AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

3
REVISION
LOG
Revision
Number
Date
Approved
Pages
Affected
Description
of
Revision
0
08/
29/
02
All
Initial
issue.
DCR­
2002­
1171.
Document
issue
date
was
08/
29/
02.
DOE/
WIPP
approval
was
received
09/
09/
02
thus
the
change
in
effective
date
to
09/
12/
02.

1
02/
26/
03
Various
DCR­
1821.
Correct
procedure
titles
and
numbers.
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
02/
25/
03
thus
the
change
in
effective
date
to
02/
26/
03.

2
03/
10/
03
12,
153
DCR­
2094.
Added
changes
to
the
training
sections
A­
7
&
B3­
14.
Document
issue
date
was
03/
10/
03.
DOE/
WIPP
approval
was
received
03/
17/
03.
The
change
in
effective
date
is
03/
31/
03.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

4
TABLE
OF
CONTENTS
Section
Page
TITLE
PAGE
1
DOCUMENT
APPROVAL
SHEET
2
REVISION
LOG
3
TABLE
OF
CONTENTS
4
Chapter
Page
A.
INTRODUCTION
10
A­
1
Scope
10
A­
2
Overview
10
A­
3
Description
of
the
Site
11
A­
4
Project
Description
11
A­
5
AMWTP
Organizations
and
Responsibilities
12
A­
6
Hierarchy
of
Documents
12
A­
7
Indocrination
and
Training
12
B.
WASTE
ANALYSIS
PLAN
13
B­
1
Identification
of
TRU
Waste
to
be
Managed
at
the
WIPP
Facility
15
B­
1a
Waste
Stream
Identification
15
B­
1b
Waste
Summary
Category
Groups
and
Hazardous
Waste
Accepted
at
the
WIPP
Facility
16
B­
1c
Waste
Prohibited
at
the
WIPP
Facility
16
B­
1d
Control
of
Waste
Acceptance
18
B­
1e
Waste
Generating
Processes
at
the
WIPP
Facility
(
termed
"
derived
waste")
18
B­
2
Waste
Paramenters
18
B­
3
Characterization
Methods
19
B­
3a
Sampling
and
Analytical
Methods
19
B­
3a(
1)
Headspace
Gas
Sampling
and
Analysis
19
B­
3a(
1)(
i)
Reduced
Sampling
Requirements
for
Homogeneous
Solid
or
Soil/
Gravel
Waste
Streams
with
no
VOC­
Related
Hazardous
Waste
Codes
20
B­
3a(
1)(
ii)
Reduced
Sampling
Requirements
for
Thermally
Treated
Waste
Streams
20
B­
3a(
2)
Homogeneous
Waste
Sampling
and
Analysis
21
B­
3a(
3)
Laboratory
Qualification
21
B­
3b
Acceptable
Knowledge
22
B­
3c
Radiography
and
Visual
Examination
22
B­
3d
Characterization
Techniques
and
Frequency
for
Newly
Generated
and
Retrievably
Stored
Waste
23
B­
3d(
1)
Newly
Generated
Waste
25
B­
3d(
1)(
a)
Sampling
of
Newly
Generated
Homogeneous
Solids
26
B­
3d(
1)(
b)
Sampling
of
Newly
Generated
Soils/
Gravels
27
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

5
TABLE
OF
CONTENTS
(
continued)

Chapter
Page
B­
3d(
2)
Retrievably
Stored
Waste
27
B­
4
Data
Verification
and
Quality
Assurance
28
B­
4a
Data
Generator
and
Site
Project
Level
Requirements
29
B­
4a(
1)
Data
Quality
Objectives
29
B­
4a(
2)
Quality
Assurance
Objectives
30
B­
4a(
3)
Sample
Control
30
B­
4a(
4)
Data
Generation
31
B­
4a(
5)
Data
Verification
31
B­
4a(
6)
Data
Transmittal
32
B­
4a(
7)
Records
Management
32
B­
4b
Waste
Stream
Screening
and
Verification
of
TRU
Waste
33
B1.
WASTE
CHARACTERIZATION
SAMPLING
METHODS
50
B1­
1
Headspace
Gas
Sampling
and
Analysis
Using
an
On­
Line
System
50
B1­
1a
Method
Requirements
50
B1­
1a(
1)
Summary
Category
S5000
Requirements
51
B1­
1a(
2)
Summary
Category
S3000/
S4000
Requirements
52
B1­
1a(
3)
General
Requirements
53
B1­
1a(
4)
Manifold
Headspace
Gas
Sampling
Requirements
55
B1­
1a(
5)
Direct
Canister
Headspace
Gas
Sampling
58
B1­
1a(
6)
Sampling
Heads
58
B1­
1a(
6)(
i)
Sampling
Through
the
Filter
58
B1­
1a(
6)(
ii)
Sampling
Through
the
Drum
Lid
by
Drum
Lid
Punching
59
B1­
1a(
7)(
iii)
Sampling
Through
a
Pipe
Overpack
Container
Filter
Vent
Hole
60
B1­
1b
Quality
Control
61
B1­
1b(
1)
Fields
Blanks
61
B1­
1b(
2)
Equipment
Blanks
62
B1­
1b(
3)
Reference
Standards
63
B1­
1b(
4)
Field
Duplicates
63
B1­
1c
Equipment
Testing,
Inspections,
and
Maintenance
63
B1­
1c(
1)
Headspace
Gas
Sample
Canister
Cleaning
64
B1­
1c(
2)
Sampling
Equipment
Initial
Cleaning
and
Leak­
Check
64
B1­
1c(
3)
Sampling
Equipment
Routine
Cleaning
and
Leak­
Check
64
B1­
1c(
4)
On­
Line
System
Cleaning
After
Field
Reference
Standard
Collection
64
B1­
1c(
5)
Sample
Head
Cleaning
65
B1­
1d
Equipment
Calibration
and
Frequency
65
B1­
2
Sampling
of
Homegeneous
Solids
and
Soil/
Gravel
65
B1­
2a
Methods
Requirements
66
B1­
2a(
1)
Core
Collection
66
B1­
2a(
2)
Sample
Collection
68
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

6
TABLE
OF
CONTENTS
(
continued)

Chapter
Page
B1­
2b
Quality
Control
Requirements
70
B1­
2b(
1)
Co­
located
Samples
70
B1­
2b(
2)
Equipment
Blanks
71
B1­
2b(
3)
Coring
Tool
and
Sampling
Equipment
Cleaning
72
B1­
2c
Equipment
Testing,
Inspection,
and
Maintenance
74
B1­
2d
Equipment
Calibration
and
Frequency
75
B1­
3
Radiography
75
B1­
3a
Methods
Requirements
75
B1­
3b
Quality
Control
77
B1­
3b(
1)
Formal
Training
78
B1­
3b(
2)
On­
the­
Job
Training
78
B1­
3b(
3)
Visual
Examination
81
B1­
3b(
4)
Formal
Training
82
B1­
3b(
5)
On­
the­
Job
Training
82
B1­
4
Custody
of
Samples
83
B1­
5
Sample
Packing
and
Shipping
84
B2.
STATISTICAL
METHODS
USED
IN
SAMPLING
AND
ANALYSIS
103
B2­
1
Approach
for
Statistically
Selecting
Waste
Containers
for
Visual
Examination
(
to
confirm
RTR)
103
B2­
2
Approach
for
Statistically
Selecting
Retrievably
Stored
Waste
Containers
for
Total
(
or
TCLP)
Analysis
104
B2­
2a
Statistical
Selection
of
Containers
for
Totals
Analysis
104
B2­
2b
Statistical
Selection
of
Containers
for
Headspace
Gas
Analysis
106
B2­
3
Upper
Confidence
Limit
for
Statistical
Sampling
107
B2­
3a
Upper
Confidence
Limit
for
Statistical
Solid
Samplimg
107
B2­
3b
Upper
Confidence
Limit
for
Statistical
Headspace
Gas
Sampling
107
B2­
4
Control
Charting
for
Newly
Generated
Waste
Stream
Sampling
108
B3.
QUALITY
ASSURANCE
OBJECTIVES
AND
DATA
VALIDATION
TECHNIQUES
FOR
WASTE
CHARACTERIZATION
SAMPLING
AND
ANALYTICAL
METHODS
112
B3­
1
Validation
Methods
112
B3­
2
Headspace
Gas
Sampling
(
HSGS)
118
B3­
3
Sampling
of
Homogeneous
Solids
and
Soils/
Gravel
120
B3­
4
Radiography
123
B3­
5
Gas
Volatile
Organic
Compound
Analysis
124
B3­
6
Total
Volatile
Organic
Compound
Analysis
126
B3­
7
Total
Semivolatile
Organic
Compound
Analysis
129
B3­
8
Total
Metal
Analysis
133
B3­
9
Acceptable
Knowledge
137
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

