professional
training
and,
where
applicable,
certified
individuals
to
perform
QA­
related
activities.

AMWTP
Quality
Assurance
Manager.
ensures
development
of
the
QA
program
and
provides
QA
oversight
of
work
performed
by
BNFL
Inc.
and
subcontractors
in
accordance
with
the
plan
requirements.
Reports
to
the
General
Manager
and
independently
to
the
BNFL
Inc.
Corporate
QA
Manager.
­
34
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
34
Site
Project
Manager
(
SPM)
has
overall
responsibility
for
ensuring
that
CH­
TRU
is
successfully
characterized
in
accordance
with
the
WIPP­
WAP.
The
SPM
(
or
designated
alternates)
responsibilities
include:

 
Ensuring
that
adequate
technical
and
QA
training
is
provided
for
personnel
performing
activities
subject
to
the
DOE/
CBFO
QAPD.

 
Reviewing
and
recommending
approval
of
the
QAPjP
and
subsequent
revisions
before
it
is
submitted
to
CBFO
for
approval
 
Waste
selection
and
tracking
 
Data
validation/
verification
 
Data
reconciliation
with
data
quality
objectives
(
DQOs)

 
Assignment
of
EPA
Hazardous
Waste
Numbers
 
Preparing
of
the
Waste
Stream
Characterization
Package
 
QA/
QC
reports
to
the
CBFO
 
Characterization
data
transmittal
to
CBFO.

Site
Quality
Assurance
Officer
(
or
designated
alternate)
reports
to
the
AMWTP
QA
Manager
and
is
responsible
for
developing,
documenting,
and
monitoring
the
implementation
of
QA
documentation
specific
to
the
characterization,
certification,
and
transportation
activities.
These
responsibilities
include,
but
are
not
limited
to:

 
Reviewing
the
AMWTP
QAPjP
and
subsequent
revisions
 
Day
to
day
guidance
to
the
project
staff
on
quality­
related
matters
 
Scheduling
and
conducting
QA
assessments
 
Nonconformance
tracking
and
corrective
action
verification
 
Data
validation/
verification
 
Data
QA
documentation
verification
 
Tracking
and
performing
trend
analysis
of
quality
problems,
and
reporting
quality
problem
areas
 
Preparing
QA/
QC
reports
to
Site
Project
Manager.
­
35
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
35
 
Maintaining
liaison
with
participant
QA
organizations
and
other
affected
organizations
 
 
Ensuring
preparation,
review,
and
issuance
of
QA
plans
and
procedures
that
implement
the
provisions
of
the
DOE/
CAO
QAPD
The
SQAO
has
the
authority,
access
to
work,
and
organizational
freedom
to
identify
quality
problems,
make
recommendations
for
resolution,
and
verify
implementation
of
corrective
actions.
In
addition,
the
SQAO
will
ensure
that
unsatisfactory
conditions
are
controlled
until
proper
corrective
actions
have
been
completed.

To
ensure
the
independence
of
this
QA
function,
the
SQAO
is
deployed
from
the
AMWTP
QA
Manager
with
established
lines
of
communication
to
the
SPM.

Waste
Certification
Official
(
WCO),
or
designated
alternate,
is
responsible
for
documenting
and
certifying
that
all
TRU
waste
payload
containers
prepared
for
shipment
to
the
WIPP
meet
all
WAC,
and
for
transmitting
the
waste
certification
data
to
the
WIPP.
The
WCO
is
responsible
for
final
compilation
and
approval
of
CH­
TRU
Waste
Certification
Statements.
The
same
or
different
individuals
may
perform
the
functions
of
the
WCO
and
the
TCO.

Transportation
Certification
Official
(
or
designated
alternate),
is
responsible
for
documenting
and
certifying
the
compliance
of
payload
containers
and
assemblies
with
transportation
requirements.
The
TCO
approves
by
signature
the
transportation
certification
documents
for
every
payload
selected
for
transport.
The
same
or
different
individuals
may
perform
the
functions
of
the
WCO
and
the
TCO.
­
36
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
36
DOE/
CBFO
DOE­
ID
Project
Manager
AMWTP
General
Manager
AMWTP
Operations
Manager
TRU
Program
Manager
AMWTP
Quality
Assurance
Manager
BNFL
Inc.
Corporate
QA
Manager
BNFL
Inc.
Manager
ES&
H/
QA
Waste
Certification
Official
Transportation
Certification
Official
Site
Project
Manager
Site
Quality
Assurance
Officer
Site
Project
Office
Lines
of
Authority:

Lines
of
Communication:

Figure:
4.1
AMWTP
TRU
Program
Organization
Structure
­
37
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
37
4.4.2
AMWTP
QA
Program
Description
This
QAP
applies
to
items
and
activities
affecting
AMWTP
quality.
QA
activities
are
integrated
into
the
AMWTP
through
reviews,
assessments,
inspections,
and
approval
and
control
of
records
and
documents.
The
AMWTP
has
identified
the
SPM,
SQAO,
WCO,
and
TCO
as
being
responsible
for
ensuring
QA
within
the
AMWTP
TRU
Program.
All
personnel
involved
with
TRU
waste
characterization,
certification,
packaging,
and
transportation
ensure
the
quality
of
their
activities
and
products.
If
work
is
delegated,
the
individual
making
the
delegation
retains
responsibility
for
the
delegated
work.
The
SQAO
and
the
cognizant
AMWTP
personnel
will
resolve
disputes
related
to
QAP
requirements.

AMWTP
TRU
Program
personnel
plan
certification
activities
and
document
this
process.
Planning
documentation
is
subject
to
review
by
TRU
Program
management
and
subject
matter
experts
(
SMEs).
Project
planning
documentation
consists
of
the
documents
discussed
in
this
section,
implementing
procedures,
and
training
plans.
These
documents
establish
performance
criteria
and
methods
to
measure
performance
relevant
to
the
AMWTP.
All
Site
Project
Office
(
SPO)
personnel
are
accountable
for
ensuring
quality
within
their
assigned
areas
of
responsibility;
however,
the
SQAO
is
responsible
for
determining
the
effectiveness
of
this
QAP,
which
is
accomplished
through
internal
reporting
procedures,
assessments,
and
surveillance's
performed
in
accordance
with
MP­
M&
IA­
17.1,
Management
Assessments,
MP­
M&
IA­
17.2,
Independent
Assessments,
and
MP­
M&
IA­
17.3,
Surveillances,
respectively.

AMWTP
management
at
all
levels
has
established
communication
channels
that
provide
timely
and
wide
dissemination
of
information
related
to
performance,
which
includes:

 
QA
program
status
 
Lessons
learned
 
Quality
improvement
 
Results
of
trend
analysis
­
38
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4.4.3
Implementation
of
the
CBFO
QA
Program
The
provisions
of
the
AMWTP
QAP
are
implemented
through
the
use
of
numerous
program
documents
and
procedures.
The
relationships
between
the
various
external
requirements
sources
and
AMWTP
programmatic
and
implementing
documents
are
depicted
in
Figure
4.2,
AMWTP
document
hierarchy.
Implementing
procedures
are
listed
within
sub­
tier
program
plans,
matrices,
or
other
documents.
Documents,
which
collectively
define
these
activities,
are
presented
below:

NRC
TRUPACT­
II
CERTIFICATE
OF
COMPLIANCE1
NMED
WIPP
HAZARDOUS
WASTE
FACILITY
PERMIT1
DOE/
CBFO
WIPP
CH
SAFETY
ANALYSIS
REPORT
(
FEIS,
SEIS
I,
SEIS
II)
EPA
WIPP
COMPLIANCE
CERTIFICATION
DECISION
CONGRESS
WIPP
LAND
WITHDRAWAL
ACT
WIPP
CH­
TRU
WASTE
ACCEPTANCE
CRITERIA
AMWTP
TRAMPAC2
MP­
TRUW­
8.3
AMWTP
QUALITY
ASSURANCE
PROJECT
PLAN2
MP­
TRU­
8.2
AMWTP
CERTIFICATION
PLAN2
MP­
TRU­
8.1
AMWTP
TRU
WASTE
PROGRAM
PROCEDURES
MATRIX
FOR
DOE­
CBFO­
QAPD
MP­
TRUW­
04­
IM
(
REQUIREMENTS)

(
CRITERIA)
WIPP
QUALITY
ASSURANCE
PROGRAM
DOCUMENT
IMPLEMENTING
PROCEDURES
Figure
4.2
AMWTP
TRU
Program
document
hierarchy.
­
39
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4.4.4
Graded
Approach
Implementation
of
the
AMWTP
QAP
is
based
on
the
application
of
the
graded
approach.
The
levels
of
analysis,
documentation,
verification,
and
other
controls
are
applied
commensurate
with
an
item's
risk
and
importance.
The
AMWTP
graded
approach
process
is
implemented
in
accordance
with,
Graded
Approach,
MP­
Q&
SI­
5.6.
The
AMWTP
QA
Manager
is
responsible
for
review
and
concurrence
with
quality
level
designations
for
the
AMWTP
Systems,
Structures,
and
Components.
MP­
Q&
SI­
5.6,
Graded
Approach,
is
submitted
to
the
CBFO
QA
Manager
for
approval
for
use
in
the
AMWTP.

4.5
Personnel
Qualification
And
Training
Personnel
performing
AMWTP
TRU
Program
activities
affecting
quality
receive
QA
indoctrination
and
are
qualified
and
trained
to
ensure
that
suitable
proficiency
is
achieved
and
maintained
in
the
performance
of
their
assigned
tasks
4.5.1
Qualification
The
appropriate
managers,
with
support
of
the
training
organization,
determine
job
positions
and
qualification
standards
for
each
job
category
relevant
to
the
AMWTP.
Task
responsibilities
for
personnel
are
analyzed
to
ensure
education,
experience,
and
training
prerequisites
is
commensurate
with
minimum
requirements
specified
in
accordance
with
Job
and
Training
Needs
Analysis,
MP­
RTQP­
14.6
4.5.2
Training
The
appropriate
managers
ensure
that
all
applicable
AMWTP
personnel
receive
indoctrination
and
training
on
the
scope,
purpose,
and
objectives
of
the
TRU
Program
and
the
specific
Quality
Assurance
Objectives
(
QAOs)
of
the
tasks
being
performed.
Personnel
performing
activities
affecting
quality
are
trained
according
to
their
respective
training
plans
to
ensure
they
achieve
and
maintain
proficiency
prior
to
performing
any
tasks
subject
to
these
QAP
requirements.
Personnel
receive
initial
and
continuing
training
requisite
with
their
activities
and
level
of
responsibility
in
accordance
with
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification,
and
MP­
RTQP­
14.20,
Training
Implementation
Matrix.
Training
is
designed,
developed,
conducted,
and
evaluated
in
accordance
with
MP­
RTQP­
14.1,
Preparation
and
Administration
of
Individual
Training
Plans..
Training
programs
may
include
classroom
instruction,
practical
hands­
on
experience,
supervised
on­
the­
job
training,
self­
paced
individual
study,
and
written,
oral,
or
practical
demonstration
of
worker
competence.
The
period
of
effectiveness
for
qualification
associated
with
special
processes,
operations
that
require
special
skills,
and
the
requalification
criteria
are
specified
or
referenced
Personnel
Qualification
and
Certification,
MP­
RTQP­
14.4
or
supporting
training
program
plans.
­
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Nondestructive
examination
(
NDE)
and
Nondestructive
assay
(
NDA)
is
considered
to
be
a
characterization
process,
therefore,
personnel
performing
NDE
are
qualified
to
a
program
based
on
the
American
Society
of
Nondestructive
Testing
(
ASNT)
Recommended
Practice
No.
SNT­
TC­
1A
and
personnel
performing
NDA
are
qualified
to
ASTM
C1490,
Standard
Guide
for
selection,
training
and
qualification
of
NDA
personnel.
Personnel
performing
helium
leak
testing
of
the
TRUPACT­
II
are
qualified
in
accordance
with
ASNT
SNT­
TC­
1A
and
its
applicable
supplements.

Training
is
subject
to
ongoing
review
to
determine
instruction
and
training
program
effectiveness
and
shall
be
upgraded
whenever
improvements
or
enhancements
are
identified
in
accordance
with
Preparation
and
Administration
of
Individual
Training
Plans,
MP­
RTQP­
14.1.

Personnel
performing
TRU
Program
activities
affecting
quality
receive
indoctrination
in
the
following:

 
General
criteria,
this
QAP,
and
applicable
codes,
regulations,
and
standards
 
Specific
criteria,
including
the
QAPjP,
Certification
Plan,
TRAMPAC,
and
the
applicable
implementing
procedures.

Auditable
records
documenting
the
required
training
and
qualifications
are
maintained
as
QA
records
and
controlled
in
accordance
with
MP­
RTQP­
14.19,
Training
Records
Administration.

4.6
Quality
Improvement
AMWTP
personnel
continually
evaluate
and
improve
project
activities.
Personnel
are
responsible
for
identifying
nonconforming
items
and
processes
that
do
not
meet
established
requirements
are
identified,
controlled,
and
corrected
in
accordance
with
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions
and
MP­
Q&
SI­
5.3,
Corrective
Action.

4.6.1
Conditions
Adverse
To
Quality
A
condition
adverse
to
quality
is
an
all­
inclusive
term
used
in
reference
to
failures,
malfunctions,
deficiencies,
and
nonconforming
items,
materials,
parts,
components,
data,
and
processes.
Significant
conditions
adverse
to
quality
are
those
that,
if
uncorrected,
could
have
a
serious
effect
on
safety,
operability,
waste
isolation,
TRU
waste
site
certification
and
shipment,
regulatory
compliance
demonstration,
or
effective
implementation
of
the
QA
program.

Conditions
adverse
to
quality
are
classified
according
to
their
significance
and
the
corrective
action
developed
accordingly.

The
SQAO
ensures
that
quality
in
the
TRU
Program
by
identifying
and
reporting
conditions
adverse
to
quality,
analyzing
trends,
reporting
and
tracking
nonconformances,
and
implementing
corrective
actions
in
accordance
with
MP­
Q&
SI­
5.1,
Investigations
and
Root
Cause
Analysis.
These
quality
improvement
activities
detect
and
prevent
unacceptable
quality
problems
and
thereby
increasing
accuracy
and
reliability,
and
reducing
variability.
­
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4.6.2
Controlling
Conditions
Adverse
To
Quality
Conditions
adverse
to
quality
are
investigated
and
documented,
including
the
extent
of
the
condition
and
the
impact
on
completed
work.
As
appropriate,
corrective
action
plans
are
developed,
documented
and
implemented
as
soon
as
practicable.

The
SQAO
notifies
CBFO
of
all
conditions
adverse
to
quality
affecting
waste
to
be
shipped
to
WIPP
and
forwards
all
reports
upon
issuance
and
again
upon
closure
related
to
violations
of
the
WAP
(
reference
42,
Attachment
B)
to
CBFO
for
tracking.
All
deficiencies
are
evaluated
for
Price­
Anderson
Amendments
Act
applicability
and
reporting
and
require
verification
of
completion
of
assigned
action
items
prior
to
closure.

All
violations
of
the
WAP
must
be
managed
as
a
significant
condition
adverse
to
quality.
Significant
conditions
adverse
to
quality
are
reported
and
evaluated
by
the
AMWTP
QA
Manager,
other
relevant
regulatory
compliance
organizations
(
e.
g.,
environmental
and
safety),
and
the
responsible
management,
to
determine
if
a
work
suspension
is
necessary.
If
a
work
suspension
is
warranted,
the
SQAO,
the
AMWTP
QA
Manager,
or
the
BNFL
Inc.
Corporate
QA
Manager
verifies
and
documents
the
completion
of
applicable
corrective
actions
prior
to
any
management
action
releasing
the
work
suspension.
AMWTP
work
suspensions
are
processed
in
accordance
with
Identification
of
Nonconforming
Conditions,
MPQ
SI­
5.4.

The
CBFO
is
notified
of
Corrective
Action
Reports
that
relate
to
violations
of
the
WAP.
Corrective
Action
Plans
relating
to
these
violations
of
the
WAP
and
all
DOE/
CBFO
issued
Corrective
Action
Reports
(
CARs)
address
corrective
action
planning
and
follow­
up
for
significant
conditions
adverse
to
quality.
Instructions
governing
these
activities
are
detailed
in
procedures
referenced
in
Identification
of
Nonconforming
Conditions,
MP­
Q&
SI­
5.4.

4.6.3
Nonconforming
Items
Management
at
all
levels
fosters
a
"
no­
fault"
attitude
to
encourage
the
identification
of
nonconforming
items
and
processes.
Nonconformances
are
uncontrolled
and
unapproved
deviations
from
an
approved
plan
or
procedure.
Nonconforming
items
are
those
that
do
not
meet
the
AMWTP
requirements,
procurement
document
criteria,
or
approved
work
procedures.
All
AMWTP
personnel
are
responsible
for
promptly
reporting
any
nonconformance
condition
identified
as
adverse
to
quality
to
management.

The
AMWTP
identifies
and
documents
nonconformances.
The
nonconformance
process
is
controlled
in
accordance
with
Identification
of
Nonconforming
Conditions,
MP­
Q&
SI­
5.4.
This
procedure
describes
AMWTP­
specific
nonconformance
procedures
and
communication
with
WIPP
concerning
nonconformance
tracking
and
resolution.
It
also
describes
the
methods
to
identify,
control,
and
dispose
of
nonconforming
items
(
nonconforming
items
are
identified
by
marking,
tagging,
or
segregating
the
items).