7
TABLE
OF
CONTENTS
(
continued)

Chapter
Page
B3­
10
Data
Review,
Validation,
and
Verification
Requirements
138
B3­
10a
Data
Generation
Level
140
B3­
10a(
1)
Independent
Technical
Review
(
ITR)
141
B3­
10a(
2)
Technical
Supervisor
Signature
Release
142
B3­
10a(
3)
QA
Representative
Signature
Release
143
B3­
10b
Project
Level
143
B3­
10b(
1)
SQAO
Signature
Review
and
Release
of
Batch
Data
Reports
144
B3­
10b(
2)
SPM
Signature
Release
of
Batch
Data
Reports
145
B3­
10b(
3)
Prepare
SQAO
Summary
and
Data
Validation
Summary
145
B3­
10b(
4)
Prepare
Waste
Stream
Characterization
Package
146
B3­
10c
CBFO
Level
146
B3­
11
Reconciliation
with
Data
Quality
Objectives
146
B3­
11a
Reconciliation
at
the
Project
Level
146
B3­
11b
Reconciliation
at
the
CBFO'
Level
148
B3­
12
Data
Reporting
Requirements
148
B3­
12a
Data
Generation
Level
to
the
Project
Level
148
B3­
12b
Project
Level
to
CBFO
Level
149
B3­
12b(
1)
Waste
Stream
Profile
Form
149
B3­
12b(
2)
Characterization
Information
Summary
150
B3­
12b(
3)
Waste
Stream
Characterization
Package
151
B3­
12b(
4)
WIPP
Waste
Information
System
(
WWIS)
Data
Reporting
151
B3­
13
Nonconformances
151
B3­
14
Special
Training
Requirements
and
Certification
153
B3­
15
Change
to
Plans
and
Procedures
153
B4.
TRU
WASTE
CHARACTERIZATION
USING
ACCEPTABLE
KNOWLEDGE
176
B4­
1
Introduction
176
B4­
2
Acceptable
Knowledge
Documentation
176
B4­
2a
Required
TRU
Waste
Management
Program
Information
177
B4­
2b
Required
TRU
Waste
Stream
Information
178
B4­
2c
Supplemental
Acceptable
Knowledge
Documentation
181
B4­
3
Acceptable
Knowledge
Training,
Procedures
and
Other
Requirements
182
B4­
3a
Qualification
and
Training
Requirements
182
B4­
3b
Acceptable
Knowledge
Assembly,
Compilation,
and
Confirmation
Procedures
and
Required
Administrative
Controls
183
B4­
3b(
1)
Procedures
Used
to
Assemble
the
Acceptable
Knowledge
Record
184
B4­
3b(
2)
Procedures
Used
to
Compile
the
Acceptable
Knowledge
Record
185
B4­
3b(
3)
Procedures
Used
to
Ensure
Unacceptable
Waste
is
Identified
and
Segregrated
185
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

8
TABLE
OF
CONTENTS
(
continued)

Chapter
Page
B4­
3b(
4)
Procedures
Used
to
Evaluate
Acceptable
Knowledge,
Resolve
Discrepancies,
Assign
Hazardous
Waste
Numbers,
etc.
185
B4­
3b(
5)
Procedures
Used
to
Identify
Hazardous
Waste
185
B4­
3b(
6)
Procedures
Used
to
Confirm
Acceptable
Knowledge
and
to
Re­
Evaluate
Acceptable
Knowledge
185
B4­
3b(
7)
Procedures
Used
to
Cross­
Reference
to
the
Applicable
Waste
Summary
Category
Group
186
B4­
3b(
8)
Procedures
Used
to
Ensure
that
Audit
Results
are
Available
186
B4­
3b(
9)
Procedures
Used
for
Administrative
Control
186
B4­
3c
Criteria
for
Assembling
an
Acceptable
Knowledge
Record
and
Delineating
the
Waste
Stream
187
B4­
3d
Requirements
for
Confirmation
of
Acceptable
Knowledge
187
B4­
3d(
1)
Re­
Evaluation
Based
on
RTR
and
Visual
Examination
188
B4­
3d(
2)
TRU
Heterogeneous
Debris
189
B4­
3d(
3)
Head
Space
Gas
Sampling
189
B4­
3d(
4)
Homogeneous
Solids
and
Soil/
Gravel
190
B4­
3e
Acceptable
Knowledge
Data
Quality
Requirements
191
B4­
4
Additional
Final
Confirmation
of
Acceptable
Knowledge
at
the
WIPP
Facility
193
B5.
QUALITY
ASSURANCE
PROJECT
PLAN
REQUIREMENTS
195
B5­
1
Site­
Specific
Quality
Assurance
Project
Plan
195
B5­
2
Document
Review,
Approval,
and
Control
196
B6.
AMWTP
AUDIT
AND
SURVEILLANCE
PROGRAM
197
B6­
1
CBFO
Audit
Conduct
197
B6­
2
Internal
Management
Assessments
and
Independent
Surveillances
197
C.
RECORDS
PROCESSING
198
D.
REFERENCES
198
D­
1
AMWTP
Documents
198
D­
2
External
References
199
E.
Glossary
200
E­
1
Acronyms
and
Abbreviations
200
E­
2
Definitions
206
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

9
TABLE
OF
CONTENTS
(
continued)

Chapter
Page
FIGURES
AND
TABLES
Page
Table
B­
1,
Summary
of
Hazardous
Waste
Characterization
Requirements
for
Transuranic
Mixed
Waste
.........................
35
Table
B­
2,
Maximum
Allowable
VOC
Room­
Averaged
Headspace
Concentration
Limits
(
ppmv)
...................................
38
Table
B­
3,
Headspace
Gas:
Target
Analyte
List
and
Methods
............................................................................................
39
Table
B­
4,
Required
Organic
Analyses
and
Test
Methods
Organized
by
Organic
Analytical
Groups
................................
40
Table
B­
5,
Summary
of
Sample
Preparation
and
Analytical
Methods
for
Metals
...............................................................
41
Table
B­
6,
Summary
of
Parameters,
Characterization
Methods,
and
Rationale
for
CH
Transuranic
Waste........................
42
Table
B­
7,
Required
Program
Records
Maintained
in
AMWTP
Project
Files.....................................................................
43
Table
B­
8,
WIPP
Waste
Information
System
Data
Fields
..................................................................................................
44
Figure
B­
1,
WIPP
Waste
Stream
Profile
Form
(
example
only)
...........................................................................................
45
Figure
B­
2,
Data
Collection
Design
for
Characterization
of
Newly
Generated
Waste
........................................................
47
Figure
B­
3,
Data
Collection
Design
for
Characterization
of
Retrievably
Stored
Waste
......................................................
48
Figure
B­
4,
TRU
Mixed
Waste
Screening
Flow
Diagram
...................................................................................................
49
Table
B1­
1,
Gas
Sample
Requirements
...............................................................................................................................
86
Table
B1­
2,
Headspace
Gas:
Summary
of
Field
Quality
Control
Sample
Frequencies
.......................................................
86
Table
B1­
3,
Headspace
Gas:
Summary
of
Field
Quality
Control
Sample
Acceptance
Criteria...........................................
87
Table
B1­
4,
Sample
Handling
Requirements
for
Homogeneous
Solids
and
Soil/
Gravel.....................................................
87
Table
B1­
5,
Headspace
Gas
Drum
Age
Criteria
Sampling
Scenarios..................................................................................
88
Table
B1­
6,
Scenario
1
Drum
Age
Criteria
(
in
days)
Matrix...............................................................................................
89
Table
B1­
7,
Scenario
2
Drum
Age
Criteria
(
in
days)
Matrix...............................................................................................
90
Table
B1­
8,
Scenario
3
Packaging
Configuration
Groups
...................................................................................................
91
Table
B1­
9,
Scenerio
3
Drum
Age
Criteria
(
in
days)
Matrix
for
S5000
Waste
by
Packaging
Configuration
Group...........
94
Table
B1­
10,
Scenerio
3
Drum
Age
Criteria
(
in
days)
Matrix
for
S3000
and
S4000
Waste
by
Packaging
Configuration
Group
...............................................................................................................................................................
97
Figure
B1­
1,
Headspace
Gas
Drum
Age
Criteria
Sampling
Scenario
Selection
Process
.....................................................
100
Figure
B1­
2,
Example
of
the
Chain­
of­
Custody/
Sample
Analysis
Request
(
WIPP)............................................................
101
Figure
B1­
3,
Overall
Programmatic
Approach
to
Visual
Examination
of
the
Waste
for
Confirmation
of
RTR..................
102
Table
B2­
1,
Number
of
Waste
Containers
Requiring
Visual
Examination..........................................................................
110
Figure
B2­
1,
Statistical
Approach
to
Sampling
and
Analysis
of
Waste
Streams
of
Retrievably
Stored
Homogeneous
Solids
and
Soil/
Gravel............................................................................................................
111
Table
B3­
1,
Waste
Material
Parameters
and
Descriptions...................................................................................................
154
Table
B3­
2,
Gas
Volatile
Organic
Compounds
Target
Analyte
List
and
Quality
Assurance
Objectives.............................
155
Table
B3­
3,
Summary
of
Laboratory
Quality
Control
Samples
and
Frequencies
for
Gas
Volatile
Organic
Compound
Analysis
.........................................................................................................................................................
156
Table
B3­
4,
Volatile
Organic
Compounds
Target
Analyte
List
and
Quality
Assurance
Objectives....................................
157
Table
B3­
5,
Summary
of
Laboratory
Quality
Control
Samples
and
Frequencies
for
Volatile
Organic
Compound
Analysis
.........................................................................................................................................................
159
Table
B3­
6,
Semi­
Volatile
Organic
Compound
Target
Analyte
List
and
Quality
Assurance
Objectives
............................
162
Table
B3­
7,
Summary
of
Laboratory
Quality
Control
Samples
and
Frequencies
for
Semi­
Volatile
Organic
Compound
Analysis.......................................................................................................................................
163
Table
B3­
8,
Metals
Target
Analyte
List
and
Quality
Assurance
Objectives........................................................................
165
Table
B3­
9,
Summary
of
Laboratory
Quality
Control
Samples
and
Frequencies
for
Metal
Analysis
.................................
166
Table
B3­
10,
Minimum
Training
and
Qualification
............................................................................................................
168
Table
B3­
11,
Testing
Batch
Data
Report
Contents..............................................................................................................
169
Table
B3­
12,
Testing
Batch
Data
Report
Contents..............................................................................................................
171
Table
B3­
13,
Analytical
Batch
Data
Report
Contents
.........................................................................................................
174
Table
B3­
14,
Data
Reporting
Flags
.....................................................................................................................................
175
Table
B5­
1,
Minimum
Requirements
for
Review,
Approval,
Implementation
and
Control
of
QAPjP................................
196
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

10
A.
INTRODUCTION
The
Advanced
Mixed
Waste
Treatment
Project
(
AMWTP)
disposes
of
contact­
handled
transuranic
(
CH­
TRU)
waste
at
the
Waste
Isolation
Pilot
Plant
(
WIPP).
The
AMWTP
has
developed
this
Quality
Assurance
Project
Plan
(
QAPjP)
to
comply
with
the
WIPP
Hazardous
Waste
Facility
Permit,
Attachment
B,
Waste
Analysis
Plan
(
WIPP­
WAP).

In
this
QAPjP,
the
term
TRU
waste
includes
TRU
and
TRU­
mixed
waste.
The
structure
of
this
document
parallels
the
structure
of
the
WIPP­
WAP,
and
the
document
complies
with
quality
requirements
of
the
United
States
(
U.
S.)
Department
of
Energy
(
DOE)
Carlsbad
Area
Office
(
CAO)
Quality
Assurance
Program
Document
(
QAPD)
(
CAO­
94­
1012).

A­
1
Scope
This
QAPjP
applies
only
to
contact­
handled
(
CH)
TRU
waste
and
describes
how
the
requirements
of
the
WIPPWAP
are
met
at
the
AMWTP.
The
Site
Project
Manager
(
SPM)
will
ensure
any
conflicts
between
this
QAPjP
and
any
existing
WIPP­
WAP
requirements
are
resolved.

This
QAPjP
identifies
the
quality
of
data
necessary
and
the
procedures
developed
by
the
AMWTP
to
attain
and
maintain
quality.
The
SPM
will
review
this
QAPjP
annually
and
revise
the
document,
as
necessary,
to
incorporate
lessons
learned
during
waste
characterization
activities
and
any
changes
made
to
source
requirements
documents
(
WIPP­
WAP).

A­
2
Overview
The
AMWTP
is
designed,
built,
and
operated
by
BNFL
Inc.
under
a
privatized,
but
non­
commercial,
contract
with
the
United
States
(
U.
S.)
Department
of
Energy
(
DOE)
and
is
located
at
the
Idaho
National
Engineering
and
Environmental
Laboratory's
(
INEEL)
Radioactive
Waste
Management
Complex
(
RWMC).

The
AMWTP
plans
to
dispose
of
approximately
65,000
m3
of
CH­
TRU
waste
at
the
WIPP.
TRU
waste
to
be
processed
at
the
AMWTP
is
currently
stored
in
drums,
boxes,
and
bins
in
the
Transuranic
Storage
Area
(
TSA)
Retrieval
Enclosure
(
RE)
and
in
Type
II
storage
modules
at
the
RWMC.

The
AMWTP
has
the
capability
of
treating
specific
waste
streams
to
be
retrieved
from
the
TSA­
RE
and
may
treat
other
applicable
INEEL
and
DOE
national
waste
streams.
The
majority
of
TRU
waste
within
the
TSA­
RE
is
CHTRU
Although
some
remote­
handled
TRU
waste
will
be
encountered
during
the
retrieval
operations,
the
remotehandled
(
RH)
TRU
waste
will
be
segregated
from
the
CH­
TRU
and
will
not
be
shipped
to
the
WIPP
for
disposal
by
BNFL
Inc.

Approximately
95%
of
the
TRU
waste
stored
at
the
RWMC
contains
hazardous
waste
regulated
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
Mixed
waste
refers
to
waste
that
is
both
radioactive
and
contaminated
by
hazardous
constituents,
and
is
regulated
by
both
the
Atomic
Energy
Act
and
RCRA.
Some
of
the
waste
stored
at
the
RWMC
may
also
contain
Toxic
Substance
Control
Act
(
TSCA)­
regulated
material
such
as
polychlorinated
biphenyls
(
PCBs)
and
asbestos.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

11
Capabilities
established
to
support
the
TRU
waste
management
mission
include:
storage
facilities;
preliminary
characterization
(
nondestructive
examination
(
NDE)
and
assay
(
NDA)
systems;
intrusive
waste
examination,
sampling
and
analysis
of
waste
forms),
treatment,
as
appropriate,
and
transportation.
Chemical
analysis
of
homogeneous
solids
is
performed
at
the
INEEL
Analytical
Laboratories
Department
(
ALD).

A­
3
Description
of
the
Site
The
AMWTP
is
located
in
southeast
corner
of
the
INEEL.
The
INEEL,
located
approximately
30
miles
west
of
Idaho
Falls,
encompasses
900
square
miles.
Facilities
supporting
characterization,
treatment,
certification,
and
transportation
activities
are
located
within
the
INEEL
at
the
RWMC,
and
Idaho
Nuclear
Technology
and
Engineering
Center
(
INTEC).

A­
4
Project
Description
Personnel
characterize
TRU
waste
on
a
waste
stream
basis.
A
waste
stream
is
defined
as
waste
material
generated
from
a
single
process
or
activity
similar
in
material,
physical
form,
and
hazardous
constituents.
The
AMWTP
personnel
characterize
TRU
waste
by
obtaining
chemical,
radiological,
and
physical
data
per
this
QAPjP.
Radiological
data
are
obtained
as
described
in
Management
Procedure
(
MP)­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.

Once
a
waste
stream,
or
an
initial
portion
of
the
waste
stream
(
i.
e.,
waste
stream
lot),
has
been
identified
using
acceptable
knowledge
(
AK),
characterization
information
must
be
developed
in
order
to
complete
and
submit
the
WIPP
Waste
Stream
Profile
Form
(
WSPF)
to
the
U.
S.
DOE­
Carlsbad
Field
Office
(
CBFO)
for
approval.
Waste
characterization
methods
used
for
completing
the
WSPF
include
AK,
Headspace
Gas
Sampling
(
HSGS)
and
analysis,
homogeneous
solids
waste
sampling
and
analysis,
radioassay
(
RA),
real­
time
radiography
(
RTR),
and
visual
examination
(
VE).
Radioassay
characterization
is
covered
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.
Data
generated
by
these
methods
are
assessed
on
a
waste
stream
basis
or
lot.
For
each
waste
stream
characterized,
the
SPM
determines
if
sufficient
data
have
been
collected
to
determine
the
waste
parameters
required
for
completion
of
the
WSPF.
After
a
WSPF
has
been
submitted
to
and
approved
by
CBFO,
characterization
activities
continue
on
subsequent
portions
of
the
waste
stream
to
verify
consistency
with
the
WSPF.