Identification
of
Nonconforming
Conditions,
MP­
Q&
SI­
5.4
is
used
for
nonconformances
identified
during
data
generation
level
and
project
level
data
review.
AMWTP
nonconformance
reports
(
NCRs)
are
processed
electronically
and/
or
tracked
in
hard
copy.
­
42
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An
NCR
is
prepared
for
each
nonconformance
identified,
including
or
referencing,
as
appropriate,
results
of
laboratory
analysis,
QC
tests,
audit
reports,
internal
memoranda,
or
letters.
The
NCR
provides
the
following
information:

 
Identification
of
the
individual(
s)
identifying
or
originating
the
nonconformance
 
Description
of
the
nonconformance
 
Method(
s)
or
suggestions
for
correcting
the
nonconformance
(
corrective
action)

 
Schedule
for
completing
the
corrective
action
 
An
indication
of
the
potential
ramifications
and
overall
usability
of
the
data,
if
applicable
 
Any
approval
signatures
specified
in
the
site
nonconformance
procedures.

Identification
of
Nonconforming
Conditions,
MP­
Q&
SI­
5.4,
also
assigns
responsibilities
to
AMWTP
organizations
and
personnel
to
identify,
report,
control,
evaluate
the
nonconformances,
obtain
and
document
a
disposition,
determine
cause,
track,
and
define
corrective
action
for
reported
nonconforming
items.
The
SQAO
(
or
designated
alternate)
oversees
the
AMWTP
NCR
process.
The
SPM
and
SQAO
are
notified
when
a
nonconformance
related
to
the
AMWTP
TRU
Program
is
observed
or
detected.
Operations,
SPM
and
SQAO
are
responsible
for
evaluating
nonconformances
and
taking
appropriate
corrective
action.

Documentation
of
nonconformances
is
made
available
to
the
SPM.
CBFO
receives
written
notification
of
all
non­
administrative
nonconformances
(
that
is,
a
failure
to
meet
a
DQO
specified
by
the
WAP)
or
confirmatory
analytical
techniques
specified
in
the
WAP
are
inconsistent
with
AK
documentation
first
identified
during
the
SPM
review
level
within
five
days
of
identification.
These
NCRs
are
also
submitted
to
CBFO
within
30
days
of
identification
(
reference
42,
Attachment
B,
Section
B3­
13).
­
43
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4.6.4
Corrective
Action
and
Planning
Follow­
up
Corrective
actions
are
planned
and
prepared
for
all
significant
conditions
adverse
to
quality
and
for
any
violation
of
the
WAP.
The
quality
systems
established
for
corrective
actions
and
reporting
are
described
in
MP­
Q&
SI­
5.3,
Corrective
Action.
The
AMWTP
identifies
and
implements
corrective
actions
before
TRU
waste
is
shipped
to
WIPP.
Corrective
Action
Reports
(
CARs)
generated
by
CBFO
are
tracked
in
hard
copy
and
processed
per
CBFO
instructions.
These
corrective
actions
address
considerations
including:

 
The
extent
and
impact
of
the
significant
condition
adverse
to
quality
 
Actions
to
resolve
the
initial
problem
 
Root
cause
of
the
problem
 
Actions
to
be
taken
to
preclude
recurrence
 
Responsible
personnel,
responsibilities,
and
expected
completion
dates
for
the
required
actions.

A
follow­
up
of
completion
of
proposed
corrective
actions
occurs
to
verify
timeliness
and
effectiveness
of
implementation.

4.6.5
Improvement
Analysis
Performance
data
are
identified,
collected,
and
routinely
analyzed
to
identify
opportunities
to
improve
items,
activities,
and
processes.
Analysis
of
quality
performance
data
serves
to
identify
trends
adverse
to
quality.
These
analyses
shall
consider
information
from
external
sources
and
not
be
limited
to
one
type
of
work
or
to
one
organization.
Reports
of
conditions
adverse
to
quality
are
evaluated
to
identify
adverse
quality
trends
and
identify
root
causes,
with
results
reported
to
responsible
management
and
to
the
applicable
quality
assurance
organization.
The
SQAO
is
responsible
to
generate
a
TRU
Programs
trend
analysis
report
semiannually
in
accordance
with
MP­
Q&
SI­
5.1,
Investigations
and
Root
Cause
Analysis.
­
44
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AMWTP
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PROCEDURE
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responsible
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correct
revision
is
used
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When
conditions
adverse
to
quality
are
identified
on
a
recurring
basis,
actions
are
taken
to
evaluate
those
conditions
in
order
to
minimize
their
impact
and
to
preclude
recurrence.
For
recurring
conditions
adverse
to
quality,
management
shall,
as
appropriate:

 
Determine
the
events
leading
to
the
occurrences
 
Develop
an
understanding
of
the
technical
and
work
activities
associated
with
the
conditions
adverse
to
quality
 
Ascertain
and
identify
any
generic
implications
and
impacts
on
completed
work
 
Determine
the
extent
to
which
similar
quality
problems,
or
precursors
to
the
problem,
have
been
recognized
by
the
responsible
organization
 
Determine
the
effectiveness
of
any
corrective
actions
that
were
taken
 
Consider
suspending
work
associated
with
the
applicable
activity
 
Suggest
actions
that
can
be
taken
by
the
responsible
organization
to
preclude
recurrence.

4.7
Documents
and
Records
4.7.1
Document
Control
Documents
that
specify
quality
requirements
or
establish
activities
affecting
quality
are
controlled
to
ensure
that
accurate
and
current
documents
are
used.
Document
Control
personnel
ensure
that
documents
are
approved,
distributed,
filed,
and
maintained
in
accordance
with
current
procedures.

AMWTP
personnel
prepare
and
control
documents
supporting
quality
in
accordance
with
management
procedure,
MP­
DOCS­
18.4,
Document
Control.
Document
owners
ensure
that
documents
are
developed
as
prescribed
by
current
procedures,
reviewed
for
adequacy,
correctness,
completeness,
and
are
approved
and
revised,
as
needed.
Document
control
personnel
verify
proper
document
approval
and
ensure
the
documents
are
distributed
to
the
appropriate
personnel.
­
45
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
45
4.7.2
Document
Preparation,
Review,
Approval
and
Issuance
Instructions,
procedures,
and
drawings
are
reviewed
for
adequacy,
correctness,
and
completeness
prior
to
approval
and
issuance.
MP­
DOCS­
18.1,
Developing
Written
Work
Instructions,
addresses
approved
AMWTP
policies
and
procedures
for
the
initiation,
preparation,
review,
and
revision
control
of
work
instructions
and
MP­
DOCS­
18.3,
Developing
Management
Procedures,
addresses
approved
AMWTP
policies
and
procedures
for
the
initiation,
preparation,
review,
and
revision
control
of
management
procedures
for
all
quality­
related
activities.
Non­
routine/
temporary
processes
may
be
addressed
by
making
temporary
changes
in
procedures
and
plans.
CBFO
approves
quality
affecting
changes
prior
to
implementation.

Qualified
and
independent
personnel
review
all
quality
documents
for
adequacy,
correctness,
and
completeness
prior
to
approval
and
issuance.
MP­
DOCS­
18.4,
Document
Control,
identifies
the
individuals
and/
or
organizations
responsible
for
the
preparation,
review,
approval,
and
issuance
of
controlled
documents.

 
Documents
are
controlled
during
the
review
and
approval
phase,
by
the
document
owner,
in
accordance
with
approved
procedures.

 
The
requesting
organization
identifies
the
applicable
criteria
for
the
review.
These
criteria
consider
technical
adequacy,
accuracy,
completeness,
and
compliance
with
established
requirements.

 
Pertinent
background
information
or
data
are
made
available
by
the
organization
requesting
the
review
if
the
information
is
not
readily
available
to
the
reviewer.

 
Individuals
other
than
the
originator
perform
this
review.

 
Reviewers
are
technically
competent
in
the
subject
area
being
reviewed.

 
The
organization
or
technical
discipline
affected
by
the
document
reviews
the
document
according
to
the
established
review
criteria.

 
The
appropriate
quality
assurance
organization
reviews
documents
that
translate
CBFO
QAPD,
or
other
CBFO
requirements.

 
Review
comment
documentation
is
resolved
by
the
document
owner
in
accordance
with
approved
procedures.
Evidence
of
review
comment
resolution
is
maintained
by
the
originating
organization.

 
Documents
are
approved
for
release
by
authorities
designated
in
accordance
with
approved
procedures.

 
Designated
individuals
or
organizations
issue
documents
in
accordance
with
approved
procedures.
­
46
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
46
Changes
to
WAP
related
plans
and
procedures
are
reviewed
and
approved
by
the
SPM
and
the
SQAO.
All
non­
administrative
changes
are
reviewed
and
evaluated
to
determine
whether
changes
will
affect
performance
criteria
or
data
quality,
such
as
sample
handling
and
custody
requirements,
sampling
and
analytical
procedures,
quality
assurance
objectives,
calibration
requirements,
or
QC
sample
acceptance
criteria.
After
site
certification
authority
has
been
obtained,
any
changes
to
WIPP­
WAP,
related
plans,
or
procedures
that
could
positively
or
negatively
impact
DQOs
(
that
is,
those
changes
that
require
prior
approval
of
WIPP
as
defined
in
Section
B5­
2
of
the
WIPP­
WAP)
shall
be
reported
to
WIPP
within
five
(
5)
days
of
identification
by
the
Project
Level
review.
The
WIPP
shall
send
NMED
a
monthly
summary
briefly
describing
the
changes
to
plans
and
procedures
identified
pursuant
to
this
section
during
the
previous
month.

4.7.3
Document
Distribution
and
Use
Distribution
and
use
of
controlled
documents
and
forms
that
document
or
prescribe
work,
including
changes
and
editorial
corrections
to
document
are
described
in
management
procedures,
MP­
DOCS­
18.4,
Document
Control
and
MP­
DOCS­
18.8,
AMWTP
Forms
Management.

4.7.4
Records
A
QA
record
is
an
authenticated
record
that
provides
evidence
of
the
quality
of
items
and/
or
activities
affecting
quality.
The
AMWTP
QA
records
are
controlled
and
maintained
to
certify
compliance
with
requirements
and
to
reflect
completed
work.
The
QA
records
are
identified,
indexed,
classified,
controlled,
maintained,
and
dispositioned
by
records
management
personnel
as
described
in
MP­
DOCS­
18.2,
AMWTP
Records
Management.

Records
related
to
waste
characterization
sampling
and
analysis
are
maintained
in
the
testing,
sampling,
or
analytical
facility
files
or
at
the
AMWTP
Records
Storage
Facility.
Contract
laboratories
forward
testing,
sampling,
and
analytical
QA
documentation
along
with
batch
data
reports,
to
the
AMWTP
Records
Storage
Facility.
Raw
data
obtained
by
testing,
sampling,
and
analyzing
TRU
waste
in
support
of
this
document
is
identifiable,
legible,
and
provides
documentary
evidence
of
quality.

Altris
eB
 
,
an
electronic
records
system,
[
the
equivalent
of
a
CBFO
required
Records
Inventory
and
Disposition
Schedule
(
RIDS)]
has
been
prepared,
approved,
and
implemented
by
the
AMWTP.
All
records
relevant
to
an
enforcement
action
under
the
WIPP
Permit,
regardless
of
disposition,
will
be
maintained
at
the
AMWTP
until
NMED
determines
that
the
records
are
no
longer
needed
for
enforcement
action.
The
records
will
then
be
dispositioned
as
specified
in
MP­
DOCS­
18.2,
AMWTP
Records
Management.
­
47
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
47
4.8
Performance
Requirements
The
work
processes
and
items
supporting
and
affecting
TRU
Program
quality
are
controlled
through
plans
and
procedures
identified
in
MP­
TRUW­
04­
IM,
AMWTP
TRU
Waste
Program
Procedures
Matrix
for
DOE­
CBFO­
QAPD.
Technical
and
QA
personnel
comply
with
the
applicable
technical
standards
and
administrative
controls
described
in
procedures,
which
are
reviewed
and
approved
by
the
SPM
(
or
designee),
the
SQAO
(
or
designee),
and
cognizant
management
for
use
in
the
TRU
Program.
Cognizant
managers
ensure
personnel
perform
work
following
established
procedures.
These
procedures
provide
the
following
information:

 
Organizational
and
individual
responsibilities
 
Training
and
qualification
requirements
 
Technical,
regulatory,
and
QA
requirements
 
Step­
by­
step
instructions
for
the
process
(
prepared
by
an
SME
of
the
cognizant
organization)

 
Equipment
specifications
 
Methods
and
criteria
for
ensuring
and
verifying
the
acceptability
of
equipment
and
materials
used
in
the
process
(
e.
g.,
calibration)

 
Requirements,
precautions,
process
parameters,
and
other
limiting
conditions
 
Products
of
the
process
 
Quantitative
and/
or
qualitative
criteria
for
determining
that
prescribed
process
activities
have
been
performed
satisfactorily
 
Records
generated
by
the
process
 
Package
and
design
control
of
equipment
and
materials.

The
SPM
and
cognizant
managers
ensure
that
TRU
Program
activities
are
controlled
and
conducted
in
accordance
with
process­
specific
procedures
that
describe
and
control
work
processes
applicable
to
TRU
waste
characterization,
certification,
packaging,
or
transportation.
If
equipment
is
designed
for
TRU
waste
characterization,
certification,
and
transportation
activities,
site
personnel
comply
with
QAPD
design
control.
Each
individual
performing
the
work
is
responsible
for
ensuring
that
work
processes
are
controlled
and
comply
with
established
criteria.
Facility
managers
are
responsible
for
ensuring
that
workers
have
the
correct
procedures,
materials,
and
training
to
perform
quality
work.
All
instructions
and
procedures
are
maintained
current
with
a
documented
and
controlled
method
of
revision.
Instructions,
procedures,
and
drawings
are
readily
available
to
AMWTP
personnel
at
locations
requiring
their
use.
­
48
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
48
Fabrication,
installation,
and
inspection
processes
that
have
an
effect
upon
the
quality
of
items
or
services
important
to
safety
are
controlled
by
process
procedures.

Special
processes
controlled
under
this
QAP
are
NDE,
NDA,
and
helium
leak
testing.
These
processes
are
controlled
by
the
procedures
referenced
in
MP­
TRUW­
04­
IM,
AMWTP
TRU
Waste
Program
Procedures
Matrix
for
DOE­
CBFO­
QAPD.

4.9
Design
Control
Design
Control
is
not
applicable
to
the
AMWTP
TRU
Program
QA
requirements.

4.10
Procurement
The
AMWTP
ensures
that
procurement
of
items
and
services
important
to
safety
and
quality
meet
requirements
and
perform
as
intended.
Procurement
controls
are
also
applicable
to
equipment
and
services
that
directly
affect
testing,
sampling,
and
analytical
data
quality.
Project
personnel
adhere
to
procurement
and
record­
keeping
practices
established
in
written
procedures.

The
procurement
criteria
are
implemented
according
to
the
procedures
specified
in
the
following
subsections.

4.10.1
Procurement
Document
Control
The
AMWTP
Operations
Manager
and
AMWTP
QA
Manager
ensure
personnel
control
procurement
documents
in
accordance
with
MP­
PCMT­
15.3,
Purchase
Order/
Subcontract
Preparation
and
Control.
Procurement
documents
supporting
waste
management
and
packaging
and
transportation
control
must
include
required
specifications
and
acceptance
criteria.
Procurement
documents
are
reviewed
by
appropriate
organizations
and
engineering
disciplines
to
ensure
that
they
contain
adequate
scope
of
work,
technical
requirements,
supplier
QA
program
requirements,
and
provisions
for
acceptance.

4.10.2
Control
of
Purchased
Items
and
Services
The
AMWTP
Operations
Manager
and
QA
Manager
ensure
that
personnel
control
items
and
services
purchased
(
including
supplier
evaluations
and
inspections)
in
accordance
with
MP­
PCMT­
15.7,
Vendor
Qualification
and
Performance
Evaluation.
Documentary
evidence
that
items,
material,
and
equipment
conform
to
the
procurement
specifications
is
provided
before
installation
or
use
of
the
item,
material,
and
equipment,
and
is
retained
in
accordance
with
MP­
PCMT­
15.3,
Purchase
Order/
Subcontract
Preparation
and
Control.
Potential
suppliers
of
goods
and
services
will
have
their
own
QA
program
or
will
comply
with
applicable
AMWTP
requirements.
­
49
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
49
Measures
are
established
to
ensure
that
materials,
parts,
and
components
used
for
repair
work
for
maintenance
purposes,
or
packaging
and
transportation
purposes,
are
adequately
identified
to
preclude
the
use
of
incorrect
or
defective
items.
Also,
where
replacement
of
limited­
life
items
is
specified,
measures
are
established
to
preclude
use
of
items
whose
shelf
life
or
time
in
operation
has
expired.