Personnel
use
the
waste
description
nomenclature
outlined
in
DOE/
LLW­
217,
DOE
Waste
Treatability
Group
Guidance.
The
nomenclature
includes
three
broad
waste
summary
categories
of
waste:

 
homogeneous
solids
(
summary
category
S3000)

 
soil/
gravel
(
summary
category
S4000)

 
debris
waste
(
summary
category
S5000).

The
Waste
Summary
Category
describes
the
physical
form
of
the
waste
and
is
used
to
determine
characterization
requirements.
Waste
Summary
Categories
are
broken
out
into
more
specific
categories
referred
to
as
Waste
Matrix
Codes.

Table
B­
1
is
a
summary
of
hazardous
waste
characterization
requirements
to
be
determined
by
the
various
characterization
activities
and
the
techniques
to
be
used.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

12
A­
5
AMWTP
Organizations
and
Responsibilities
The
AMWTP
TRU
Waste
Program
organization,
the
project
level
positions,
and
their
primary
responsibilities
are
detailed
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.

A­
6
Hierarchy
of
Documents
The
program
documents
used
for
demonstrating
compliance
with
CBFO
requirements
are
described
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.

A­
7
Indoctrination
and
Training
The
management
of
each
organization
is
responsible
for
ensuring
personnel
assigned
meet
the
training
requirements
stated
in
the
WIPP­
WAP.
MP­
TRUW­
14.20,
AMWTP
Training
Implementation
Matrix,
implements
the
training
plan
for
AMWTP.
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification,
specifically
addresses
the
requirements
of
the
WIPP­
WAP
and
this
QAPjP
for
education,
experience,
training
and
qualification
of
AMWTP
participants.
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification,
implements
the
minimum
training
and
qualification
requirements
of
Table
B3­
10.

A
WIPP­
WAP
orientation
class
provides
participants
with
information
on
scope,
purpose
and
objectives
of
the
program,
and
reference
information
on
specific
quality
assurance
objectives
(
QAOs)
for
their
assigned
tasks.
MPRTQP
14.4,
Personnel
Qualification
and
Certification,
requires
that
all
assigned
personnel
complete
this
indoctrination
course.

Training
and
qualification
requirements
of
AMWTP
participants
are
identified
in
qualification
packages
or
Individual
Training
Plans
(
ITPs).
Qualification
packages
are
established
for
facility
personnel
involved
with
mixed
waste
handling,
management,
and
operations
at
the
AMWTP.
A
qualification
package
measures
education,
training,
or
experience
of
an
individual
against
standards
or
tests
that
demonstrate
an
individual
is
able
to
perform
a
function.
The
method
used
to
qualify
an
individual
is
described
in
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.
An
ITP
is
prepared
in
accordance
with
MP­
RTQP­
14.1,
Preparation
and
Administration
of
Individual
Training
Plans.
At
a
minimum,
the
ITP
identifies
the
job/
position
description,
qualifications,
and
minimum
training
requirements
for
achieving
and
maintaining
required
qualification
and
certification
for
the
position.
The
ITP
also
serves
as
a
checklist
to
ensure
training
record
completeness.

MP­
RTQP­
14.6,
Job
and
Training
Needs
Analysis,
requires
completion
of
job
analyses
for
each
job
position
responsible
for
TRU
waste
characterization
tasks
and
activities.
This
position
job
analysis
documents
the
assessment
of
the
position
description
and
the
functions,
tasks,
and
training
involved
in
the
job.
The
position
job
analysis
yields
requirements
for
the
education
and
experience
of
assigned
personnel
and
training
needs
assessment,
which
contains
the
training
and
qualification
requirements
for
the
position.
The
job
analysis
and
training
needs
assessment
are
periodically
reviewed
to
identify
changes
in
requirements
and
additional
necessary
training.

Management
evaluates
the
resumes
of
assigned
personnel,
and
personnel
who
change
positions
or
are
assigned
to
short­
term
or
temporary
work.
Management
documents
that
personnel
meet
the
education
and
experience
requirements
in
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification,
MP­
TRUW­
8.28,
Project
Level
Administrative
Controls
for
Analytical
Laboratory
Department
and
MP­
ADMIN­
1.6,
AMWTP
Recruitment,
Selection,
and
Hiring
of
Personnel.
Completion
of
the
training
and
qualification
requirements,
as
well
as
continuing
training
to
ensure
that
job
proficiency
is
maintained
by
participants,
is
reviewed
by
management
and
training
program
personnel
to
ensure
personnel
maintain
proficiency.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

13
B.
WASTE
ANALYSIS
PLAN
Introduction
and
Highlights
The
AMWTP
disposes
of
TRU
waste
at
the
WIPP
facility,
and
has
developed
this
document
to
comply
with
the
applicable
requirements
of
the
WIPP­
WAP
and
the
WIPP
Waste
Acceptance
Criteria
(
WAC).
In
this
document,
the
term
TRU
waste
includes
TRU
and
TRU­
mixed
waste.

TRU
waste
is
designated
as
either
CH
or
RH,
based
on
the
radiological
dose
rate
at
the
surface
of
the
waste
container.
RH­
TRU
wastes
(
i.
e.,
TRU
waste
with
a
surface
dose
rate
of
200
millirem
per
hour
or
greater)
will
be
segregated
from
CH­
TRU
waste
and
will
not
be
shipped
to
the
WIPP
facility
for
disposal
by
BNFL
Inc.
The
hazardous
components
of
the
TRU
waste
to
be
shipped
for
disposal
at
the
WIPP
facility
from
AMWTP
are
designated
in
the
WIPP
Hazardous
Waste
Permit,
Attachment
O.

Retrievably
stored
waste
is
defined
as
TRU
waste
generated
before
New
Mexico
Environment
Department
(
NMED)
notifies
the
WIPP
facility,
by
approval
of
the
final
audit
report,
that
the
characterization
requirements
of
the
WIPP­
WAP
have
been
implemented
appropriately.
Newly
generated
waste
is
defined
as
TRU
waste
that
is
generated
after
NMED
approves
the
final
audit
report
for
AMWTP.
Acceptable
knowledge
(
AK)
is
assembled
for
both
the
retrievably
stored
and
newly
generated
waste.
Retrievably
stored
TRU
waste
will
be
characterized
on
an
ongoing
basis,
as
the
waste
is
retrieved.
Newly
generated
TRU
waste
is
typically
characterized
as
it
is
generated,
although
some
characterization
occurs
post­
generation.
Waste
characterization
requirements
for
retrievably
stored
and
newly
generated
TRU
wastes
differ,
as
discussed
in
Sections
B­
3d(
l)
and
B­
3d(
2)
of
this
document.

Characterization
requirements
for
individual
containers
of
TRU
waste
are
specified
on
a
waste
stream
basis.
A
waste
stream
is
defined
as
waste
material
generated
from
a
single
process
or
from
an
activity
that
is
similar
in
material,
physical
form,
and
hazardous
constituents.
Waste
streams
are
grouped
by
Waste
Matrix
Code
Groups
that
relate
to
the
physical
and
chemical
properties
of
the
waste.
The
AMWTP
uses
the
characterization
techniques
described
in
the
WIPP­
WAP
to
assign
appropriate
Waste
Matrix
Code
Groups.

The
Waste
Matrix
Code
Groups
are
solidified
inorganics,
solidified
organics,
salt
waste,
soils,
lead/
cadmium
metal,
inorganic
nonmetal
waste,
combustible
waste,
graphite,
filters,
heterogeneous
debris
waste,
and
uncategorized
metal.
Initially
the
Waste
Matrix
Code
Groups
are
categorized
into
the
three
broad
Summary
Category
Groups
that
are
related
to
the
final
physical
form
of
the
wastes.
Waste
characterization
requirements
for
these
Summary
Category
Groups
are
specified
separately
in
Section
B­
2
of
this
document.
Each
of
the
three
broad
groups
is
described
below.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

14
 
S3000
­
Homogeneous
Solids
Homogeneous
solids,
or
solid
process
residues,
are
defined
as
solid
materials,
excluding
soil,
that
do
not
meet
the
NMED
criteria
for
classification
as
debris
(
20
NMAC
4.1.800
(
incorporating
40
Code
of
Federal
Regulations
(
CFR)
§
268.2[
g]
and
[
h])).
Included
in
the
series
of
solid
process
residues
are
inorganic
process
residues,
inorganic
sludges,
salt
waste,
and
pyrochemical
salt
waste.
Other
waste
streams
are
included
in
this
Summary
Category
Group
based
on
the
specific
waste
stream
types
and
final
waste
form.
This
Summary
Category
Group
is
expected
to
contain
toxic
metals
and
spent
solvents.
This
category
includes
wastes
that
are
at
least
50
percent
by
volume
solid
process
residues.