4.10.3
Control
of
Subcontractors
MP­
PCMT­
15.3,
Purchase
Order/
Subcontract
Preparation
and
Control,
also
applies
to
subcontractors
who
perform
work
that
directly
affects
the
quality
of
characterization
and
certification
data.
Subcontractors
are
required
to
establish
procurement
controls
and
a
QA
program
to
ensure
that
purchased
materials,
equipment,
and
services
conform
to
AMWTP
procurement
and
QAP
procedures.
The
controls
must
include
provisions,
as
appropriate,
for
source
evaluation
and
selection,
objective
evidence
of
quality
furnished
by
the
contractor
or
subcontractor,
inspection
at
the
contractor
or
subcontractor
source,
and
examination
of
products
on
delivery.
Subcontractors
are
subject
to
periodic
assessments
and
audits
at
intervals
consistent
with
the
importance,
complexity,
and
quantity
of
the
product
or
services
provided,
to
ensure
compliance
with
procurement
requirements.

Subcontractors
may
support
activities
under
a
"
staff
augmentation"
role
or
for
procurement
of
products
and
services.
The
staff
augmentation
subcontractors
operate
under
the
purview
of
this
QAP
and
are
subject
to
all
applicable
requirements
for
the
AMWTP­
related
functions
they
perform.
All
subcontractors
who
support
the
AMWTP
will
be
informed
of
the
need
to
perform
operations
in
compliance
with
QAPD
requirements.

4.11
Inspection
and
Testing
Equipment
is
tested,
inspected,
and
identified,
in
accordance
with
approved
procedures.
AMWTP
personnel
identify
and
control
items
(
e.
g.,
items
with
limited
shelf
or
operating
lives,
materials,
equipment,
samples)
and
ensure
that
only
correct
and
accepted
items
are
used.
This
procedure
addresses
planning,
parameters
for
evaluation,
techniques
to
be
used,
and
qualification
of
inspection
and
test
personnel,
hold
points,
documentation,
acceptance
criteria,
and
organizational
responsibilities.

AMWTP
personnel
routinely
test
and
inspect
items
and
processes
and
control,
calibrate,
and
maintain
equipment
to
ensure
proper
operation
and
data
quality.
The
procedure
identified
above
implements
an
inspection
program
that
establishes
criteria
for
inspection
of
activities
affecting
quality
by,
or
for,
the
organization
performing
the
activity,
and
to
verify
conformance
with
the
requirements
for
accomplishing
the
activity.
The
verification
is
performed
in
accordance
with
written
procedures,
instructions,
or
drawings.
Personnel
performing
the
inspections
are
independent
from
the
individuals
performing
the
activity
being
inspected.
Equipment
modifications,
repairs,
and
replacement
are
inspected
in
accordance
with
the
original
design
and
inspection
requirements,
unless
an
approved
alternative
exists.
The
inspection
program
also
provides
for
identification
and
documentation
of
deficiencies
discovered
during
the
inspection.
Identification
and
documentation
of
deficiencies
are
accomplished
in
accordance
with
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions.
Measures
are
established
to
indicate,
by
the
use
of
markings,
tags,
stamps,
labels,
routing
cards,
or
other
suitable
means,
the
status
of
inspections
and
tests
performed.
These
measures
provide
for
the
identification
of
items
that
have
satisfactorily
passed
required
inspections
and
tests,
where
necessary,
to
preclude
inadvertent
bypassing
of
the
inspections
and
tests.
­
50
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
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INEEL
Contact­
Handled
Transuranic
Waste
50
Measuring
and
test
equipment
with
the
necessary
range
and
accuracy
is
provided
to
qualified
personnel
for
the
inspection,
test,
and
acceptance
of
material,
parts,
components,
and
systems.
Equipment
accuracy
is
ensured
by
periodic
calibration
that
is
traceable
to
national
standards
or
a
documented
equivalent
basis
for
calibration.

The
AMWTP
ensures
that
equipment
used
for
inspection
and
testing
is
properly
controlled,
calibrated,
and
maintained
in
accordance
with
MP­
CMNT­
10.5,
Calibration
of
Measuring
and
Test
Equipment
Program.

The
test
control
program
is
established
for
items
and
services
important
to
safety.
No
testing
requiring
a
test
control
program
relative
to
waste
payload
containers
or
the
TRUPACT­
II
will
be
performed
under
this
program.

Specific
measures
to
control
use,
operation,
inspection,
and
maintenance
of
the
TRUPACT­
II
shipping
container
and
directly
related
components
are
established
in
accordance
with
requirements
in
DOE/
WIPP
02­
3183,
CH
Packaging
Program
Guidance
and
DOE/
WIPP
02­
3184,
CH
Packaging
Operations
Manual.
These
procedures
address
the
following
requirements:

 
Operating
and
maintenance
procedures
 
Sites
may
use
the
specific
instructions
provided
by
DOE/
WIPP
02­
3184,
CH
Packaging
Operations
Manual,
or
develop
their
own
procedures
using
steps
from
this
document
word
for
word,
in
sequence,
including
Notes
and
Cautions.
Site­
specific
procedures
must
be
submitted
to
WIPP
for
approval
and
a
copy
of
the
approval
letter
available
for
audit
purposes.

 
Record
Maintenance
 
Records
regarding
inspections,
tests,
and
maintenance
must
be
retained
for
a
period
of
three
years
after
the
life
of
the
package
to
which
they
apply.
Original
records
designated
as
QA
records
will
be
maintained,
as
permanent
records
at
WIPP
and
the
user
preparing
the
maintenance
records
will
retain
a
copy
for
their
file.

 
Material
Control
 
All
components
will
be
procured
and
furnished
to
the
user
sites
by
WIPP.
All
components
shall
be
verified
as
complying
with
applicable
material
requirements
specified
in
the
TRUPACT­
II
SAR
drawings.
Inspection
reports,
test
reports
and
material
certificates
of
conformance
are
maintained
at
WIPP.
Spare
parts
furnished
by
WIPP
will
be
labeled
with
a
part
number,
description,
WIPP
purchase
order
number,
and
shelf
life
expiration
date,
if
applicable.

 
Training
requirements
 
Users
that
perform
maintenance,
leak
testing,
component
replacement,
and
related
operations
receive
training
as
required
in
DOE/
WIPP
02­
3183,
CH
Packaging
Program
Guidance,
Attachment
C.
NDE,
NDA,
and
leak
testing
are
a
special
process
discussed
in
Section
4.3.1
of
this
QAP.

 
Nonconformance
Reports
­
Conditions
encountered
during
inspections
of
the
TRUPACTII
that
are
not
correctable
by
using
work
instructions
contained
in
DOE/
WIPP
02­
3183,
CH
Packaging
Program
Guidance,
Attachment
B,
should
be
brought
to
the
attention
of
the
WIPP
CH
Packaging
Engineer
for
resolution.
­
51
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
51
 
Prior
to
shipment
of
a
TRUPACT­
II,
conditions
of
the
NRC's
certificate
of
compliance
shall
be
satisfied.
Required
shipping
papers
shall
be
prepared
and
shall
accompany
the
shipment.

4.12
Assessment
Requirements
The
AMWTP
participates
in
an
assessment
program
to
ensure
compliance
with
applicable
QA
requirements.
Management
assessments
are
performed
on
every
level
of
management.
Qualified
personnel
who
are
independent
from
the
activities
being
assessed
perform
independent
assessment
and
surveillance
activities.
The
CBFO
and
external
regulatory
agencies
also
conduct
assessments
of
the
AMWTP.
The
SQAO
tracks
deficiencies
identified
during
assessments
and
the
corrective
actions
to
resolve
deficiencies
according
to
Corrective
Action,
MP­
Q&
SI­
5.3.

4.12.1
Management
Assessments
The
AMWTP
managers
periodically
assess
the
performance
of
their
organization
to
determine
the
effectiveness
of
QAP
provisions
that
enable
the
organization
to
comply
with
requirements
of
the
WIPPWAP
QAPD,
WIPP­
WAC,
TRAMPAC,
and
applicable
procedures
and
documents.
Managers
evaluate
the
QAP
effectiveness
by
focusing
on
the
identification
and
resolution
of
both
systemic
and
management
issues
and
problems,
and
by
identifying
strengths
and
weaknesses
to
facilitate
actions
to
improve
quality,
efficiency
and
cost­
effectiveness.
The
management
assessment
should
include
an
introspective
evaluation
to
determine
whether
the
entire
integrated
management
system
effectively
focuses
on
meeting
strategic
goals.
Management
assessments
are
conducted
as
described
in
MP­
M&
IA­
17.1,
Management
Assessments.
The
SPM
is
responsible
for
ensuring
that
assessments
affecting
TRU
Program
characterization,
certification,
and
transportation
activities
are
conducted
regularly
and
reported
at
least
annually
on
relevant
findings.

4.12.2
Independent
Assessments
Documented
independent
assessments
are
used
to
measure
item
service
and
quality,
process
adequacy
and
effectiveness,
and
to
promote
improvement.
AMWTP
personnel
and
facilities
are
subject
to
periodic
independent
assessments
as
identified
by
the
SQAO.
The
SQAO
ensures
that
characterization
facilities
and
analytical
laboratories
are
assessed.
Assessment
teams
include
one
or
more
qualified
assessors,
one
of
whom
must
be
a
certified
lead
assessor.
Assessment
personnel
qualifications
are
addressed
in
the
MPQ
SI­
5.8,
Qualification
of
Inspection,
Test,
and
Audit
Personnel.
­
52
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
52
For
independent
assessments
performed
by
the
SPO,
the
assessment
team
is
made
up
of
a
team
leader
appointed
by
the
SQAO
and
team
members
and
technical
specialists
selected
by
the
team
leader
in
conjunction
with
the
SQAO.
The
team
leader
provides
indoctrination
and
supervision
of
the
team,
organizes
and
directs
the
assessment,
establishes
the
scope
of
the
assessment,
prepares
a
plan
for
conducting
the
assessment,
and
prepares
and
issues
an
assessment
report
to
the
management
of
the
assessed
organization
and
any
affected
organizations.
The
assessment
team
members
and
technical
specialists
prepare
the
assessment
checklist,
conduct
the
assessment,
brief
the
management
of
the
assessed
organization
on
a
daily
basis,
and
prepare
a
draft
report
for
presentation
at
the
exit
conference
for
the
assessment.
Independent
assessments
are
performed
in
accordance
with
MP­
M&
IA­
17.2,
Independent
Assessment.

The
SQAO
ensures
the
acceptable
knowledge
process
and
waste
stream
documentation
is
evaluated
through
internal
assessments
by
the
AMWTP
quality
organization
and
assessments
by
auditors
or
observers
external
to
the
AMWTP.

4.12.3
Surveillances
The
surveillance
program
is
conducted
primarily
to
monitor
work
in
progress
and
to
follow
up
on
corrective
actions.
Surveillance
results
are
reported
and
monitored
similarly
to
other
assessment
activities.
Surveillances
are
performed
in
accordance
with
MP­
M&
IA­
17.3.

4.12.4
CBFO
Audits
Facilities
participating
in
characterization,
certification,
and
shipment
of
waste
to
WIPP
are
subject
to
CBFO
audits,
as
discussed
in
Attachment
B6
of
the
WIPP­
WAP
(
B­
4b(
1)(
iii)).
A
CBFO
audit
of
the
AMWTP
is
conducted
before
waste
is
shipped
to
WIPP
and
annually
thereafter.
These
audits
are
the
responsibility
of
the
CBFO
QA
manager,
who
coordinates
these
audits
through
the
SPM
and
SQAO.

The
CBFO
is
responsible
for
granting
or
suspending
a
site's
authority
to
certify
TRU
waste
and
to
use
the
TRUPACT­
II
based
upon
an
assessment
of
their
documented
TRU
waste
program
and
its
implementation.
Subsequent
to
the
initial
audit,
the
CBFO
will
perform
audits
at
least
annually.
CBFO
may
also
perform
unannounced
audits
and
surveillance's
at
the
AMWTP
to
confirm
continued
compliance
with
the
approved
plans.

4.12.5
Reports
to
Management
The
SQAO
shall
summarize
all
relevant
information
on
the
QA/
QC
activities
during
the
period
in
a
semiannual
report.
The
SQAO
reports
these
independent
assessment
results
to
the
SPM
in
accordance
with
management
procedure,
MP­
TRUW­
8.26,
Reports
to
Management.
The
SPM
shall
review
the
report;
comment
if
appropriate,
and
then
forward
a
copy
of
the
report
with
comments
to
the
DOE
Field
Office
and
the
AMWTP
General
Manager.
The
annual
QA
report
includes
the
following
information,
as
appropriate:

 
Any
changes
to
the
AMWTP
QAPjP
 
Identification
of
any
significant
QA/
QC
problems,
recommended
solutions,
and
corrective
actions
­
53
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
53
 
An
assessment
of
QC
data
collected
during
the
period,
including
the
frequency
of
repeated
analyses,
reasons
they
were
repeated,
and
corrective
actions
 
Discussions
of
whether
QAOs
have
been
met
and
any
resulting
impact
on
decision
making
 
Limitations
on
the
use
of
measurement
data
 
Status
of
Performance
Demonstration
Program
(
PDP)
results
 
Results
of
audits
and
surveillances
conducted
during
the
period
 
Performance
Demonstration
Program
The
AMWTP
and
supporting
facilities
participate
in
the
Headspace
Gas
Sampling
(
HGS)
and
Solids
Sampling
PDP
as
summarized
in
the
AMWTP
QAPjP.
PDP
samples
are
processed
according
to
the
facility
procedures
applicable
to
the
specific
testing
or
analytical
characterization
activity
being
assessed.
Results
are
reported
to
CBFO
for
evaluation
and
approval
of
the
system.

The
AMWTP
also
participates
in
the
Non­
Destructive
Assay
(
NDA)
PDP
as
summarized
in
the
Appendix
A
of
this
document.
The
AMWTP
demonstrates
compliance
with
the
QAO
for
precision
and
accuracy
by
performing
replicate
processing
of
a
mock
waste
container
containing
quantities
of
TRU
isotopes
for
each
range
for
which
the
measurement
system
is
to
be
qualified.
Results
are
reported
to
CBFO
for
evaluation
and
approval
of
the
system.

4.13
Sample
Control
Requirements
AMWTP
personnel
and
supporting
contractors
follow
procedures
to
ensure
proper
documentation
and
tracking
of
sample
possession
from
the
time
of
collection/
identification,
through
handling,
preservation,
shipment,
transfer,
analysis,
storage,
and
final
disposition.
Sample
control
procedures
used
by
personnel
are
described
in
the
AMWTP
QAPjP.
AMWTP
personnel
ship
samples
in
compliance
with
the
Department
of
Transportation
(
DOT)
regulations
and
Project
QA
requirements.

4.14
Scientific
Investigation
Requirements
The
AMWTP
uses
data
validation
as
a
systematic
process
for
reviewing
radioassay
data
to
ensure
that
data
are
of
known
and
documented
quality
and
that
the
required
data
quality
objectives
are
met.
Results
of
the
review
may
require
that
qualifiers
be
placed
on
the
use
of
the
data.
­
54
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
54
All
radioassay
data
reviewed
and
approved
by
qualified
personnel
prior
to
being
reported.
Personnel
performing
validation
at
the
AMTWP
are
trained
to
the
existing
industry
standardized
training
requirements
(
e.
g.,
ASTM
C1490,
Standard
Guide
for
Selection,
Training
and
Qualification
of
Nondestructive
Assay
[
NDA]
Personnel
and
meets
the
specifications
in
the
QAPD.

The
Technical
Reviewer
is
independent
of
the
collection
activities
and
the
results
of
the
review
are
documented
as
defined
in
MP­
TRUW­
8.8,
Level
I
Data
Validation.
The
review
ensures
the
following
as
applicable:
 
Data
is
recorded
so
that
it
is
clearly
identifiable
and
traceable
to
the
source
of
generation.

 
Data
transferred
and
reduced
from
logbooks,
data
sheets,
and
radioassay
instrumentation
are
evaluated
to
determine
if
the
data
was
collected
in
a
technical
correct
manner.

 
Deviations
are
documented
 
QA
results
are
complete
and
documented
correctly.

 
Results
are
compared
to
the
acceptance
criteria
to
determine
if
the
data
is
valid.

 
Data
that
are
determined
to
be
rejected,
superseded,
or
otherwise
unsuited
for
their
intended
use
are
documented
in
accordance
with
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions.

 
All
data
records
from
logbooks,
data
sheets,
or
radioassay
instrumentation
are
maintained
in
accordance
with
MP­
DOCS­
18.2,
AMWTP
Records
Management.

4.15
Software
Requirements
Computer
software
used
in
the
manipulation
or
production
of
data
in
the
processing,
gathering,
or
generation
of
information
whose
output
is
relied
upon
to
make
design,
analytical,
operational,
or
compliance
related
decisions
in
the
performance
of
waste
characterization,
waste
transportation,
or
waste
acceptance
is
developed
and
maintained
in
a
controlled
manner.
Computer
hardware/
software
configurations
used
in
AMWTP
activities
are
developed,
documented,
verified,
validated,
tested,
and
controlled
prior
to
use
in
compliance
with
requirements
contained
in
the
QAPD.
Instructions
governing
these
activities
are
detailed
in
procedures
referenced
in
MP­
CD&
M­
11.2,
Software
Quality
Assurance.
­
55
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
55
5.0
REFERENCES
NOTE:
AMWTP
document
references
are
available
in
the
AMWTP
TRU
Waste
Program
Procedures
Matrix
for
DOE­
CBFO­
QAPD,
MP­
TRUW­
04­
IM.