 
S4000
­
Soils/
Gravel
This
Summary
Category
Group
includes
S4000
waste
streams
that
are
at
least
50
percent
by
volume
soil/
gravel.
This
Summary
Category
Group
is
expected
to
contain
toxic
metals.
Soils/
gravel
are
further
categorized
by
the
amount
of
debris
included
in
the
matrix.

 
S5000
­
Debris
Wastes
This
Summary
Category
Group
includes
heterogeneous
waste
that
is
at
least
50
percent
by
volume
materials
that
meet
the
criteria
specified
in
20
NMAC
4.1.800
[
incorporating
40
CFR
§
268.2
(
g)].

Debris
means
solid
material
exceeding
a
2.36
inch
(
60
millimeter)
particle
size
that
is
intended
for
disposal
and
that
is:

1.
a
manufactured
object,
or
2.
plant
or
animal
matter,
or
3.
natural
geologic
material.

Particles
smaller
than
2.36
inches
in
size
may
be
considered
debris
if
the
debris
is
a
manufactured
object
and
if
it
is
not
a
particle
of
S3000
or
S4000
material.

If
a
waste
does
not
include
at
least
50
percent
of
any
given
category
by
volume,
characterization
shall
be
performed
using
the
waste
characterization
process
required
for
the
category
constituting
the
greatest
volume
of
waste
for
that
waste
stream
(
see
Section
B­
3d).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

15
All
waste
characterization
activities
specified
in
this
QAPjP
shall
be
carried
out
at
the
AMWTP
and,
as
applicable,
at
the
WIPP
facility
in
accordance
with
the
WIPP­
WAP.
CBFO
will
audit
generator/
storage
site
waste
characterization
programs
and
activities
as
described
in
Section
B­
3.
Waste
characterization
activities
at
the
AMWTP
include
the
following,
although
not
all
these
techniques
will
be
used
on
each
container,
as
discussed
in
Section
B­
3:

 
Radiography,
which
is
an
x­
ray
technique
to
determine
physical
contents
of
containers
 
Visual
examination
of
opened
containers
as
an
alternative
way
to
determine
their
physical
contents
or
to
verify
Radiography
results
 
Headspace­
gas
sampling
to
determine
VOC
content
of
gases
in
the
void
volume
of
the
containers
 
Sampling
and
analysis
of
waste
forms
that
are
homogeneous
and
can
be
representatively
sampled
to
determine
concentrations
of
hazardous
waste
constituents
and
toxicity
characteristic
contaminants
of
waste
in
containers
 
Compilation
of
acceptable
knowledge
documentation
into
an
auditable
record.

Once
the
required
waste
characterization
is
complete,
the
AMWTP
completes
a
WSPF
to
document
the
results
of
their
characterization
activities
(
Section
B­
1d).
The
WSPF
and
the
Characterization
Information
Summary
for
the
waste
stream
resulting
from
waste
characterization
activities
shall
be
transmitted
to
the
CBFO,
reviewed
for
completeness,
and
screened
for
acceptance
prior
to
loading
any
TRU
mixed
waste
into
the
Contact
Handled
Packaging,
as
described
in
Section
B­
4.
Only
TRU
waste
that
has
been
characterized
in
accordance
with
this
WIPPWAP
and
meets
the
Treatment
Storage
Disposal
Facility
(
TSDF)­
WAC
will
be
accepted
at
the
WIPP
facility
for
disposal.

In
the
event
CBFO
requests
detailed
information
on
a
waste
stream,
the
AMWTP
will
provide
a
Waste
Stream
Characterization
Package
[
Section
B3­
12b(
3)].
For
each
waste
stream,
this
package
will
include
the
WSPF,
the
Characterization
Information
Summary,
and
the
complete
AK
summary.
The
Waste
Stream
Characterization
Package
will
also
include
specific
Batch
Data
Reports
and
raw
analytical
data
associated
with
waste
container
characterization
as
requested
by
CBFO.

B­
1
Identification
of
TRU
Waste
to
be
Managed
at
the
WIPP
Facility
B­
1a
Waste
Stream
Identification
TRU
waste
destined
for
disposal
at
WIPP
is
characterized
on
a
waste
stream
basis.
The
AMWTP
delineates
waste
streams
using
AK.
Required
AK
is
specified
in
Section
B­
3b
and
B4.
If
AK
for
retrievably
stored
waste
does
not
comply
with
these
requirements
(
e.
g.,
heterogeneous
Debris
Waste
in
Summary
Category
S5000),
the
waste
is
reexamined
(
and
characterized)
in
the
same
manner
as
newly
generated
waste.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

16
All
of
the
waste
within
a
waste
stream
may
not
be
available
for
sampling
and
analysis
at
one
time.
In
these
instances,
the
waste
streams
may
be
divided
into
waste
stream
lots,
per
MP­
TRUW­
8.11,
Data
Reconciliation,
based
on
staging,
transportation
or
handling
issues.
Characterization
activities
are
then
undertaken
on
a
waste
stream
lot
basis
as
needed.
A
WSPF
need
not
be
submitted
for
subsequent
waste
lots
unless
warranted
by
the
characterization
information.

B­
1b
Waste
Summary
Category
Groups
and
Hazardous
Waste
Accepted
at
the
WIPP
Facility
Once
a
waste
stream
has
been
delineated,
a
Waste
Matrix
Code
is
assigned
to
the
waste
stream
based
on
the
physical
form
of
the
waste.
Waste
streams
are
then
assigned
to
one
of
three
broad
Summary
Category
Groups:
S3000­
Homogeneous
Solids,
S4000­
Soils/
Gravel,
and
S5000­
Debris
Wastes.
These
Summary
Category
Groups
are
used
to
determine
further
characterization
requirements.

The
AMWTP
ships
only
those
TRU
waste
streams
which
have
U.
S.
Environmental
Protection
Agency
(
EPA)
Hazardous
Waste
Numbers
(
HWNs)
already
listed
on
the
WIPP
Hazardous
Waste
Permit,
Attachment
O.
Some
of
the
waste
may
also
be
identified
by
unique
state
hazardous
waste
codes
which
are
acceptable
at
the
WIPP
as
long
as
the
TSDF­
WAC
criteria
are
met.
The
AWMTP
will
perform
characterization
of
all
waste
streams
as
required
by
the
WIPP­
WAP.
If
new
EPA
HWNs
are
identified
during
the
characterization
process,
those
wastes
will
not
be
shipped
for
disposal
to
the
WIPP
facility
until
the
EPA
HWN
has
been
added
to
the
permit
and
WSPF.

B­
1c
Waste
Prohibited
at
the
WIPP
Facility
The
following
TRU
waste
are
prohibited
at
WIPP
and
therefore
these
wastes
will
not
be
shipped
to
the
WIPP
facility
for
disposal:

 
Liquid
waste
(
waste
shall
contain
as
little
residual
liquid
as
is
reasonably
achievable
by
pouring,
pumping
and/
or
aspirating,
and
internal
containers
shall
contain
less
than
1
inch
or
2.5
centimeters
of
liquid
in
the
bottom
of
the
container).
Total
residual
liquid
in
any
payload
container
(
e.
g.,
55­
gallon
drum
or
standard
waste
box)
may
not
exceed
1
percent
volume
of
that
container.
(
Refer
to
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste).
(
Payload
Containers
with
U134
waste
shall
have
no
detectable
liquid)

 
Non­
radionuclide
pyrophoric
materials
(
refer
to
MP­
TRUW­
8.1).

 
Hazardous
wastes
not
occurring
as
co­
contaminants
with
TRU
waste
[
non­
mixed
hazardous
waste
(
refer
to
MP­
TRUW­
8.1)].

 
Wastes
incompatible
with
backfill,
seal
and
panel
closures
materials,
container
and
packaging
materials,
shipping
container
materials,
or
other
wastes
(
refer
to
MP­
TRUW­
8.1).

 
Wastes
containing
explosives
or
compressed
gases
(
refer
to
MP­
TRUW­
8.1).