INEEL
Documents
1.
EDF­
RWMC­
803,
Chemical
Constituents
in
Transuranic
Storage
Area
(
TSA)
Waste,
current
revision,
Idaho
National
Engineering
and
Environmental
Laboratory.

2.
INEL­
96/
0280,
Acceptable
Knowledge
Documentation
for
INEL
Stored
Transuranic
Waste,
Rocky
Flats
Plant
Waste,
current
revision,
Idaho
National
Engineering
and
Environmental
Laboratory.

DOE
Documents
3.
DOE
Order
0414.1A,
Quality
Assurance,
U.
S.
Department
of
Energy.

4.
DOE
Order
435.1,
Implementation
Guide,
Chapter
III.
L,
Radioactive
Waste
Management,
U.
S.
Department
of
Energy.

5.
DOE
Order
460.1,
Packaging
and
Transportation
Safety,
Department
of
Energy.

6.
DOE
Order
460.2,
Departmental
Materials
Transportation
and
Packaging
Management,
U.
S.
Department
of
Energy.

7.
DOE/
CBFO­
94­
1012,
Quality
Assurance
Program
Document,
U.
S.
Department
of
Energy,
Carlsbad
Area
Office,
Carlsbad,
New
Mexico.
(
http://
www.
wipp.
ws/
library/
qapd/
caoqapd.
pdf)

8.
DOE/
CAO­
1996­
2184,
Title
40
Code
of
Federal
Regulations
(
CFR)
191/
194
Compliance
Certification
Application
for
the
Waste
Isolation
Pilot
Plant,
U.
S.
Department
of
Energy,
Carlsbad,
New
Mexico.
(
http://
www.
wipp.
ws/
library/
cca/
cca.
htm)

9.
DOE/
CBFO­
97­
2273,
WIPP
Waste
Information
System
User's
Manual
For
Use
by
Shippers/
Generators,
U.
S.
Department
of
Energy,
Carlsbad
Area
Office
(
DOE/
CAO),
Carlsbad,
New
Mexico.
(
ftp://
ftp.
wipp.
ws/
usermanual.
pdf)

10.
DOE/
EIS­
0026,
Final
Environmental
Impact
Statement
for
the
Waste
Isolation
Pilot
Plant,
U.
S.
Department
of
Energy,
1980.

11.
DOE/
EIS­
0026­
FS,
Final
Supplemental
Environmental
Impact
Statement
for
the
Waste
Isolation
Pilot
Plant,
U.
S.
Department
of
Energy,
1990.

12.
DOE/
EIS­
0026­
S­
2,
Final
Supplemental
Environmental
Impact
Statement
for
the
Waste
Isolation
Pilot
Plant,
U.
S.
Department
of
Energy,
1997.
­
56
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
56
13.
DOE/
WIPP
89­
004,
TRUPACT­
II
Content
Codes
(
TRUCON),
current
revision,
U.
S.
Department
of
Energy.

14.
DOE/
WIPP­
95­
2065,
Waste
Isolation
Pilot
Plant
Safety
Analysis
Report,
U.
S.
Department
of
Energy,
Carlsbad,
New
Mexico.
(
http://
www.
wipp.
ws/
library/
chsar/
chsar.
htm)

15.
DOE/
WIPP­
95­
2125,
Waste
Isolation
Pilot
Plant
Contact
Handled
(
CH)
Technical
Safety
Requirements,
U.
S.
Department
of
Energy,
Waste
Isolation
Pilot
Plant
(
DOE/
WIPP),
Carlsbad,
New
Mexico.
(
http://
www.
wipp.
ws/
library/
chsar/
chsar.
htm)

16.
DOE/
WIPP
02­
3122,
Contact­
Handled
Transuranic
Waste
Acceptance
Criteria
for
the
Waste
Isolation
Pilot
Plant,
U.
S.
Department
of
Energy,
Carlsbad
Field
Office,
Waste
Isolation
Pilot
Plant
(
DOE/
WIPP),
Carlsbad,
New
Mexico.

17.
DOE/
WIPP
02­
3183,
CH
Packaging
Program
Guidance,
U.
S.
Department
of
Energy,
Waste
Isolation
Pilot
Plant
(
DOE/
WIPP),
Carlsbad,
New
Mexico.

18.
DOE/
WIPP
02­
3184,
CH
Packaging
Operations
Manual,
U.
S.
Department
of
Energy,
Waste
Isolation
Pilot
Plant
(
DOE/
WIPP),
Carlsbad,
New
Mexico.

19.
DOE/
WIPP­
02­
3185,
CH
Packaging
Maintenance
Manual,
U.
S.
Department
of
Energy,
Waste
Isolation
Pilot
Plan
(
DOE/
WIPP),
Carlsbad,
New
Mexico.

Codes
and
Standards
20.
Public
Law
96­
164,
93
Sta.
1259.
DOE
National
Security
and
Military
Applications
of
Nuclear
Energy
Authorization
Act,
1980,
Section
213(
a).
(
http://
thomas.
loc.
gov/
cgibin
bdquery/
z?
d096:
SN00673:
TOM:/
bss/
d096query.
html)

21.
Public
Law
102­
579,
106
Stat.
4777,
1992
(
as
amended
by
Public
Law
104­
201),
Waste
Isolation
Pilot
Plant
Land
Withdrawal
Act.
(
http://
www.
emnrd.
state.
nm.
us/
wipp/
lwa.
htm)

22.
42
U.
S.
C.
6901
et
seq.
Resource
Conservation
and
Recovery
Act
(
RCRA)
of
1988.

23.
42
U.
S.
C.
2011
et
seq.
Atomic
Energy
Act
(
AEA)
of
1954.
(
http://
www4.
law.
cornell.
edu/
uscode/
42/
2011.
html)

24.
42
U.
S.
C
10141.
Nuclear
Waste
Policy
Act
of
1982.
(
http://
www4.
law.
cornell.
edu/
uscode/
42/
10141.
html)

25.
EPA­
QA/
G­
4,
Guidance
for
the
Data
Quality
Objectives
Process,
U.
S.
Environmental
Protection
Agency.
Washington,
DC,
Quality
Assurance
Management
Staff,
U.
S.
Environmental
Protection
Agency.
(
http://
www.
epa.
gov/
swerust1/
cat/
epaqag4.
pdf)
­
57
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
57
26.
63
FR
27353,
Criteria
for
the
Certification
and
Recertification
of
the
Waste
Isolation
Pilot
Plant's
27.
Compliance
with
the
Disposal
Regulations:
Certification
Decision:
EPA
Final
Rule.
Federal
Register
63:
27353­
27406,
May
18,
1998,
Radiation
Protection
Division,
Washington,
D.
C.
(
http://
www.
epa.
gov/
radiation/
wipp/
docs/
frnotice.
pdf)

28.
Title
10
CFR
Part
71.
"
Packaging
and
transportation
of
radioactive
material."
Code
of
Federal
Regulations
(
CFR)
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
cfrhtml_
00/
Title_
10/
10cfr71_
00.
html)

29.
10
CFR
71,
Subpart
H,
Quality
Assurance,
Code
of
Federal
Regulations
(
CFR)

30.
10
CFR
830.
Subpart
A,
Nuclear
Safety
Management,
Code
of
Federal
Regulations
(
CFR).

31.
10
CFR
835,
Occupational
Radiation
Protection,
Code
of
Federal
Regulations
(
CFR).
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
waisidx_
01/
10cfr835_
01.
html)

32.
Title
40
CFR
Part
191.
"
Environmental
Radiation
Protection
for
Management
and
Disposal
of
Spent
Nuclear
Fuel,
High­
Level,
and
Transuranic
Radioactive
Wastes."
Code
of
Federal
Regulations,
Washington,
D.
C.,
Office
of
the
Federal
Register,
National
Archives
and
Records
Administration.
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
cfrhtml_
00/
Title_
40/
40cfr191_
00.
html)

33.
40
CFR
194,
Criteria
for
the
Certification
and
Re­
certification
of
the
Waste
Isolation
Pilot
Plants
Compliance
with
the
40
CFR
Part
191
Disposal
Regulations,
Code
of
Federal
Regulations
(
CFR).
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
cfrhtml_
00/
Title_
40/
40cfr194_
00.
html)

34.
40
CFR
262,
Standards
Applicable
to
Generators
of
Hazardous
Waste,
Code
of
Federal
Regulations
(
CFR).
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
cfrhtml_
00/
Title_
40/
40cfr262_
00.
html)

35.
49
CFR
172,
Shipping
Papers:
Additional
Description
Requirements,
Code
of
Federal
Regulations
(
CFR).
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
cfrhtml_
00/
Title_
49/
49cfr172_
00.
html)

36.
Title
49
CFR
Part
173.
"
Shippers
 
General
requirements
for
shipping
and
packaging."
Code
of
Federal
Regulations,
Washington,
D.
C.,
Office
of
the
Federal
Register,
National
Archives
and
Records
Administration.
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
cfrhtml_
00/
Title_
49/
49cfr173_
00.
html)

37.
49
CFR
173.433,
Contamination
Control,
Code
of
Federal
Regulations
(
CFR).
(
http://
www.
access.
gpo.
gov/
nara/
cfr/
waisidx_
00/
49cfr173_
00.
html)

38.
ASME
NQA­
1
1989,
Nuclear
Quality
Assurance,
American
Society
of
Mechanical
Engineers.
­
58
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
58
39.
ASME
NQA­
2
1990,
Nuclear
Quality
Assurance,
American
Society
of
Mechanical
Engineers.

40.
ANSI/
AIM
BC1­
1995,
Uniform
Symbology
Specification
 
Code
39,
American
National
Standards,
Inc.

41.
NIST,
Handbook
44,
1996,
Specifications,
Tolerances,
and
Other
Technical
Requirements
for
Weighing
and
Measuring
Devices,
U.
S.
Department
of
Commerce,
National
Bureau
of
Standards,
National
Institute
of
Standards
and
Technology
(
NIST).

42.
NM4890139088­
TSDF,
Waste
Isolation
Pilot
Plant
Hazardous
Waste
Facility
Permit,
New
Mexico
Environment
Department,
Santa
Fe,
New
Mexico.
http://
www.
wipp.
ws/
library/
rcrapermit/
rcrapermit.
htm)

Other
Documents
43.
U.
S.
Nuclear
Regulatory
Commission
(
NRC),
Certificate
of
Compliance,
NRC
Docket
No
71­
9218,
Office
of
Regulatory
Procedures,
Washington
D.
C.
(
http://
www.
wipp.
ws/
library/
t2sar/
rev19a/
cofc/
trucert.
pdf)

44.
U.
S.
Nuclear
Regulatory
Commission
(
NRC),
Safety
Analysis
Report
for
the
TRUPACT­
II
Shipping
Package,
NRC
Docket
No
71­
9218
(
TRUPACT­
II
SARP),
Office
of
Regulatory
Procedures,
Washington
D.
C.

45.
U.
S.
Nuclear
Regulatory
Commission.
TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
TRAMPAC).
Washington,
D.
C.,
Office
of
Regulatory
Procedures,
U.
S.
Nuclear
Regulatory
Commission.
(
http://
http://
www.
wipp.
carlsbad.
nm.
us/
library/
t2sar/
rev19a/
Trampac/
TRAMPAC.
PDF)
­
1
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
1
APPENDIX
A
Radioassay
Requirements
for
Contact­
Handled
Transuranic
Waste
­
2
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
2
A.
1
Introduction
To
support
the
radiological
characterization
data
required
by
WIPP,
the
AMWTP
performs
nondestructive
assay
(
NDA)
on
each
payload
container
and
reports
the
following
information
to
WIPP
using
the
WWIS:

 
Track
the
WIPP
radionuclide
inventory,
by
isotopic
activity
and
mass,
for
those
radionuclides
listed
in
section
3.3.1,

 
Demonstrate
that
each
payload
container
disposed
of
at
the
WIPP
contains
TRU
waste
as
specified
in
section
3.3.3,
and
 
Verify
that
applicable
transportation
and
facility
limits
on
individual
payload
containers
and
assemblies
for
FGE,
PE­
Ci,
and
decay
heat
are
not
exceeded,
as
specified
in
section
3.3.2,
3.3.4
and
3.3.6.

The
radioassay
process
quantifies
at
least
one
of
the
more
prevalent
radionuclides
known
to
be
present
in
the
waste.
The
remaining
listed
radionuclides
present
in
the
waste
in
significant
quantities
will
be
identified
by
direct
measurement
of
isotopic
ratios
as
discussed
in
section
A.
2.
The
isotopic
ratios
are
then
used
to
quantify
radionuclides
based
on
the
assay
value.

The
requisite
data
on
isotopic
ratios
and
quantities
will
be
derived
from
AK
(
see
section
A.
2),
radioassay
or
both
using
CBFO
approved
NDA,
instruments
and
procedures.
The
AMWTP
technically
justifies
that
the
AK
and/
or
radioassay
techniques,
instruments
and
procedures
used:

 
are
appropriate
for
the
specific
waste
stream
and
waste
content
code
descriptions
being
assayed,
and
 
will
result
in
unbiased
values
for
the
cumulative
activity
and
mass
of
the
WIPP
radionuclide
inventory.
­
3
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
3
The
AMWTP
uses
NDA
techniques
to
quantify
the
radionuclides
entrained
in
the
TRU
waste
drums.
Two
Retrieval
Drum
Assay
Systems
(
RDAS)
are
used.
The
RDAS
are
designed
to
accommodate
both
55­
gallon
and
83/
85­
gallon
drums.
The
measurement
techniques
used
with
the
drum
assay
systems
are
passive
neutron
multiplicity
counting,
active
neutron
counting
using
the
differential
die­
away
(
DDA)
technique,
gamma­
ray
isotopic
analysis
and
quantitative
gamma­
ray
energy
analysis.
The
high­
efficiency
passive
neutron
analysis
provides
measurement
of
most
matrix
types
in
the
waste
processed
by
the
AMWTP.
Active
neutron
analysis
supplements
the
passive
approach
for
certain
waste
forms
and
provides
better
detection
limits
for
low­
activity
waste
containers.
The
high­
resolution
gamma­
ray
measurements
provide
direct
information
on
the
isotopic
composition
of
the
plutonium
(
Pu),
uranium
(
U),
americium
(
Am),
and
other
isotopes
in
the
waste
or
isotopic
ratios.
The
integrated
information
from
the
neutron
measurements,
gamma­
ray
measurements,
and
Acceptable
Knowledge
(
AK)
are
used
to
determine
the
isotopic
material
composition,
quantify
the
radionuclide
masses,
and
compute
the
associated
derived
quantities
for
each
payload
container.

AMWTP
will
not
use
existing
radioassay
data
collected
prior
to
the
implementation
of
a
quality
assurance
program
pursuant
to
40
CFR
§
194.22(
a)(
1)
to
characterize
and
certify
payload
containers
for
disposal
at
WIPP.

Proposals
for
alternative
approaches
to
identification
and
quantification
of
radioisotopes
(
e.
g.,
quantification
of
isotopic
ratio
AK
on
a
waste
stream
basis)
must
be
submitted
to
CBFO
for
review
and
approval.
CBFO
will
report
such
proposals
to
EPA
for
consideration
prior
to
issuing
approval.

A.
2
Radionuclide
Isotopic
Ratios
Establishing
isotopic
ratios
for
use
in
quantifying
radionuclides
is
performed
by
direct
measurement
of
each
container
using
the
AMWTP
Drum
Assay
Systems
(
DASs).
Sites
may
opt
to
qualify
AK
as
permitted
by
40
CFR
§
194.22(
b)
by
performing
confirmatory
testing
using
WIPP­
certified
radioassay
systems.
The
AMWTP
performs
an
assay
on
each
container
characterized
for
disposal
at
WIPP.
When
direct
measurements
of
isotopic
ratios
does
not
yield
useable
data
as
a
result
of
technical
reasons
(
e.
g.,
lack
of
sufficient
signal
or
poor
counting
statistics),
AK
is
used.
All
such
instances
will
be
documented
and
appropriately
dispositioned.

A.
2.1
Methods
for
Confirmation
of
Isotopic
Ratio
AK
As
a
minimum,
to
confirm
existing
AK
data,
it
is
necessary
to
compare
the
ratio
of
the
two
most
prevalent
radionuclides
in
the
isotopic
mix.
For
weapons
and
reactor
grade
plutonium,
these
are
typically
239Pu
and
240Pu.
For
heat
source
waste,
the
predominant
radionuclides
are
typically
238Pu
and
239Pu.
Measured
isotopic
ratios
for
241Am
may
confirm
existing
AK
by
waste
stream.
However,
due
to
the
fluctuation
of
241Am
in
certain
waste
streams,
it
may
become
necessary
to
measure
239Pu
to
241Am
isotopic
ratios
on
all
containers
in
that
waste
stream.
­
4
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
4
241Am
is
the
daughter
of
241Pu,
which
decays
with
a
half­
life
of
about
14
years.
If
the
time
since
the
chemical
separation
of
the
plutonium
is
known,
the
quantity
of
measured
241Am
can
be
used
to
calculate
the
quantity
of
241Pu.
This
assumes
there
was
no
241Am
in
the
waste
just
after
the
chemical
separation
and
that
no
241Am
was
added
to
or
removed
from
the
waste
during
the
time
since
the
separation.
Since
241Am
is
an
indirect
measurement
of
241Pu,
it
could
be
compared
(
by
ratio)
to
any
plutonium
isotope
(
239Pu
or
240Pu)
associated
with
weapons
and
reactor
grade
plutonium.

For
weapons
grade
and
reactor
grade
waste,
isotopic
ratio
values
for
238Pu
can
be
assumed
to
be
valid
in
AK
data
if
the
values
for
239Pu
and
240Pu
have
been
confirmed.
Because
242Pu
cannot
be
measured
using
NDA
methods,
the
contribution
of
242Pu
isotopic
ratio
is
calculated
by
correlation
techniques.

For
some
of
the
generator
sites
that
were
involved
primarily
in
weapons
production,
the
fissile
isotopes
235U
and
233U
and
the
fissionable
isotope
238U
may
not
have
been
measured
when
the
transuranic
waste
was
originally
assayed
(
i.
e.,
using
non­
WIPP­
certified
systems),
primarily
because
the
plutonium
isotopes
were
the
radionuclides
of
interest
to
the
generator
site.
However,
other
forms
of
AK
may
be
available.
If
so,
then
the
AK
can
be
confirmed
by
data
generated
on
a
WIPP­
certified
system.
If
valid
AK
does
not
exist,
then
the
data
generated
on
a
WIPP­
certified
system
can
only
be
used
to
detect
or
calculate
238U,
235U,
and
233U
or
to
confirm
their
absence.
Because
234U
cannot
be
measured
using
NDA
methods,
the
isotopic
ratios
for
234U
may
be
calculated
from
the
235U
enrichment.
Values,
or
lack
thereof,
for
137Cs
can
be
confirmed
by
the
data
generated
on
a
WIPP­
certified
system.
This
is
typically
done
by
measuring
137Cs
directly,
or
by
comparing
the
NDA
measured
241Am
662
keV
peak
to
the
other
241Am
peaks
(
e.
g.,
the
125
keV
or
721
keV
peaks)
to
determine
if
the
662
keV
peak's
intensity
is
consistent
with
the
expected
241Am
intensity.
A
disproportionate
response
for
the
662
keV
peak
relative
to
the
other
241Am
peaks
may
indicate
the
presence
of
137Cs.
90Sr
may
be
calculated
from
the
value
for
137Cs
and
AK.
If
detected,
a
waste
container's
concentration
of
137Cs
can
be
used
to
derive
a
value
of
90Sr,
through
the
application
of
the
appropriate
scaling
factor(
s).
All
scaling
factors
used
will
be
technically
sound
and
based
on
known,
documented
relationships
or
correlations.
The
data
report
for
the
waste
containers
for
which
the
90Sr,
value
is
derived
in
this
manner
shall
reflect
the
use
of
a
scaling
factor(
s)
and
provide
sufficient
documentation
to
enable
its
independent
calculation.
Finally,
the
gamma
spectra
must
be
carefully
examined
for
significant
presence
of
other
radionuclides
to
ensure
compliance
with
transportation
requirements.
Data
obtained
for
radionuclides
other
than
the
WIPP­
tracked
radionuclides
presented
above
are
required
to
address
confounding
isotope
issues
(
i.
e.,
masking)
with
regard
to
NDA.

The
technique
used
to
confirm
that
the
absence
or
the
ratio
of
non­
measurable
radionuclides
are
valid
for
the
radioassay
method
used
to
confirm
AK
are
documented
in
RPT­
TRUW­
03,
Drum
Assay
Technical
Review
Report.
­
5
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
5
A.
2.2
Acceptable
Knowledge
(
AK)
Documentation
The
use
of
AK
information
concerning
the
radiological
composition
of
a
waste
stream
will
be
documented
either
in
the
AK
summary
report
for
the
waste
characterization
of
the
waste
stream
or
in
another
controlled
document
approved
by
the
Site
Project
Manager.
Should
this
information
be
contained
in
AK
package(
s)
prepared
to
meet
other
general
waste
characterization
requirements,
it
need
not
be
duplicated
in
other
controlled
documents
that
address
the
radiological
properties
of
the
waste
stream;
however,
all
relevant
information
must
be
included
in
the
AK
record.
The
AMWTP
AK
process
is
controlled
and
documented
in
accordance
with
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK.
The
following
discussion
is
included
for
the
sake
of
completeness.

A.
2.2.1
Required
Elements
This
section
identifies
the
required
radiological
information
that
each
TRU
waste
generating
site
or
measurement
facility
must
maintain
for
a
waste
stream.
A
TRU
waste
generator
site
or
waste
characterization
facility
may
use
AK
to
delineate
the
distribution
of
the
10
WIPP­
tracked
radioisotopes
within
a
TRU
waste
stream
and
the
presence
or
absence
of
isotopes.
The
type
and
quantity
of
supporting
documentation
may
vary
by
waste
stream
and
shall
be
compiled
in
a
written
record
that
shall
include
a
summary
identifying
all
sources
of
information
used
to
delineate
the
waste
stream's
isotopic
distribution.
The
basis
and
rationale
for
the
delineation
shall
be
clearly
summarized
in
an
AK
report
and
traceable
to
referenced
documents.
Assumptions
made
in
this
delineation
shall
be
identified.
The
following
information
shall
be
included
as
part
of
the
AK
written
record:

 
Map
of
the
site
with
the
areas
and
facilities
involved
in
TRU
mixed
waste
generation,
treatment,
and
storage
identified
 
Facility
mission
description
as
related
to
radionuclide­
bearing
materials
and
their
management,
e.
g.,
routine
weapons
production,
fuel
research
&
development
and
experimental
processes
 
Description
of
the
specific
site
locations
(
such
as
the
area
or
building)
and
operations
relative
to
the
isotopic
composition
of
the
TRU
wastes
they
generated,
e.
g.,
plutonium
recovery,
weapons
fabrication,
pyrochemical
operations
and
waste
incineration
 
Waste
identification
or
categorization
schemes
used
at
the
facility
relevant
to
the
waste
material's
isotopic
distribution,
e.
g.,
the
use
of
codes
that
correlate
to
a
specific
isotopic
distribution,
and
a
description
of
the
isotopic
composition
of
each
waste
stream
 
Information
regarding
the
waste's
physical
and
chemical
composition
that
could
affect
the
isotopic
distribution,
e.
g.,
processes
used
to
remove
ingrown
241Am
or
alter
its
expected
contribution
based
solely
on
radioactive
decay
kinetics
­
6
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
6
 
Statement
of
all
numerical
adjustments
applied
to
derive
the
material's
isotopic
distribution,
e.
g.,
scaling
factors,
decay/
ingrowth
corrections
and
secular
equilibrium
considerations
 
Specification
of
the
isotopic
ratios
for
the
10
WIPP­
tracked
radionuclides
(
241Am,
238Pu,
239Pu,
240Pu,
242Pu,
233U,
234U,
238U,
90Sr,
and
137Cs)
and,
if
applicable,
the
radionuclides
that
comprise
95%
of
the
radiological
hazard
on
a
waste
stream,
waste
stream
subpopulation,
or
container
basis.

A.
2.2.2
Supplemental
Acceptable
Knowledge
Information
Each
generator
site
or
measurement
facility
shall
obtain
supplemental
AK
information,
dependent
on
availability.
The
amount
and
type
of
this
information
cannot
be
mandated,
but
sites
shall
collect
information
as
appropriate
to
support
their
contention
regarding
the
waste's
isotopic
distribution.
This
information
will
be
used
to
compile
the
waste's
AK
written
record.
Supplemental
AK
documentation
that
may
be
used
includes,
but
is
not
limited
to,
information
from
the
following
sources:

 
Safeguards
&
Security,
Materials
Control
&
Accountability
and
other
nuclear
materials
control
systems
or
programs
and
the
data
they
generated
 
reports
of
nuclear
safety
or
criticality,
or
accidents/
excursions
involving
the
use
of
special
nuclear
material
(
SNM)
or
nuclear
material
 
waste
packaging,
waste
disposal,
building
or
nuclear
material
management
area
(
NMMA)
logs
or
inventory
records,
and
site
databases
that
provide
information
on
SNM
or
nuclear
materials
 
test
plans,
research
project
reports
or
laboratory
notebooks
that
describe
the
radionuclide
content
of
materials
used
in
experiments
 
information
from
site
personnel
(
e.
g.,
documented
interviews)

 
historical
analytical
data
relevant
to
the
isotopic
distribution
of
the
waste
stream
­
7
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
7
A.
2.2.3
Discrepancy
Resolution
If
there
is
a
discrepancy
between
AK
information
related
to
isotopic
ratios
or
composition,
the
site
will
evaluate
the
sources
of
the
discrepancy
to
determine
if
the
discrepant
information
is
credible.
Information
that
is
not
credible
or
information
that
is
limited
in
its
applicability
to
WIPP
characterization
will
be
identified
as
such
and
the
reasons
for
dismissing
it
will
be
justified
in
writing
in
accordance
with
management
procedure,
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
Acceptable
Knowledge
Documentation.
Limitations
concerning
the
information
will
be
documented
in
the
AK
record
and
summarized
in
the
AK
report.
In
the
event
that
the
discrepancy
cannot
be
resolved,
the
site
will
perform
direct
measurements
for
the
impacted
population
of
containers.

If
discrepancies
result
in
a
change
to
the
original
determinations,
the
AK
summary
will
be
updated.

A.
3
Data
Quality
Objectives
The
data
quality
objectives
for
WIPP
certifiable
radiological
characterization
data
are
established
in
section
3.3
of
the
WAC.
They
are
summarized
below
in
table
A­
3
as
they
apply
to
individual
payload
containers.
The
AMWTP
does
not
use
Radiochemistry
(
RC)
or
calorimetry
methods
to
characterized
TRU
waste
for
disposal
at
WIPP.

Table
A­
3
Data
Quality
Objectives
for
Radioassay
Requirement
DQO
Confidencea
TRU
 
 ­
activity
concentration
>
100
nCi/
g
A
>
LLD
N/
A
Fissile
mass
<
 
200
FGE
(
55­
gallon
drums)
FGE
+
2 TMU(
FGE)
<
200
97.5%

Fissile
mass
<
 
325
FGE
(
SWBs
and
TDOPs)
FGE
+
2 TMU(
FGE)
<
 
325
97.5%

Decay
heat
 
<
TRAMPAC
limit
DH
+
1 TMU(
DH)
<
 
LTRAMPAC
84%

aConfidence
means
the
statistical
level
of
confidence
that
the
limit
is
exceeded
or
not
exceeded
depending
on
the
requirements
of
the
individual
data
quality
objectives.
The
confidence
is
derived
from
the
specified
DQOs
which
assume
contributions
to
TMU
are
normally
distributed.
­
8
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
8
There
are
no
stipulated
data
quality
objectives
for
PE­
Ci
or
individual
isotope
activities
(
except
as
they
impact
the
requirements
listed
above).
However,
at
a
minimum,
radioassay
programs
must
be
capable
of
identifying,
measuring,
and
reporting
the
presence
or
absence
of:

 
the
ten
radionuclides
identified
in
section
3.3.1
for
tracking
of
the
WIPP
radionuclide
inventory
(
see
section
A.
2.1),

 
235U,
in
order
to
calculate
FGE,
as
required
in
section
3.3.2
for
compliance
with
transportation
requirements,
and
 
other
radionuclides
whose
presence
contribute
to
95%
of
the
radioactive
hazard,
as
specified
in
section
3.3.1,
for
compliance
with
transportation
requirements.

In
support
of
the
above
requirements,
the
Canberra
Site
Acceptance
Test
Reports
(
SATR)
for
the
Integrated
Waste
Assay
Systems,
CI­
IDA­
NDA­
0051
and
CI­
IDA­
NDA­
0052
documents
and
provides
technical
justification
for
the
following
determinations.

Lower
Limit
of
Detection:
The
lower
limit
of
detection
(
LLD)
for
the
DAS
has
been
determined.
Only
DAS
measurement
modalities
that
have
an
LLD
of
100
nCi/
g
or
less
are
used
to
perform
TRU/
low­
level
waste
discrimination
measurements.
Background
and
container
specific
interferences
are
factored
into
LLD
determinations.
The
LLD
is
that
level
of
radioactivity
which,
if
present,
yields
a
measured
value
greater
than
the
critical
level
with
a
95%
probability,
where
the
critical
level
is
defined
as
that
value
which
measurements
of
the
background
will
exceed
with
5%
probability.
Because
the
LLD
is
a
measurement­
based
parameter,
it
is
not
feasible
to
calculate
LLDs
for
radionuclides
that
are
not
determined
primarily
by
measurement,
e.
g.,
Sr­
90.
In
such
cases,
the
AMWTP
has
derived
and
documented
the
equivalent
of
an
LLD,
i.
e.,
a
reporting
threshold
for
a
radionuclide(
s),
when
it
is
technically
justified.
For
purposes
of
reporting
radionuclide
data
in
the
WWIS,
this
value
will
be
the
equivalent
of
an
LLD.
References
A3
and
A4
provide
information
in
developing
the
LLD.

Total
Measurement
Uncertainty
(
TMU):
The
method
used
to
calculate
the
TMU
for
the
quantities
in
table
A­
3
must
be
documented
and
technically
justified
in
the
Canberra
Industries,
Total
Measurement
Uncertainty
for
the
AMWTP
Integrated
Waste
Assay
Systems,
CI­
IDA­
NDA­
0055.
Compliance
with
this
requirement
will
be
evaluated
in
reviews
of
the
TMU
documentation
package
for
each
assay
system
by
CBFO.
General
guidance
for
determining
the
TMU
is
provided
in
references
A5
and
A6.
­
9
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
9
Calibration
Procedures
and
Frequencies:
Each
DAS
(
references
A21
through
32)
has
been
calibrated
before
initial
use.
During
calibration
or
re­
calibration,
system
correction
factors
are
established
and
algorithms
adjusted
such
that
the
value
of
%
R
is
set
as
close
to
100%
as
possible,
i.
e.,
the
system
is
calibrated
to
approximately
100%
R.
The
range
of
applicability
of
system
calibrations
is
specified
in
SATR.
The
matrix/
source
surrogate
waste
combination(
s)
used
for
calibration
are
representative
of
the
 
activity
range(
s)
or
gram
loading(
s),
and
 
relevant
waste
matrix
characteristics
(
e.
g.,
densities,
moderator
content,
container
size)
planned
for
measurement
by
the
system.

Calibration(
s)
shall
be
performed
in
accordance
with
consensus
standards,
where
applicable.
If
consensus
standards
are
not
used,
full
documentation
of
the
calibration
technique
is
provided
to
and
approved
by
CBFO
prior
to
performing
WIPP
related
assays.
Primary
calibration
standards
shall
be
obtained
from
suppliers
maintaining
a
nationally
accredited
measurement
program.
When
primary
standards
are
not
available,
the
standards
are
correlated
with
primary
standards
obtained
from
a
nationally
accredited
measurement
program
Calibration
Verification:
Notwithstanding
the
need
to
calibrate
individual
components
for
replacement,
changes
or
adjustments
(
e.
g.,
energy
calibration
of
a
detector),
verification
of
the
DAS
calibration
is
performed
after
any
one
of
the
following
occurs:

 
major
system
repairs
and/
or
modifications
 
replacement
of
the
measurement
system's
components,
e.
g.,
detector,
neutron
generator
or
supporting
electronic
components
that
have
the
capacity
to
affect
data
 
significant
changes
to
the
system's
software
 
relocation
of
the
system
Calibration
verification
shall
consist
of
demonstrating
that
the
system
is
within
the
range
of
acceptable
operation.
Secondary
standards
can
be
used
for
the
calibration
verification
if
their
performance
has
been
correlated
with
the
calibration
standard.
If
a
verification
of
the
measurement
system's
calibration
or
other
test
demonstrates
that
the
system's
response
has
significantly
changed,
a
re­
calibration
of
the
system
shall
be
performed.
Calibrated
verification
tests,
along
with
acceptance
criteria
are
detailed
work
instruction,
INST­
TRUW­
8.1.1,
Drum
Assay
Post
Maintenance
Calibration
&
Verification.
­
10
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
10
Calibration
Confirmation:
In
order
to
confirm
that
the
calibration
of
each
DAS
was
correctly
established,
the
accuracy
and
precision
of
each
DAS
are
determined
after
each
calibration
or
re­
calibration
by
performing
replicate
measurements
of
a
non­
interfering
matrix.
Calibration
confirmation
replicate
measurements
are
performed
on
containers
of
the
same
nominal
size
as
those
in
which
actual
waste
is
assayed
and
according
to
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
The
number
of
replicate
measurements
to
be
performed
is
documented
and
technically
justified.
The
replicate
measurements
are
performed
using
nationally
recognized
standards,
or
certified
standards
derived
from
nationally
recognized
standards
that
span
the
range
of
use.
The
standards
used
to
calculate
accuracy
are
not
the
same
as
those
used
for
the
system
calibration.
Accuracy
is
reported
as
percent
recovery
(%
R).
The
applicable
range
for
accuracy
shall
not
exceed
+
 
30%
on
a
non­
interfering
matrix.
Precision
is
reported
as
percent
relative
standard
deviation
(%
RSD).
The
%
RSD
shall
not
exceed
the
values
listed
in
Table
A­
3.2
for
the
corresponding
number
of
replicate
measurements
in
a
non­
interfering
matrix.
Calibration
confirmation
tests
are
conducted
and
documented
in
accordance
with
work
instruction,
CI­
IDA­
NDA­
0035,
Calibration
Verification
&
Confirmation
Procedure
for
the
Integrated
Waste
Assay
System
(
IWAS)
at
AMWTP
and
SATR..