 
Wastes
with
PCB
concentrations
equal
to
or
greater
than
50
parts­
per­
million
(
ppm)
where
the
resulting
concentration
(
i.
e.,
below
50
ppm)
is
not
the
result
of
dilution,
or
leaks
or
spills
of
PCBs
in
concentrations
over
50
ppm
(
refer
to
MP­
TRUW­
8.1).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

17
 
Wastes
exhibiting
the
characteristic
of
ignitability,
corrosivity,
or
reactivity
[
EPA
HWNs
D001,
D002,
or
D003
(
refer
to
MP­
TRUW­
8.1)].

 
RH­
TRU
waste
[
waste
with
a
surface
dose
rate
of
200
millirem
per
hour
or
greater
(
refer
to
MP­
TRUW­
8.1)].

 
Any
waste
container
which
does
not
have
Volatile
Organic
Compounds
(
VOC)
concentration
values
available
for
the
headspace
[
refer
to
Section
B­
3a(
1)
of
this
document].

 
Any
waste
container
which
has
not
undergone
either
radiographic
examination
or
VE
(
refer
to
Section
B­
3c
and
Section
Bl­
3
of
this
document).

 
Any
waste
container
from
a
waste
stream
which
has
not
been
preceded
by
an
appropriate,
certified
WSPF
(
refer
to
Section
B­
ld
of
this
document
and
MP­
TRUW­
8.14,
Preparation
of
the
Waste
Stream
Profile
Forms).

Before
shipping
a
container
holding
TRU
waste
to
the
WIPP
facility,
the
AMWTP
examines
the
RTR
or
VE
data
records
(
refer
to
Section
B­
4)
to
verify
that
the
container
holds
no
unvented
compressed
gas
containers
and
that
residual
liquid
does
not
exceed
1
percent
volume
in
any
payload
container.
If
discrepancies
or
inconsistencies
are
detected
during
the
data
form
review,
the
RTR
audio/
videotape
or
the
VE
audio/
videotape
are
reviewed
to
verify
that
the
observed
physical
form
of
the
waste
is
consistent
with
the
waste
stream
description
provided
by
the
generator
and
to
ensure
that
no
prohibited
items
are
present
in
the
waste.
(
The
AMWTP
does
not
have
classified
waste
and
will
not
ship
classified
waste.)
Section
B­
4
includes
a
description
of
the
waste
verification
process
that
is
conducted
prior
to
shipping
waste
to
the
WIPP
facility.

Containers
are
vented
through
filters
allowing
any
gases
that
are
generated
by
radiolytic
and
microbial
processes
within
a
waste
container
to
escape,
thereby
preventing
over
pressurization
or
development
of
conditions
within
the
container
that
would
lead
to
the
development
of
ignitable,
corrosive,
reactive,
or
other
characteristic
wastes.

To
ensure
the
integrity
of
the
WIPP
facility,
waste
streams
identified
to
contain
incompatible
materials
or
materials
incompatible
with
waste
containers
are
not
shipped
to
the
WIPP
until
after
they
have
been
treated
to
remove
the
incompatibility.
Only
those
waste
streams
that
are
compatible
or
have
been
treated
to
remove
incompatibilities
are
shipped
to
the
WIPP.
The
compatibility
of
waste
with
packaging
material,
shipping
containers,
backfill,
etc.
is
assessed
by
verification
of
the
TRUCON
Code
(
refer
to
MP­
TRUW­
8.1).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

18
The
WIPP­
WAP
limits
the
VOC
concentrations
in
the
headspace
of
waste
containers
to
those
which
when
averaged
on
a
room
basis,
will
ensure
compliance
with
the
performance
standards.
These
limits
apply
at
the
WIPP
facility
but
do
not
apply
to
the
AMWTP,
and
are
presented
in
Table
B­
2,
Maximum
Allowable
VOC
Room­
Averaged
Headspace
Concentration
Limits,
as
maximum
allowable
VOC
room­
averaged
headspace
concentration
limits.
There
are
no
maximum
allowable
headspace
gas
concentration
limits
for
individual
containers,
as
some
containers
can
exceed
these
values
as
long
as
container
headspace
averages
in
a
disposal
room
do
not.
At
the
AMWTP,
a
container
which
has
been
analyzed
and
is
reported
to
contain
higher
VOC
concentrations
than
the
averaged
limits
specified
in
Table
B­
2
may
be
approved
for
disposal
by
the
WIPP
Management
&
Operations
(
M&
O)
Contractor
on
a
case­
by­
case
basis.
Approval
for
containers
exceeding
the
averaged
limits
will
be
obtained
through
the
WIPP
Waste
Information
System
(
WWIS)
exception
process.

B­
1d
Control
of
Waste
Acceptance
Every
waste
stream
shipped
to
WIPP
shall
be
preceded
by
a
WSPF.
The
required
WSPF
information
and
the
Characterization
Information
Summary
elements
are
discussed
in
section
B3­
12b(
1)
and
section
B3­
12b(
2).

The
AMWTP
provides
the
WSPF
for
each
waste
stream
to
CBFO
for
acceptance
prior
to
shipping
the
waste
(
refer
to
MP­
TRUW­
8.14,
Preparation
of
Waste
Stream
Profile
Forms)
to
the
WIPP.
The
WSPF
and
Characterization
Information
Summary
will
be
transmitted
to
CBFO
for
each
waste
stream.
If
continued
waste
characterization
reveal
discrepancies
that
identify
different
hazardous
waste
codes
or
indicates
that
the
waste
belongs
to
a
different
waste
stream,
the
waste
is
redefined
to
a
separate
waste
stream
and
a
new
WSPF
is
submitted.

As
stated
in
the
introduction
of
this
QAPjP,
anytime
CBFO
requests
additional
information
concerning
a
waste
stream,
the
AMWTP
will
provide
a
Waste
Characterization
Package.
The
option
to
request
additional
information
ensures
that
waste
being
offered
for
disposal
is
adequately
characterized
and
accurately
described
in
the
WSPF.

B­
1e
Waste
Generating
Processes
at
the
WIPP
Facility
(
termed
"
derived
waste")

The
requirements
contained
in
Attachment
B­
1e
of
the
WIPP­
WAP
are
specific
to
the
WIPP
facility.
Therefore
these
requirements
have
not
been
addressed
in
this
document.

B­
2
Waste
Parameters
The
following
waste
analysis
parameters
are
characterized
at
the
AMWTP:

 
Confirmation
of
physical
form
and
exclusion
of
prohibited
items
specified
in
Section
B­
1c.

 
Toxicity
characteristic
contaminants
listed
in
20
NMAC
4.1.200
(
incorporating
40
CFR,
§
261.24),
Table
1
(
excluding
pesticides),
as
specified
in
the
WIPP
Hazardous
Waste
Permit,
Attachment
O.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

19
 
F­
listed
and
P­
listed
solvents
or
waste
(
F00l,
F002,
F003,
F004,
F005,
F006,
F007,
F009,
P015)
found
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261.31).

 
Hazardous
constituents
included
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261)
Appendix
VIII
as
specified
in
Tables
B­
1,
B­
3,
and
B­
4
as
well
as
any
other
hazardous
constituent
identified
through
AK.

Tables
B­
1,
B­
3,
B­
4,
and
B­
5
provide
the
parameters
of
interest
for
the
various
constituent
groupings
and
analytical
methodologies.
The
following
sections
provide
a
description
of
the
acceptable
methods
to
evaluate
these
parameters
for
each
Summary
Category
Group.

B­
3
Characterization
Methods
The
characterization
techniques
used
by
the
AMWTP
include
AK,
which
incorporates
confirmation
by
HSGS
and
analysis;
radiography;
and
homogeneous
waste
sampling
and
analysis.
All
confirmation
characterization
activities
are
performed
in
accordance
with
this
QAPjP.
Table
B­
6,
Summary
of
Parameters,
Characterization
Methods,
and
Rationale
for
CH
Transuranic
Waste,
provides
a
summary
of
the
characterization
requirements
for
TRU
waste.