Table
A­
3.2
Upper
Limits
for
%
RSD
vs.
Number
of
Replicates
Number
of
Replicates
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Max
%
RSDa
1.8
6.6
10.0
12.3
14.0
15.2
16.2
17.1
17.7
18.3
18.8
19.3
19.7
20.0
a
The
values
listed
are
derived
from
the
measured
standard
deviation
of
the
replicate
measurements
using
%
100
1
)
292
.
0
(
%
100
2
1
,
05
.
0
 
 
 
<
 
 

n
s
n
 
µ
where
s
is
the
measured
standard
deviation,
n
is
the
number
of
replicates,
µ
is
the
true
value,
 2
0.05,
n­
1
is
the
critical
value
for
the
upper
5%
tail
of
a
one
sided
chi­
squared
distribution
with
n­
1
degrees
of
freedom,
and
0.292
corresponds
to
a
95%
upper
confidence
bound
on
the
true
system
precision
limit
of
29.2%.

A.
4
Quality
Control
Section
4.0
of
this
AMWTP
Certification
Plan
summarizes
the
QA
requirements
relating
to
waste
characterization,
certification,
and
transportation
that
meet
all
applicable
requirements
of
the
CBFO
QAPD.
The
AMWTP
DAS
uses
calibration
and
operating
procedures
that
have
been
written,
approved,
and
controlled.
Noncomforming
items
and
processes
that
do
not
meet
established
criteria
are
identified,
controlled
and
corrected
in
accordance
with
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions
and
MP­
Q&
SI­
5.3,
Corrective
Action.
­
11
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
11
A.
4.1
General
Requirements
Radioassay
Training:
Only
appropriately
trained
and
qualified
personnel
are
allowed
to
perform
radioassay
and
data
validation/
review.
Standardized
Training
requirements
for
radioassay
personnel
are
based
upon
existing
industry
standardized
training
requirements
(
e.
g.,
ASTM
C1490,
Standard
Guide
for
Selection,
Training
and
Qualification
of
Nondestructive
Assay
[
NDA]
Personnel
[
reference
A8])
and
meets
the
specifications
in
the
QAPD.
Requalification
of
radioassay
personnel
shall
be
based
upon
evidence
of
continued
satisfactory
performance
and
must
be
performed
at
least
every
two
years.
Personnel
receive
training
requisite
with
their
activities
and
level
of
responsibility
in
accordance
with
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.
The
period
of
effectiveness
for
qualification
and
the
requalification
criteria
are
also
specified.

Software
QC
Requirements:
All
computer
programs
and
revisions
thereof
used
for
radioassay
meet
the
applicable
requirements
in
the
QAPD
(
reference
A2,
section
6.0)
and
are
performed
in
accordance
with
MP­
CD&
M­
11.2,
Software
Quality
Assurance.

Comparison
Programs:
The
AMWTP
participates
in
any
relevant
measurement
comparison
program(
s)
sponsored
or
approved
by
the
CBFO.
Such
programs
may
be
conducted
as
part
of
the
NDA
performance
demonstration
program
(
PDP)
(
references
A7
and
A10)
or
through
other
third
parties.
(
Reference:
WIPP
Compliance
Certification
Application
including
Annual
Reports
to
the
EPA).

A.
4.2
NDA
QC
Requirements
The
assay
procedures
cited
in
various
American
Society
for
Testing
and
Materials
(
ASTM)
and
American
National
Standards
Institute
(
ANSI)
standards
(
references
A9,
A11­
A15)
and
NRC
standard
practices
and
guidelines
(
reference
A16)
as
referenced
in
this
appendix
are
recommended
for
use
at
all
testing
facilities.

Background
Measurements:
Background
measurements
are
performed
and
recorded
at
least
once
per
operational
day,
unless
otherwise
approved
by
CBFO.
Contributions
to
background
due
to
radiation
from
nearby
radiation
producing
equipment,
standards
or
wastes
are
engineered
into
the
facility
and
DAS
design
and
controlled
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.

Instrument
Performance
Measurements:
Performance
checks
on
the
calibrated
and
operable
DAS
(
both
gamma
and
neutron
modalities)
are
performed
and
recorded
described
in
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
Performance
checks
shall
include
daily
efficiency
checks
and
checks
for
spectrometric
instruments,
peak
position
and
resolution
checks
and
weekly
matrix
correction.
­
12
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
12
A
Standardization
Check
is
performed
prior
to
assaying
each
waste
container.
The
Standardization
Check
is
performed
by
extending
the
Add­
A­
Source
prior
to
loading
a
waste
container
and
performing
passive
neutron
and
gamma­
ray
measurements.
The
results
of
the
Standardization
Check
are
compared
against
established
criteria
to
perform
efficiency
checks
and,
for
the
gamma­
ray
measurement,
peak
position
and
resolution
checks
prior
to
assaying
each
waste
drum.

At
least
once
per
operational
week
an
interfering
matrix,
loaded
with
radioactive
sources,
is
assayed
in
accordance
with
work
instruction,
INST­
OI­
14,
Drum
Assay
Operations.
The
results
are
evaluated
against
established
criteria
to
assess
the
long­
term
stability
of
the
NDA
instrument's
matrix
correction.
Both
high
interfering
and
less
interfering
surrogate
waste
containers
are
used
with
source
standards
to
test
the
range
of
the
waste
and
the
source
loadings
being
assayed.
Over
a
six­
month
period,
the
operating
range
of
the
DAS
is
tested
on
applicable
surrogate
waste
matrices
representative
of
the
waste
streams
being
processed.
The
interfering
surrogate
matrix
drums
are
such
that
the
waste
characteristics
do
not
change
over
time.

Radioactive
sources
used
for
the
performance
measurement
checks
are
long­
lived,
easy
to
position
relative
to
the
detector(
s),
and
of
sufficient
radioactivity
to
obtain
good
results
with
relatively
short
count
times.
Where
appropriate,
decay­
corrected
values
are
used
for
compliance
comparisons.
­
13
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
13
Data
Checks:
Background
and
performance
measurements
(
standardization,
daily
performance
verification,
and
weekly
check
with
an
interfering
matrix
drum)
are
evaluated
against
established
criteria
at
the
time
of
the
measurements
to
determine
acceptability
of
the
RDAS.
At
least
once
per
week,
the
background
and
performance
measurement
results
are
reviewed
and
evaluated
to
monitor
performance
trends
in
accordance
with
management
procedure,
MP­
TRUW­
8.8,
Level
I
Data
Validation.
If
daily
performance
checks
result
in
data
that
are
outside
the
acceptable
range,
the
required
responses
in
table
A­
4.2
shall
be
followed.

Acceptability
Rangea
Required
Response
Acceptable
Range
 
|
Data|
c
<
2 b
No
action
required.

Warning
Range
2
 b
<
|
Data|
<
3 b
If
the
first
performance
check
rerun
is
less
than
2 ,
then
proceed
with
waste
assay
measurements.
If
the
first
performance
check
rerun
is
greater
than
3 ,
then
go
to
the
response
required
for
the
"
Action
Range".
If
the
first
performance
check
rerun
is
between
2 
and
3 ,
then
make
one
more
performance
measurement
(
i.
e.,
a
second
run).
If
that
mesurement
is
less
than
2 ,
then
proceed
with
waste
assay
measurements;
otherwise
go
to
the
reponse
for
the
"
Action
Range".

Action
Range
|
Data|
>
3 b
If
a
daily
performance
verification
check
result
from
the
first
run
is
greater
than
3 
or
if
the
Required
Response
described
above
leads
to
the
Action
Range,
then
work
stops
for
the
affected
DAS
and
the
occurrence
is
documented
and
appropriately
dispositioned
(
e.
g.,
a
non­
conformance
report
is
initiated).
The
DAS
is
removed
from
service
pending
successful
resolution
of
all
necessary
actions,
and
all
assays
performed
since
the
last
acceptable
daily
performance
verification
check
are
suspect,
pending
satisfactory
resolution.
Recalibration
or
calibration
verification
is
required
prior
to
returning
the
system
back
to
service.
aReference
A15
b"
 "
­
the
standard
deviation
is
only
based
on
the
reproducibility
of
the
data
check
measurements
themselves.
This
is
not
TMU.
cAbsolute
Value
A.
4.3
Radiochemistry
QC
Requirements
AMWTP
does
not
use
Radiochemistry
(
RC)
methods
to
characterize
TRU
waste
for
disposal
at
WIPP.
Assay
standards
are
prepared
and
used
as
indicated
in
the
standard
test
methods.

A.
5
Data
Management
­
14
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
14
A.
5.1
Data
Review
and
Validation
All
radioassay
data
must
be
reviewed
and
approved
by
qualified
personnel
prior
to
being
reported.
At
a
minimum,
the
data
must
be
reviewed
by
a
technical
reviewer
and
approved
by
the
site
project
manager
or
their
designee(
s).
Personnel
are
qualified
as
specified
in
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.
The
validation
process
described
in
MP­
TRUW­
8.8,
Level
I
Data
Validation,
and
MPTRUW
8.9,
Level
II
Data
Validation,
includes
verification
that
the
applicable
quality
controls
specified
in
section
A.
4
have
been
met.

A.
5.2
Data
Reporting
Radioassay
data
are
reported
to
the
site
project
office
on
a
testing
batch
basis.
Batches
are
defined,
as
a
suite
of
waste
containers
undergoing
radioassay
using
the
same
testing
equipment.
For
NDA,
the
sites
shall
specify
the
size
of
the
testing
batch
as
needed,
without
regard
to
waste
matrix.

The
AMWTP
submits
testing
batch
data
reports
(
either
by
the
WTS
or
hard
copy)
for
each
testing
batch
to
the
site
project
office,
as
defined
in
MP­
TRUW­
8.8,
Level
I
Data
Validation.
Radioassay
testing
batch
data
reports
shall
consist
of
the
following:

 
Testing
facility
name,
testing
batch
number,
container
numbers
included
in
that
testing
batch,
and
signature
release
by
the
site
project
manager
or
their
designee(
s).

 
Table
of
contents
 
Background
and
performance
data
or
control
charts
for
the
relevant
time
period.

 
Data
validation
per
the
QAPD
(
reference
A2,
section
5.3.2)
and
as
described
in
MPTRUW
8.8,
Level
I
Data
Validation.

 
Separate
testing
report
sheet(
s)
for
each
container
in
the
testing
batch
that
includes
­
Title
"
Radioassay
Data
Sheet"
­
Method
used
for
radioassay
(
i.
e.,
procedure
identification)
­
Date
of
radioassay
­
Activities
and/
or
masses
of
individual
radioisotopes
present
and
their
associated
TMUs
(
curies
and/
or
grams)
­
Operator
signature/
date
­
Reviewer
signature/
date
­
15
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
15
Other
radiological
properties
to
be
documented
for
each
container
include:

 
Decay
heat
expressed
in
Watts
(
W)
and
its
associated
TMU,

 
Total
239Pu
FGE
expressed
in
grams
(
g)
and
its
associated
TMU
 
TRU
alpha
activity
concentration
expressed
in
curies/
gram
(
Ci/
g)
and
its
associated
TMU,
and
 
Total
239Pu
equivalent
activity
expressed
in
curies
(
Ci).

Radioassay
data
for
each
performance
check
(
i.
e.,
daily
performance
check
and
weekly
interfering
matrix
performance
check)
and
each
container
is
transferred
from
the
DAS
to
the
WTS.
Calculated
quantities
are
included
in
the
radioassay
batch
data
reports.

TMU
is
reported
in
terms
of
one
standard
deviation
on
the
DAS
and
the
WTS
reports.

A.
5.3
Data
and
Records
Retention
The
following
nonpermanent
records
are
maintained
at
the
AMWTP
for
maintenance,
and
are
documented
and
retrievable
by
testing
batch
number,
in
accordance
with
the
QAPD:

 
testing
batch
reports
 
all
raw
data,
including
instrument
readouts,
calculation
records,
and
radioassay
QC
results
 
all
instrument
calibration
reports,
as
applicable
A.
6
Quality
Characteristics
Assessment
Per
40
CFR
§
194.22(
c),
there
are
five
"
quality
characteristics"
that
have
to
be
assessed.
These
quality
characteristics
and
the
method
by
which
they
are
assessed
are
described
in
the
following
sections.
­
16
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
16
A.
6.1
Data
Accuracy
Per
40
CFR
§
194.22(
c)(
1),
Data
Accuracy
is
defined
as
"
the
degree
to
which
data
agree
with
an
acceptable
reference
or
true
value."
For
the
AMWTP
NDA
methods,
this
quality
characteristic
is
met
and
maintained
as
described
in
section
A.
3.
The
AMWTP
does
not
use
RC
methods
for
characterizing
CHTRU
waste.

A.
6.2
Data
Precision
Per
40
CFR
§
194.22(
c)(
2),
Data
Precision
is
defined
as
"
a
measure
of
the
mutual
agreement
between
comparable
data
gathered
or
developed
under
similar
conditions
expressed
in
terms
of
standard
deviation."
For
AMWTP
NDA
methods,
this
quality
characteristic
is
met
and
maintained
as
described
in
section
A.
3.
The
AMWTP
does
not
use
RC
methods
for
characterizing
CH­
TRU
waste.

A.
6.3
Data
Representativeness
Per
40
CFR
§
194.22(
c)(
3),
Data
Representativeness
is
defined
as
"
the
degree
to
which
data
can
accurately
and
precisely
represent
a
characteristic
of
a
population,
a
parameter,
variations
at
a
sampling
point,
or
environmental
conditions."
For
NDA
and
RC
methods,
this
quality
characteristic
for
the
waste
stream
is
met
and
maintained
through
100%
measurement
confirmation
on
a
payload
container
basis.
For
NDA,
since
the
entire
waste
container
is
subjected
to
measurement,
representativeness
pertaining
to
the
actual
measurement
is
not
applicable.
The
AMWTP
does
not
use
RC
methods
for
characterizing
CHTRU
waste.

A.
6.4
Data
Completeness
Per
40
CFR
§
194.22(
c)(
4),
Data
Completeness
is
defined
as
"
a
measure
of
the
amount
of
valid
data
obtained
compared
to
the
amount
that
was
expected."
For
NDA
methods,
this
quality
characteristic
is
met
and
maintained
by
requiring
100%
valid
results.
For
the
AMWTP
NDA
program,
any
results
indicating
the
NDA
measurement
was
invalid
require
re­
measurement.
The
AMWTP
does
not
use
RC
methods
for
characterizing
CH­
TRU
waste.
­
17
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
17
A.
6.5
Data
Comparability
Per
40
CFR
§
194.22(
c)(
5),
Data
Comparability
is
defined
as
"
a
measure
of
confidence
with
which
one
data
set
can
be
compared
to
another."
For
NDA
methods,
this
quality
characteristic
is
addressed
by
ensuring
that
all
data
are
produced
under
the
same
system
of
controls.
These
controls
apply
to
all
aspects
of
the
data
generation
process,
including:
procurement
of
analytical
instruments;
calibration
and
operation
of
assay
equipment
according
to
industry
standards;
preparation
and
use
of
standardized
instrument
and
data
review
procedures;
and,
training
of
equipment
operators
and
technical/
data
review
personnel
to
the
QAPD,
as
specified
in
Section
A.
4.1.
All
NDA
and
RC
systems
and
methods
are
approved
by
CBFO
prior
to
use
in
generating
waste
characterization
data.
Additionally,
comparison
of
measured
data
with
AK
derived
or
based
values,
as
applicable,
provides
a
means
to
assess
comparability
on
a
waste
stream
basis.
Although
no
specific
confidence
level
is
specified,
these
controls
provide
comparability
among
all
data
generated
under
this
program.
Sites
using
radioassay
systems
shall
participate
in
measurement
comparison
programs
as
specified
in
Section
A.
4.1.
­
18
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
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ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
18
Appendix
A
References
A1.
U.
S.
Nuclear
Regulatory
Commission.
Peer
Review
for
High­
Level
Nuclear
Waste
Repositories,
NUREG­
1297,
Washington
D.
C.,
Office
of
Nuclear
Material
Safety
and
Safeguards,
U.
S.
Nuclear
Regulatory
Commission.

A2.
U.
S.
Department
of
Energy.
Quality
Assurance
Program
Document.
CAO­
94­
1012.
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy.
http://
www.
wipp.
ws/
library/
qapd/
caoqapd.
pdf
A3.
Currie,
Lloyd
A.,
1968.
Limits
for
qualitative
detection
and
quantitative
determination.
Anal.
Chem.
40:
586­
93.

A4.
EPA,
1980.
Upgrading
Environmental
Radiation
Data.
EPA
520/
1­
80­
012,
Washington
D.
C.,
Office
of
Radiation
Programs,
U.
S.
Environmental
Protection
Agency.

A5.
K.
C.
Smith,
R.
A.
Stroud,
K.
L.
Coop,
and
J.
F.
Bresson.
1998.
"
Total
Measurement
Uncertainty
Assessment
for
Transuranic
Waste
Shipments
to
the
Waste
Isolation
Pilot
Plant."
Proceedings
of
the
6th
Nondestructive
Assay
Waste
Characterization
Conference,
Salt
Lake
City,
Utah,
Nov.
17­
19,
1998,
pp.
21­
37.

A6.
K.
L.
Coop,
J.
F.
Bresson,
M.
E.
Doherty,
B.
M.
Gillespie,
and
D.
R.
Davidson.
"
Standardized
Total
Measurement
Uncertainty
Reporting
for
WIPP".
Nondestructive
Assay
Interface
Working
Group,
Salt
Lake
City,
Utah,
May
22,
2000.

A7.
U.
S.
Department
of
Energy.
Performance
Demonstration
Program
Plan
for
Nondestructive
Assay
of
Boxed
Wastes
for
the
TRU
Waste
Characterization
Program.
DOE/
CBFO­
01­
1006,
Current
Revision.
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy.
http://
www.
wipp.
ws/
library/
pdp/
DOE­
CBFO­
01­
1006Rev0.
pdf
A8.
American
Society
for
Testing
and
Materials.
Standard
Guide
for
Selection,
Training
and
Qualification
of
Nondestructive
Assay
(
NDA)
Personnel,
ASTM
C1490,
Annual
Book
of
ASTM
Standards,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials.

A9.
American
National
Standards
Institute.
Radiometric
Calorimeters
 
Measurement
Control
Program,
ANSI
N15.54,
American
National
Standards
Institute,
Inc.,
1430
Broadway,
New
York,
NY
10018.

A10.
U.
S.
Department
of
Energy.
Performance
Demonstration
Program
Plan
for
Nondestructive
Assay
of
Drummed
Wastes
for
the
TRU
Waste
Characterization
Program.
DOE/
CBFO­
01­
1005,
Current
Revision.
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy.
http://
www.
wipp.
ws/
library/
pdp/
DOE­
CBFO­
01­
1005Rev0.1.
pdf
­
19
­
AMWTP
MANAGEMENT
PROCEDURE
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responsible
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is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
19
A11.
American
Society
for
Testing
and
Materials.
"
Standard
Test
Method
for
Determination
of
Plutonium
Isotopic
Composition
by
Gamma­
Ray
Spectrometry."
ASTM
C1030­
95,
Annual
Book
of
ASTM
Standards,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials.

A12.
American
Society
for
Testing
and
Materials.
"
Standard
Test
Method
for
Nondestructive
Assay
of
Nuclear
Material
in
Scrap
and
Waste
by
Passive­
Active
Neutron
Counting
Using
a
252Cf
Shuffler."
ASTM
C1316­
95,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials.

A13.
American
Society
for
Testing
and
Materials.
"
Standard
Test
Method
for
Nondestructive
Assay
of
Special
Nuclear
Material
in
Low
Density
Scrap
and
Waste
by
Segmented
Passive
Gamma­
Ray
Scanning."
ASTM
C1133­
96,
Annual
Book
of
ASTM
Standards,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials.

A14.
American
Society
for
Testing
and
Materials.
"
Standard
Test
Method
for
Nondestructive
Assay
of
Plutonium,
Tritium
and
241
Am
by
Calorimetric
Assay."
ASTM
C1458­
00,
Annual
Book
of
ASTM
Standards,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials.

A15.
American
National
Standards
Institute.
Nondestructive
Assay
Measurement
Control
and
Assurance,
ANSI
N15.36.
American
National
Standards
Institute,
Inc.,
1430
Broadway,
New
York,
NY
10018
A16.
U.
S.
Nuclear
Regulatory
Commission.
1984.
Nondestructive
Assay
of
Special
Nuclear
Material
Contained
in
Scrap
and
Waste.
Regulatory
Guide
5.11,
Washington,
DC,
Office
of
Nuclear
Regulatory
Research,
U.
S.
Nuclear
Regulatory
Commission.

A17.
American
National
Standards
Institute.
Plutonium­
Bearing
Solids
Calibration
Techniques
for
Calorimetric
Assay.
ANSI
N15.22­
1987,
American
National
Standards
Institute,
Inc.,
1430
Broadway,
New
York,
NY
10018.

A18.
Canberra
Industries,
Genie
2000
Spectroscopy
System
Customization
Tools,
ICN
9230847F4
A19.
Canberra
Industries,
NDA
2000
Technical
Reference
Manual,
ICN
9231595C.

A20.
Canberra
Industries,
Total
Measurement
Uncertainty
for
the
AMWTP
Integrated
Waste
Assay
Systems,
CI­
IDA­
NDA­
0055.

A21.
Canberra
Industries,
Neutron
Multiplicity
Counter
Characterization
Report
for
the
Integrated
Waste
Assay
System,
Retrieval
Unit
1,
34000B.
­
20
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
20
A22.
Canberra
Industries,
Neutron
Multiplicity
Counter
Characterization
Report
for
the
Integrated
Waste
Assay
System,
Retrieval
Unit
2,
34001B.

A23.
Canberra
Industries,
Differential
Die­
Away
Analysis
Characterization
Report
for
the
Integrated
Waste
Assay
System,
Retrieval
Unit
1,
34002A.

A24.
Canberra
Industries,
Differential
Die­
Away
Analysis
Characterization
Report
for
the
Integrated
Waste
Assay
System,
Retrieval
Unit
2,
34003B
A.
25.
Canberra
Industries,
Q2
Calibration
Report
for
the
Integrated
Waste
Assay
System,
Retrieval
Unit
1,
34004A.

A.
26.
Canberra
Industries,
Q2
Calibration
Report
for
the
Integrated
Waste
Assay
System,
Retrieval
Unit
2,
34005A.

A.
27.
Canberra
Industries,
Site
Acceptance
Test
Reports
(
SATR)
for
the
Integrated
Waste
Assay
Systems
Retrieval
Unit
#
1
at
AMWTP,
CI­
IDA­
NDA­
0051.

A.
28.
Canberra
Industries,
Site
Acceptance
Test
Reports
(
SATR)
for
the
Integrated
Waste
Assay
Systems
Retrieval
Unit
#
2
at
AMWTP,
CI­
IDA­
NDA­
0052.
­
21
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
A­
21
A.
29.
Canberra
Industries,
Calibration
Verification
&
Confirmation
Procedure
for
Integrated
Waste
Assay
(
IWAS)
at
AMWTP,
CI­
IDA­
NDA­
0035.

A.
30.
BNFL
Inc.,
Drum
Assay
Technical
Review
Report,
RPT­
TRUW­
03.

A.
31.
BNFL
Inc.,
Drum
Assay
Post
Maintenance
Calibration
and
Verification,
INST­
TRUW­
8.1.1.
­
1
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
B­
1
APPENDIX
B
239Pu
Equivalent
Activity
­
2
­
AMWTP
MANAGEMENT
PROCEDURE
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responsible
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Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
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for
INEEL
Contact­
Handled
Transuranic
Waste
B­
2
The
concept
of
239Pu
equivalent
activity
(
PE­
Ci)
is
intended
to
eliminate
the
dependency
of
radiological
analyses
on
specific
knowledge
of
the
radionuclide
composition
of
a
TRU
waste
stream.
A
unique
radionuclide
composition
and/
or
distribution
are
associated
with
most
TRU
waste
streams
at
each
site.
By
normalizing
all
radionuclides
to
a
common
radiotoxic
hazard
index,
radiological
analyses
that
are
essentially
independent
of
these
variations
can
be
conducted
for
the
WIPP
facility.
239Pu,
as
a
common
component
of
most
defense
TRU
wastes,
was
selected
as
the
radionuclide
to
which
the
radiotoxic
hazard
of
other
TRU
radionuclides
could
be
indexed.

Modeled
operational
releases
from
the
WIPP
facility,
including
both
routine
and
accident­
related,
are
airborne.
There
are
no
known
significant
liquid
release
pathways
during
the
operational
phase
of
the
facility.
This,
and
the
fact
that
TRU
radionuclides
primarily
represent
inhalation
hazards,
allows
a
valid
relationship
to
be
established,
which
normalizes
the
inhalation
hazard
of
a
TRU
radionuclide
to
that
of
239Pu
for
the
purpose
of
the
WIPP
radiological
analyses.
In
effect,
the
radiological
dose
consequences
of
an
airborne
release
of
a
quantity
of
TRU
radioactivity
with
a
known
radionuclide
distribution
will
be
essentially
identical
to
that
of
a
release
of
that
material
expressed
in
terms
of
a
quantity
of
239Pu.
To
obtain
this
correlation,
the
50­
year
effective
whole­
body
dose
commitment
or
dose
conversion
factor
for
a
unit
intake
of
each
radionuclide
will
be
used.

For
a
known
radioactivity
quantity
and
radionuclide
distribution,
the
239Pu
equivalent
activity
is
determined
using
radionuclide­
specific
weighting
factors.
The
239Pu
equivalent
activity
(
AM)
can
be
characterized
by:

K
AM
=
 
Ai
/
WFi
i
=
1
where
K
is
the
number
of
TRU1
radionuclides,
Ai
is
the
activity
of
radionuclide
i,
and
WFi
is
the
PE­
Ci
weighting
factor
for
radionuclide
i.

WFi
is
further
defined
as
the
ratio
WFi
=
Eo
/
Ei
where
Eo
(
rem/
µ
Ci)
is
the
50­
year
effective
whole­
body
dose
commitment
due
to
the
inhalation
of
239Pu
particulates
with
a
1.0
µ
m
activity
median
aerodynamic
diameter
(
AMAD)
and
a
weekly
pulmonary
clearance
class,
and
Ei
(
rem/
µ
Ci)
is
the
50­
year
effective
whole­
body
dose
commitment
due
to
the
inhalation
of
radionuclide
(
i)
particulates
with
a
1.0
µ
m
activity
median
aerodynamic
diameter
and
the
pulmonary
clearance
class
resulting
in
the
highest
50­
year
effective
whole­
body
dose
commitment.
­
3
­
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MP­
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8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
B­
3
Weighting
factors
calculated
in
this
manner
are
presented
in
table
B­
1
for
radionuclides
typically
present
in
CH­
TRU
waste.
If
other
TRU
radionuclides
are
determined
to
be
present
in
the
payload
container,
their
weighting
factors
can
be
obtained
from
the
values
of
Eo
and
Ei
contained
in
DOE/
EH­
0071
(
reference
B1).

Table
B­
1
PE­
Ci
Weighting
Factors
for
Selected
Radionuclides
Radionuclide
Pulmonary
Clearance
Classa
Weighting
Factor
233U
Y
3.9
237Np
W
1.0
236Pu
W
3.2
238Pu
W
1.1
239Pu
W
1.0
240Pu
W
1.0
241Pu
W
51.0
242Pu
W
1.1
241Am
W
1.0
243Am
W
1.0
242Cm
W
30.0
244Cm
W
1.9
252Cf
Y
3.9
a
(
W)
Weekly,
(
Y)
Yearly
B.
1
Appendix
B
References
B1.
U.
S.
Department
of
Energy.
Internal
Dose
Conversion
Factors
for
Calculation
of
DOSE
to
the
Public.
DOE/
EH­
0071,
July
1988.
­
1
­
AMWTP
MANAGEMENT
PROCEDURE
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responsible
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correct
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MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
C­
1
APPENDIX
C
Glossary
­
2
­
AMWTP
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MP­
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Revision
2
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11/
03
Effective:
06/
11/
03
Certification
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for
INEEL
Contact­
Handled
Transuranic
Waste
C­
2
Acceptable
knowledge
(
AK)
­
Knowledge
used
for
waste
characterization,
which
is
based
on
the
materials
and
processes
used
to
generate
a
waste.
Acceptable
knowledge
includes
information
about
the
physical
form
of
the
waste,
the
base
materials
composing
the
waste
(
especially
hazardous
and
radioactive
materials),
and
the
process
that
generated
the
waste.
Acceptable
knowledge
is
used
to
define
waste
streams,
assign
summary
categories,
assign
EPA
hazardous
waste
numbers,
estimate
the
weight
fraction
of
CPR,
and
estimate
isotopic
ratios.

Activity
­
A
measure
of
the
rate
at
which
a
material
emits
nuclear
radiation,
usually
given
in
terms
of
the
number
of
nuclear
disintegrations
occurring
in
a
given
length
of
time.
The
common
unit
of
activity
is
the
curie,
which
amounts
to
37
billion
(
3.7
x
1010)
disintegrations
per
second.
The
International
Standard
unit
of
activity
is
the
becquerel
and
is
equal
to
one
disintegration
per
second.

Administrative
controls
­
Provisions
relating
to
organization
and
management,
procedures,
record
keeping,
assessment,
and
reporting
necessary
to
ensure
the
safe
operation
of
the
facility.

Atomic
energy
defense
activities
­
Activities
of
the
Secretary
of
Energy
(
and
predecessor
agencies)
performed
in
whole
or
in
part
in
carrying
out
any
of
the
following
functions:
naval
reactors
development;
weapons
activities,
including
defense
inertial
confinement
fusion;
verification
and
control
technology;
defense
nuclear
material
production;
defense
nuclear
waste
and
materials
by­
product
management;
defense
nuclear
materials
security
investigations;
and
defense
research
and
development.

Authorization
basis
­
Those
aspects
of
the
facility
design
and
operational
requirements
relied
upon
by
DOE
to
authorize
the
operation
of
nuclear
facilities
and
processes.

Characterization
­
Sampling,
monitoring,
and
analysis
 
whether
by
review
of
AK,
nondestructive
examination,
NDA,
RC,
headspace
gas
analysis,
or
chemical
analysis
of
the
volatile
or
semi­
volatile
organic
compounds
or
metals
 
to
identify
and
quantify
the
constituents
of
a
waste
material.

Chemical
compatibility
­
Assessing
the
properties
of
chemicals
in
a
payload
container
(>
1
weight
percent);
there
must
be
no
adverse
safety
or
health
hazards
produced
as
a
result
of
any
mixtures
that
occur.

Completeness
­
The
percentage
of
measurements
made
which
are
judged
to
be
valid
measurements.
The
completeness
goal
is
to
generate
a
sufficient
amount
of
valid
data
based
on
program
needs.
Valid
results
for
analytical,
radioassay,
and
radiography
data
are
those
that
were
obtained
when
the
laboratory
or
testing
facility
demonstrated
that
the
instrumentation
and
method
were
in
control;
that
is,
that
all
calibration,
verification,
interference,
and
zero
matrix
checks
met
acceptance
criteria.
Valid
samples
are
those
collected
and
submitted
for
analysis
that
were
representative
and
met
all
preservation
requirements
upon
arrival
at
the
laboratory.

Compressed
gas
­
Compressed
gases
are
those
materials
defined
as
such
by
49
CFR
Part
173,
Subpart
G.
­
3
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
C­
3
Contact­
handled
transuranic
waste
­
Transuranic
waste
with
a
surface
radiation
dose
equivalent
rate
not
greater
than
200
mrem/
h.

Content
code
­
A
uniform
system
applied
to
waste
forms
to
group
those
with
similar
characteristics
for
purposes
of
shipment
in
the
TRUPACT­
II.

Corrosive/
Corrosivity
­
A
solid
waste
exhibits
corrosivity
if
a
sample
of
the
waste
is
either
aqueous
and
has
a
pH
<
2
or
>
12.5,
or
it
is
a
liquid
and
corrodes
steel
at
a
rate
>
6.35
mm
(
0.250
inch)
per
year
at
a
test
temperature
of
550
(
1300F).
(
40
CFR
§
261.22)

Curie
­
A
unit
of
activity
equal
to
37
billion
(
3.7
X
1010)
disintegrations
per
second.

Disposal
­
Permanent
isolation
of
TRU
waste
from
the
accessible
environment
with
no
intent
of
recovery,
whether
or
not
such
isolation
permits
the
recovery
of
such
waste
(
reference
2,
section
2,
subsection
5).

Dose
conversion
factor
­
A
numerical
factor
used
in
converting
radionuclide
uptake
(
curies)
in
the
body
to
the
resultant
radiation
dose
(
rem).

Dose
equivalent
rate
­
The
radiation
dose
equivalent
delivered
per
unit
time
(
e.
g.,
rem
per
hour).

Fissile
gram
equivalent
­
An
isotopic
mass
of
radionuclide
normalized
to
239Pu.

Fissile
material
­
Any
material
consisting
of
or
containing
one
or
more
radionuclides
that
can
undergo
neutron­
induced
fission
with
neutrons
of
essentially
zero
kinetic
energy
(
e.
g.,
thermal
neutrons)
such
as
233U,
235U,
and
239Pu.

Hazardous
waste
­
Those
wastes
which
are
designated
hazardous
by
EPA
(
or
state)
regulations.
For
a
detailed
description,
see
40
CFR
§
261.3.
Hazardous
wastes
are
listed
in
20.4.1
NMAC,
subpart
II
(
40
CFR
Part
261)
and/
or
exhibit
one
of
the
four
characteristics
in
20.4.1
NMAC,
subpart
II
(
40
CFR
Part
261)
(
i.
e.,
ignitability,
corrosivity,
reactivity,
and
toxicity).

Headspace
­
The
total
contained
volume
of
a
container
minus
the
volume
occupied
by
the
waste
material.