TRU
waste
is
characterized
either
in
lots
(
Section
B­
1a)
or
batches
(
testing,
sampling,
analytical
or
on­
line).
A
sampling
batch
can
be
up
to
20
samples
(
excluding
field
QC
samples),
all
of
which
shall
be
collected
within
14
days
of
the
first
sample
in
the
batch.
An
analytical
batch
can
be
up
to
20
samples
(
excluding
laboratory
QC
samples),
all
of
which
shall
be
received
by
the
laboratory
within
14
days
of
the
validated
time
of
sample
receipt
of
the
first
sample
in
the
batch.
For
on­
line
integrated
headspace­
gas
sampling/
analytical
systems,
samples
will
be
collected
within
a
12­
hour
period
using
the
same
on­
line
integrated
sampling/
analytical
system.
The
analytical
requirements
are
specified
by
the
analytical
method
being
used
in
the
on­
line
system
(
e.
g.,
FTIRS,
GC/
MS).
Refer
to
Section
B3
for
additional
clarification
regarding
the
expected
contents
of
Batch
Data
Reports.

B­
3a
Sampling
and
Analytical
Methods
B­
3a(
1)
Headspace
Gas
Sampling
and
Analysis
Headspace­
gas
samples
are
used
to
determine
the
types
and
concentrations
of
VOCs
in
the
void
volume
of
waste
containers.
VOC
constituents
are
compared
to
those
assigned
by
AK,
and
the
AMWTP
will
assign
hazardous
waste
codes,
as
warranted.
This
comparison
may
include
as
analysis
of
radiolytically
derived
VOCs.
The
AMWTP
may
also
consider
radiolysis
when
assessing
the
presence
of
listed
waste
and
whether
radiolysis
would
generate
wastes
which
exhibit
the
toxicity
characteristic.
Refer
to
Section
B4
for
additional
clarification
regarding
hazardous
waste
code
assignment
and
headspace
gas
results.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

20
Every
TRU
mixed
waste
container
or
statistically
selected
containers
from
waste
streams
that
meet
the
conditions
for
reduced
headspace
gas
sampling
listed
in
this
section,
will
be
sampled
and
analyzed
to
determine
the
concentrations
of
VOCs
in
headspace
gases.
If
composite
samples
are
used,
containers
used
in
the
composite
sample
must
be
from
the
same
waste
stream
with
no
more
than
20
containers
being
included
in
a
single
composite
sample.
Sampling
protocols,
equipment,
and
QA/
QC
methods
for
headspace­
gas
sampling
are
provided
in
Section
B1.
In
accordance
with
EPA
convention,
identification
of
hazardous
constituents
detected
by
Gas
Chromatography/
Mass
Spectrometry
(
GC/
MS)
methods
that
are
not
on
the
list
of
target
analytes
shall
be
reported.
These
compounds
are
reported
as
tentatively
identified
compounds
(
TICs)
in
the
analytical
batch
data
report
and
shall
be
added
to
the
target
analyte
list
if
detected
in
a
given
waste
stream,
if
they
appear
in
the
20.4.1.200
NMAC
(
incorporating
40
CFR
§
261)
Appendix
VIII,
and
if
they
are
reported
in
25%
of
the
waste
containers
sampled
from
a
given
waste
stream.
The
headspace
gas
analysis
method
QAOs
are
specified
in
Section
B3.

B­
3a(
1)(
i)
Reduced
Sampling
Requirements
for
Homogeneous
Solid
or
Soil/
Gravel
Waste
Streams
with
no
VOC­
Related
Hazardous
Waste
Codes
Headspace
gas
sampling
of
homogeneous
solid
and
soil/
gravel
wastes
that
have
no
VOC­
related
hazardous
waste
codes
assigned
may
qualify
for
reduced
headspace
sampling
if
they
meet
the
following
criteria:

 
The
waste
stream
or
waste
stream
lot
must
consist
of
more
than
10
containers.

 
The
waste
stream
must
be
a
homogeneous
solid
or
soil/
gravel
waste
stream
that
has
no
VOC­
related
hazardous
waste
codes
assigned
to
it.

 
The
results
of
the
solid
sampling
and
analysis
must
confirm
that
no
VOC­
related
hazardous
waste
codes
should
be
assigned
to
the
waste
stream.

When
a
waste
stream
meets
these
conditions
for
reduced
headspace
gas
sampling,
the
AMWTP
randomly
selects
containers
for
headspace
gas
sampling
and
analysis
using
the
statistical
approach
in
Section
B2­
2b.

B­
3a(
1)(
ii)
Reduced
Sampling
Requirements
for
Thermally
Treated
Waste
Streams
Headspace
gas
sampling
of
homogeneous
solid
and
soil/
gravel
wastes
that
have
undergone
high­
temperature
thermal
processes
may
qualify
for
reduced
headspace
sampling
if
they
meet
the
following
criteria:

 
The
waste
stream
or
waste
stream
lot
must
consist
of
more
than
10
containers
 
The
waste
stream
must
have
either
been
generated
using
a
high­
temperature
thermal
process
or
been
subjected
to
a
high­
temperature
thermal
process
after
generation
that
results
in
the
reduction
of
matrixrelated
VOCs
in
the
headspace
to
concentrations
below
the
Program
Required
Quantitation
Limits
(
PRQLs)
in
Table
B3­
2.

 
The
site
must
have
documentation
demonstrating
that
high­
temperature
thermal
processes
were
used.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

21
If
a
waste
stream
meets
these
conditions
for
reduced
headspace
gas
sampling,
the
AMWTP
may
choose
to
randomly
select
containers
for
headspace
gas
sampling
and
analysis
using
the
statistical
approach
in
Section
B2­
2b.

B­
3a(
2)
Homogeneous
Waste
Sampling
and
Analysis
Sampling
of
homogeneous
and
soil/
gravel
wastes
results
in
the
collection
of
a
sample
that
is
used
to
confirm
hazardous
waste
code
assignment
by
AK.
Sampling
is
accomplished
through
core
or
other
EPA
approved
sampling,
which
is
described
in
Section
B1.
For
those
waste
streams
defined
as
Summary
Category
Groups
S3000
or
S4000,
debris
that
may
also
be
present
within
these
wastes
is
not
sampled.
The
waste
containers
for
sampling
and
analysis
are
selected
randomly
from
the
population
of
containers
for
the
waste
stream.
The
random
selection
methodology
is
specified
in
Section
B2.

As
appropriate,
Totals
or
Toxicity
Characteristic
Leaching
Procedure
(
TCLP)
analyses
for
volatile
organic
compounds
(
VOCs),
semivolatile
organic
compounds
(
SVOCs),
PCBs
and
RCRA­
regulated
metals
(
refer
to
Table
B­
4
and
Table
B­
5)
are
used
to
determine
waste
parameters
in
soils/
gravels
and
solids
that
may
be
important
to
the
performance
within
the
disposal
system.
To
determine
if
a
waste
exhibits
a
toxicity
characteristic
for
compounds
specified
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261,
Subpart
C),
TCLP
may
be
used
instead
of
total
analyses.
The
results
from
these
analyses
are
used
to
determine
if
a
waste
exhibits
a
toxicity
characteristic.
The
mean
concentration
of
toxicity
characteristic
contaminants
is
calculated
for
each
waste
stream
such
that
it
can
be
reported
with
an
upper
90
percent
confidence
limit
(
UCL90).
The
UCL90
values
for
the
mean
measured
contaminant
concentrations
in
a
waste
stream
are
compared
to
the
specified
regulatory
levels
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261),
expressed
as
total/
TCLP
values,
to
determine
if
the
waste
stream
exhibits
a
toxicity
characteristic.
A
comparison
of
total
analyses
and
TCLP
analyses
is
presented
in
Appendix
C3
of
the
WIPP
RCRA
Part
B
Permit
Application,
and
a
discussion
of
the
UCL90
is
included
in
Section
B2.
If
toxicity
characteristic
(
TC)
wastes
are
identified,
these
will
be
compared
to
those
determined
by
AK
and
TC
waste
codes
will
be
revised,
as
warranted.
Refer
to
Section
B4
for
additional
clarification
regarding
hazardous
waste
code
assignment
and
homogeneous
solid
and
soil/
gravel
analytical
results.

B­
3a(
3)
Laboratory
Qualification
The
AMWTP
conducts
analyses
using
laboratories
that
are
qualified
through
participation
in
the
Performance
Demonstration
Program
(
PDP).
Required
QAOs
are
specified
in
Section
B3.

Analytical
methods
used
by
the
laboratories:
1)
satisfy
all
of
the
appropriate
QAOs,
and
2)
are
implemented
through
laboratory­
documented
standard
operating
procedures.
These
analytical
QAOs
are
discussed
in
detail
in
Section
B3
of
this
document.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

22
B­
3b
Acceptable
Knowledge
AK
is
used
in
TRU
waste
characterization
activities
in
three
ways:

 
To
delineate
TRU
waste
streams.

 
To
assess
whether
TRU
heterogeneous
debris
wastes
exhibit
a
toxicity
characteristic
(
20.4.1.200
NMAC,
incorporating
40
CFR
§
261.24).