Headspace
gas
­
The
gas
within
the
headspace
of
a
container.

Lower
Limit
of
Detection
­
The
level
of
radioactivity
which,
if
present,
will
yield
a
measured
value
greater
than
the
critical
limit
with
a
95%
probability.
The
critical
limit
is
defined
as
that
value
which
measurements
of
the
background
will
exceed
with
a
5%
probability.

Overpack
­
A
payload
container
placed
around
another
container
to
control
contamination
or
to
enclose
a
damaged
container.
­
4
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
C­
4
Package
­
(
1)
A
packaging
plus
its
contents.
(
2)
The
reusable
Type
B
shipping
container
(
i.
e.,
TRUPACT­
II)
loaded
with
TRU
waste
payload
containers,
which
has
been
prepared
for
shipment
in
accordance
with
the
package
QA
program.
(
3)
In
the
regulations
governing
the
transportation
of
radioactive
materials,
the
packaging,
together
with
its
radioactive
contents,
as
presented
for
transport.

Packaging
­
The
reusable
Type
B
shipping
container
for
transport
of
TRU
waste
payload
containers
(
i.
e.,
TRUPACT­
II).

Packaging
quality
assurance
program
­
A
site­
specific
document
that
defines
the
quality
assurance
and
quality
control
activities
applicable
to
usage
of
the
NRC­
approved
packaging.
This
program
shall
meet
the
requirements
of
10
CFR
Part
71,
Subpart
H.

Payload
container
­
The
outermost
container
(
i.
e.,
drum,
SWB,
or
TDOP)
for
TRU
waste
material
that
is
placed
in
a
reusable
Type
B
shipping
container
(
i.
e.,
TRUPACT­
II)
for
transport.

Payload
container
assembly
­
An
assembly
of
payload
containers,
such
as
a
seven­
pack
of
drums,
that
is
intended
to
be
handled
and
emplaced
in
the
WIPP
as
a
single
unit.

Pipe
overpack
­
A
packaging
configuration
consisting
of
a
vented
cylindrical
pipe
component
surrounded
by
dunnage
within
a
vented
55­
gallon
drum
with
a
rigid
polyethylene
liner
and
vented
lid.

Plutonium
equivalent
activity
­
An
equivalent
radiotoxic
hazard
of
a
radionuclide
normalized
to
239Pu.

Precision
­
A
measure
of
mutual
agreement
among
individual
measurements
of
the
same
property
made
under
prescribed
similar
conditions;
often
expressed
as
a
standard
deviation
or
relative
percent
difference.

Pyrophoric
­
Materials
that
may
ignite
spontaneously
in
air
or
that
emit
sparks
when
scratched
or
struck,
especially
with
materials
such
as
steel.
A
flammable
solid
that,
under
transport
conditions,
might
cause
fires
through
friction
or
retained
heat
or
that
can
be
ignited
readily
and,
when
ignited,
burns
vigorously
and
persistently
so
as
to
create
a
serious
transportation
hazard.
Included
in
the
pyrophoric
definition
are
spontaneously
combustible
materials,
water
reactive
materials,
and
oxidizers.
Examples
of
nonradioactive
pyrophorics
are
organic
peroxides,
sodium
metal,
and
chlorates.

Radioassay
­
Methods
used
to
identify
and
quantify
radionuclides
in
TRU
waste.
Radioassay
includes
NDA
and
RC.

Radiography
­
A
nondestructive
testing
method
that
uses
x­
rays
to
inspect
and
determine
the
physical
form
of
waste.

Radionuclide
­
A
nuclide
that
emits
radiation
by
spontaneous
transformation.
­
5
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
C­
5
Residual
liquid
­
Liquids
in
quantities
of
less
than
1
volume
percent
of
the
waste
payload
container
that
result
from
liquid
residues
remaining
in
well­
drained
internal
containers,
condensation
of
moisture,
and
liquid
separation
resulting
from
sludge/
resin
setting.

Shipper
­
A
TRU
waste
site
that
releases
a
TRUPACT­
II
to
a
carrier
for
shipment.

Shipping
category
­
A
shipping
category
is
defined
by
the
following
parameters:
chemical
composition
of
the
waste
(
waste
type),
gas
generation
potential
of
the
waste
material
type
(
quantified
by
the
g­
value
for
hydrogen),
and
gas
release
resistance
(
type
of
payload
container
and
type
and
maximum
number
of
confinement
layers
used).

Sites
­
Department
of
Energy
TRU
waste
generator/
storage
sites.

Standard
waste
box
­
A
metal
payload
container
authorized
for
use
within
the
TRUPACT­
II
packaging,
that
has
been
tested
by
DOE
to
meet
DOT
Specification
7A
Type
A
requirements.

Ten­
drum
overpack
­
A
metal
payload
container
authorized
for
use
within
the
TRUPACT­
II
packaging,
that
has
been
tested
by
DOE
to
meet
DOT
Specification
7A
Type
A
requirements.

Test
Category
­
Payload
containers
that
do
not
meet
the
analytical
category
limits
are
classified
as
test
category.
(
TRAMPAC,
revision
19,
section
5.2)

Trace
chemicals/
materials
­
Chemicals/
materials
that
occur
individually
in
the
waste
in
quantities
less
than
1
weight
percent.
The
total
quantity
of
trace
chemicals/
materials
not
listed
as
allowed
materials
for
a
given
waste
material
type
in
any
payload
container
is
restricted
to
less
than
5
weight
percent.
(
TRAMPAC,
revision
19,
section
4.3.1)

TRU
isotope
­
An
isotope
of
any
element
having
an
atomic
number
greater
than
uranium
(
i.
e.,
92).

TRU
waste
­
Waste
containing
more
than
100
nCi
of
alpha­
emitting
TRU
isotopes
per
gram
of
waste,
with
half­
lives
greater
than
20
years,
except
for
(
1)
high­
level
radioactive
waste,
(
2)
waste
that
the
Secretary
has
determined,
with
the
concurrence
of
the
Administrator,
does
not
need
the
degree
of
isolation
required
by
the
disposal
regulations,
or
(
3)
waste
that
the
NRC
has
approved
for
disposal
on
a
case­
by­
case
basis
in
accordance
with
10
CFR
Part
61.
(
Land
Withdrawal
Act,
section
2,
subsection
18)

TRU
mixed
waste
­
TRU
waste
that
is
also
a
hazardous
waste
as
defined
by
the
Hazardous
Waste
Act
and
20.4.1.200
NMAC
(
incorporating
40
CFR
§
261.3).
(
Hazardous
Waste
Facility
Permit,
module
I,
section
I.
D.
6)
­
6
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
C­
6
TRUCON
content
codes
­
(
1)
The
document
containing
a
description
of
the
waste
stream,
waste
form,
and
package
configuration
for
each
waste
content
code
authorized
for
shipment
in
TRUPACT­
II
containers.
(
2)
A
type
of
shorthand
representation
of
the
chemical
content
and
physical
waste
form
of
generator
waste
streams
for
use
in
the
transportation
safety
analyses.

TRUPACT­
II
­
An
NRC­
certified
Type
B
transportation
packaging
used
for
transportation
of
CH­
TRU
wastes.

TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
TRAMPAC)
­
The
TRAMPAC
is
the
governing
document
for
payload
shipments
in
the
TRUPACT­
II.
(
TRAMPAC,
section
1.0)

Verification
­
The
act
of
authenticating
or
formally
asserting
the
truth
that
a
process,
item,
data
set,
or
service
is,
in
fact,
that
which
is
claimed.
Data
verification
is
the
process
used
to
confirm
that
all
review
and
validation
procedures
have
been
completed.

Volatile
organic
compounds
­
For
the
purposes
of
the
TRU
waste
program,
those
RCRA­
regulated
VOCs
listed
in
the
WIPP
WAP
and
any
additional
compounds
tentatively
identified
by
VOC
analytical
procedures
used
to
satisfy
program
requirements
(
i.
e.,
any
compound
containing
carbon
and
hydrogen
with
any
other
element
that
has
a
vapor
pressure
of
77.6
mL
of
mercury
(
1.5
psia)
or
greater
under
actual
storage
conditions).

Waste
acceptance
criteria
­
Constraints
(
limits)
on
the
physical,
chemical,
and
radiological
properties
of
TRU
waste
and
its
packaging
as
determined
by
WIPP's
authorization
basis
requirements.
TRU
waste
will
not
be
approved
for
shipment
to
and
disposal
at
the
WIPP
until
it
has
been
certified
as
meeting
these
criteria.
Waste
acceptance
criteria
ensure
that
CH­
TRU
waste
is
managed
and
disposed
of
in
a
manner
that
protects
human
health
and
safety
and
the
environment.

Waste
analysis
plan
­
The
waste
analysis
plan
includes
test
methods,
details
of
planned
waste
sampling
and
analysis,
a
description
of
the
waste
shipment
screening
and
verification
process,
and
a
description
of
the
QA/
QC
program.
Sites
are
required
to
implement
the
applicable
requirements
of
the
WIPP
WAP.
(
Hazardous
Waste
Facility
Permit,
attachment
B)

Waste
characterization
­
The
process
of
determining
that
TRU
waste
meets
the
requirements
of
the
WAC
by
the
acceptable
performance
of
the
activities
defined
by
CBFO­
approved
site­
specific
plans.

Waste
certification
­
Formal
and
documented
declaration
by
sites
that
waste
has
been
characterized
and
meets
the
requirements
of
the
WIPP
WAC.

Waste
stream
­
A
waste
stream
is
waste
material
generated
from
a
single
process
or
from
an
activity
which
is
similar
in
material,
physical
form,
and
hazardous
constituents
(
Hazardous
Waste
Facility
Permit,
attachment
B).
­
1
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
D­
1
APPENDIX
D
Payload
Container
Integrity
­
2
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
D­
2
The
operator
is
to
visually
examine
100%
of
the
payload
container
exterior
to
determine
if
the
payload
container
meets
the
criteria
of
Section
3.2.1.
At
a
minimum,
sites
shall
incorporate
the
questions
and
criteria
contained
in
the
following
checklist
into
applicable
site
procedures.
This
payload
container
inspection
shall
be
performed
and
documented
as
a
part
of
the
TRUPACT­
II
loading
process.
Any
YES
answer
on
the
inspection
checklist
will
result
in
the
operator
discontinuing
the
inspection,
marking
the
payload
container
as
unacceptable
for
shipment,
and
removal
of
the
payload
container
from
the
shippable
inventory.
Before
the
rejected
container
can
be
shipped,
it
must
undergo
appropriate
corrective
actions
(
e.
g.,
evaluation,
repackaging,
overpacking,
etc.),
as
applicable.
All
containers
must
have
an
acceptable
and
complete
inspection
checklist
documenting
that
it
meets
the
DOT
7A
criteria.

CONTAINER
EXAMINATION
DISCUSSION
OF
CRITERIA
COMPLIANCE
Is
the
payload
container
obviously
degraded?
Obviously
degraded
means
clearly
visible
and
potentially
significant
defects
in
the
payload
container
or
payload
container
surface.
YES
NO.

Is
there
evidence
that
the
payload
container
is,
or
has
been,
pressurized?
Pressurization
can
be
indicated
by
a
fairly
uniform
expansion
of
the
sidewalls,
bottom
or
top.
Past
pressurization
can
be
indicated
by
a
notable
outward
deflection
of
the
bottom
or
top.
Verify
that
the
drum
is
not
warped.
YES
NO
­
3
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
D­
3
CONTAINER
EXAMINATION
DISCUSSION
OF
CRITERIA
COMPLIANCE
3.
Is
there
any
potentially
significant
rust
or
corrosion
such
that
wall
thinning,
pin
holes,
or
breaches
are
likely
or
the
load
bearing
capacity
is
suspect?
Rust
shall
be
assessed
in
terms
of
its
type,
extent,
and
location.
Pitting,
pocking,
flaking,
or
dark
coloration
characterizes
potentially
significant
rust
or
corrosion.
This
includes
the
extent
of
the
payload
container
surface
area
covered,
thickness,
and,
if
it
occurs
in
large
flakes
or
built­
up
(
caked)
areas.
Rusted
payload
containers
may
not
be
accepted
if:
 
Rust
is
present
in
caked
layers
or
deposits
 
Rust
is
present
in
the
form
of
deep
metal
flaking,
or
built­
up
areas
of
corrosion
products
In
addition,
the
location
of
rust
should
be
noted;
for
example
on
a
drum:
top
lid;
filter
region;
locking
chine;
top
one­
third,
above
the
second
rolling
hoop;
middle
one­
third,
between
the
first
and
second
rolling
hoops;
bottom
one­
third,
below
the
second
rolling
hoop;
and
on
the
bottom.
Payload
containers
may
still
be
considered
acceptable
if
the
signs
of
rust
show
up
as:
 
Some
discoloration
on
the
payload
container
 
If
rubbed
would
produce
fine
grit
or
dust
or
minor
flaking
(
such
that
wall
thinning
does
not
occur)
YES
NO
4.
Are
any
of
the
following
apparent?
 
wall
thinning
 
pin
holes
 
breaches
Wall
thinning,
pin
holes,
and
breaches
an
be
a
result
of
rust/
corrosion
(
see
discussion
for
#
3).
YES
NO
5.
Are
there
any
split
seams,
tears,
obvious
holes,
punctures
(
of
any
size),
creases,
broken
welds,
or
cracks?
Payload
containers
with
obvious
leaks,
holes
or
openings,
cracks,
deep
crevices,
creases,
tears,
broken
welds,
sharp
edges
or
pits,
are
either
breached
or
on
the
verge
of
being
breached.
Verify
that
there
is
no
warpage
that
could
cause
the
container
to
be
unstable
or
prevent
it
from
fitting
properly
in
the
TRUPA
CT­
II
YES
NO
6.
Is
the
load­
bearing
capacity
suspect?
The
load­
bearing
capacity
could
be
reduced
for
excessive
rust
(
see
discussion
for
#
3),
wall
thinning
(
see
discussion
for
#
4),
breaches,
cracks,
creases,
broken
welds,
etc.
(
see
discussion
for
#
5)
YES
NO
­
4
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
D­
4
CONTAINER
EXAMINATION
DISCUSSION
OF
CRITERIA
COMPLIANCE
7.
Is
the
payload
container
improperly
closed?
Inspect
the
fastener
and
fastener
ring
(
chine)
if
applicable
for
damage
or
excessive
corrosion.
Check
the
alignment
of
the
fastener
to
ensure
that
it
is
in
firm
contact
around
the
entire
lid
and
the
payload
container
will
not
open
during
transportation.
YES
NO
8.
Are
there
any
dents,
scrapes,
or
scratches
that
make
the
payload
container's
structural
integrity
questionable
or
prevent
the
top
and
bottom
surfaces
from
being
parallel?
Deep
gouges,
scratches,
or
abrasions
over
wide
areas
are
not
acceptable.
If
top
and
bottom
surfaces
are
not
parallel,
this
would
indicate
that
the
container
is
warped.
Dents
should
be
less
than
¼
inch
deep
by
3
inches
long
and
between
½
inch
to
6
inches
wide.
All
other
dents
must
be
examined
to
determine
impact
of
structural
integrity
YES
NO
9.
Is
there
discoloration
which
would
indicate
leakage
or
other
evidence
of
leakage
of
material
from
the
payload
container?
Examine
the
payload
container
regions
near
the
filter
vents,
top
lid
fittings,
bottom
fittings,
welds,
seams
and
intersections
of
one
or
more
metal
sheets
or
plates.
Payload
containers
must
be
rejected
if
evidence
of
leakage
is
present
YES
NO
10.
Is
the
payload
container
bulged?
For
the
purposes
of
this
examination,
bulging
is
indicated
by:
 
A
fairly
uniform
expansion
of
the
sidewalls,
bottom,
or
top
(
e.
g.,
in
the
case
of
a
drum,
either
the
top
or
bottom
surface
protrudes
beyond
the
planar
surface
of
the
top
or
bottom
ring,
 
A
protrusion
of
the
side
wall
(
e.
g.,
in
the
case
of
a
drum,
beyond
a
line
connecting
the
peaks
of
the
surrounding
rolling
hoops
or
a
line
between
a
surrounding
rolling
hoop
and
the
bottom
or
top
ring),
or
 
Expansion
of
the
sidewall
(
e.
g.,
in
the
case
of
a
drum,
such
that
it
deforms
any
portion
of
a
rolling
hoop).
YES
NO
­
5
­
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.1,
Revision
2
Issued:
06/
11/
03
Effective:
06/
11/
03
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
D­
5
References
INEEL
Engineering
Design
File
"
Waste
Container
Integrity
Evaluation
for
Storage",
EDF­
RWMC­
705,
September
25,
1996.
Idaho
National
Engineering
and
Environmental
Laboratory,
Idaho
Falls,
ID.

Title
49
CFR
Part
173,
Subpart
475.
"
Quality
Control
Requirements
Prior
to
Each
Shipment
of
Class
7
(
Radioactive)
Materials."
Code
of
Federal
Regulations,
Washington,
D.
C.,
Office
of
the
Federal
Register,
National
Archives
and
Records
Administration.

DOE/
RL­
96­
57,
Section
2.5.5.
"
Test
&
Evaluation
Document
for
the
U.
S.
Department
of
Transportation
Specification
7A
type
to
Packaging.
(
Formerly
WHC­
EP­
0558).