 
To
assess
whether
TRU
wastes
are
listed
(
20
NMAC
4.1.200,
incorporating
40
CFR
§
261.31).

AK
is
discussed
in
detail
in
Section
B4,
which
outlines
the
minimum
set
of
requirements
that
are
met
by
the
AMWTP
in
order
to
use
AK.
In
addition,
Section
B­
4b(
1)
of
this
QAPjP
describes
the
verification
of
AK
through
sampling
and
analysis.

B­
3c
Radiography
and
Visual
Examination
Radiography
is
a
nondestructive
qualitative
and
quantitative
technique
that
involves
X­
ray
scanning
of
waste
containers
to
identify
and
verify
waste
container
contents.
VE
consists
of
opening
a
container
and
physically
examining
its
contents.

Radiography
and/
or
VE
are
used
to
examine
every
waste
container
to
verify
its
physical
form.
These
techniques
can
detect
liquid
wastes
and
containerized
gases,
which
are
prohibited
for
WIPP
disposal.
The
prohibition
of
liquids
and
containerized
gases
prevents
the
shipment
of
corrosive,
ignitable,
or
reactive
wastes.

Radiography
and/
or
VE
are
also
used
to
confirm
that
the
physical
form
of
the
waste
matches
its
waste
stream
description
[
i.
e.,
Homogeneous
Solids,
Soil/
Gravel,
or
Debris
Waste
(
including
uncategorized
metals)].
If
the
physical
form
does
not
match
the
waste
stream
description,
the
waste
is
designated
as
another
waste
stream
and
assigned
the
preliminary
hazardous
waste
codes
associated
with
that
new
waste
stream
assignment.
That
is,
if
radiography
and/
or
VE
indicate
that
the
waste
does
not
match
the
waste
stream
description
arrived
at
by
AK
characterization,
a
nonconformance
report
(
NCR)
is
completed
and
the
inconsistency
is
resolved
as
specified
in
Section
B4
of
this
document.
The
proper
waste
stream
assignment
is
determined
(
including
preparation
of
a
new
WSPF
when
necessary),
the
correct
hazardous
waste
codes
are
assigned,
and
the
resolution
is
documented.
Refer
to
Section
B4
for
a
discussion
of
AK
and
its
confirmation
process.

At
the
AMWTP,
there
are
three
specific
reasons
for
utilizing
VE
as
follows:

 
VE
performed
to
confirm
radiography:
VE
that
is
performed
as
a
confirmation
of
radiography
data
requires
audio/
videotaping.
This
VE
is
performed
on
a
statistically
selected
subpopulation
of
waste
containers
that
have
already
undergone
radiography
(
refer
to
Section
B2­
1
for
a
discussion
of
the
statistical
selection
of
these
waste
containers
and
Section
B1
for
radiographic
examination
protocols).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

23
 
VE
performed
in
lieu
of
radiography:
VE
that
is
performed
in
lieu
of
radiography
(
e.
g.,
used
for
waste
containers
with
lead
liners)
requires
audio/
videotaping.
It
is
anticipated
that
some
of
the
drums
excavated
from
the
TSA­
RE
will
contain
lead­
liners.
Lead­
lined
drums
will
be
managed
on
a
case­
by­
case
basis,
and,
if
appropriate,
some
of
these
drums
may
be
segregated
as
RH­
TRU
waste.

 
VE
performed
as
a
visual
verification
of
AK:
VE
that
is
performed
for
newly
generated
waste
or
when
repackaging
retrievably
stored
waste
does
not
require
audio/
videotaping.
This
activity
requires
two
operators.
The
first
operator
sorts
the
contents
of
the
incoming
drums
into
new
drums,
and
the
second
operator
visually
verifies
the
waste
being
packaged
into
the
new
drums
[
refer
to
Section
B3­
d(
l)].

If
AMWTP
chooses
to
use
VE
in
lieu
of
radiography,
the
detection,
through
shaking,
of
any
liquid
waste
in
nontransparent
inner
containers
is
handled
by
assuming
that
the
container
is
filled
with
liquid
and
adding
this
volume
to
the
total
liquid
in
the
payload
container
[
e.
g.,
55­
gallon
drum
or
Standard
Waste
Box
(
SWB)].

The
payload
container
would
then
be
rejected
and/
or
repackaged
to
exclude
the
container
if
it
is
over
the
TSDFWAC
limits.

When
radiography
is
used,
or
visual
examination
of
transparent
containers
is
performed,
if
any
liquid
in
inner
containers
is
detected,
the
volume
of
liquid
is
added
to
the
total
for
the
payload
container.
Radiography,
or
the
equivalent,
is
used
on
the
existing/
stored
waste
containers
to
verify
that
the
physical
characteristics
of
the
TRU
waste
correspond
with
its
waste
stream
identification/
waste
stream
Waste
Matrix
Code,
and
to
identify
prohibited
items.
The
results
of
radiography
are
verified
through
visual
examination
of
a
statistically
selected
subpopulation
of
TRU
waste
containers
in
each
TRU
waste
summary
category
group
as
specified
in
Section
B2.
Radiographic
examination
protocols
and
QA/
QC
methods
are
provided
in
Section
B1.

B­
3d
Characterization
Techniques
and
Frequency
for
Newly
Generated
and
Retrievably
Stored
Waste
The
AMWTP
uses
AK
to
delineate
all
TRU
waste
containers
into
waste
streams
for
the
purposes
of
grouping
waste
for
further
characterization.
The
analyses
performed
does
not
differ
based
on
the
waste
stream,
only
on
the
physical
form
of
the
waste
(
i.
e.,
heterogeneous
debris
waste
cannot
be
sampled
for
totals
analyses).
Both
retrievably
stored
and
newly
generated
wastes
are
delineated
in
this
fashion,
though
the
types
of
AK
used
may
differ.
Section
B­
3b
discusses
the
use
of
AK,
sampling,
and
analysis
in
more
detail.
AK
is
discussed
more
completely
in
Section
B4.
Every
waste
stream
will
be
assigned
hazardous
waste
codes
based
upon
AK,
and
these
hazardous
waste
codes
are
confirmed
using
headspace
gas
(
all
Summary
Category
Groups)
and
solid
sampling
and
analysis
(
Summary
Category
Groups
S3000
and
S4000
only).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

24
Radiography
and/
or
VE
are
used
to
verify
the
physical
form
of
retrievably
stored
TRU
waste.
For
newly
generated
waste
or
repackaged
retrievably
stored
waste,
physical
form
and
prohibited
items
are
either
verified
during
packaging
(
using
the
VE
technique)
or
will
be
verified
after
packaging
using
radiography
(
or
VE
in
lieu
of
radiography).
Generator
/
storage
sites
may
use
either
the
VE
technique
or
radiography
separately
or
together,
as
long
as
100%
of
the
containers
undergo
confirmation
of
AK.
Radiography
and/
or
VE
are
also
used
in
conjunction
with
AK
to
characterize
heterogeneous
debris
wastes.
Radiography
and/
or
VE,
and
the
associated
information
compiled
from
AK
(
e.
g.,
age
of
the
waste,
generating
process)
are
used
to
determine
the
RCRA­
regulated
constituents
present
in
the
waste.
VE,
the
VE
technique,
and/
or
radiography
shall
be
performed
prior
to
any
treatment
designed
to
supercompact
waste
prior
to
shipment.
It
should
be
noted
that
no
supercompacted
waste
will
be
shipped
to
the
WIPP
facility
until
approval
for
emplacement
of
supercompacted
waste
is
received
from
the
U.
S.
Environmental
Protection
Agency.

All
waste
containers
(
retrievably
stored
and
newly
generated)
or
randomly
selected
containers
from
waste
streams
that
meet
the
condition
for
reduced
headspace
gas
sampling
listed
in
Section
B­
3a(
1)
are
sampled
and
analyzed
for
VOCs
in
the
headspace
gas.
A
statistically
selected
portion
of
each
homogeneous
solids
and
soil/
gravel
waste
stream
is
sampled
and
analyzed
for
RCRA
regulated
total
VOCs,
SVOCs,
and
Metals
(
see
Section
B2).
Sampling
and
analysis
methods
used
for
waste
characterization
are
discussed
in
Section
B­
3a.

In
the
process
of
performing
organic
headspace
and
solid
sample
analyses,
nontarget
compounds
may
be
identified.
These
compounds
are
reported
as
TICs.
TICs
reported
in
25%
of
the
samples
and
listed
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261)
Appendix
VIII,
are
compared
with
AK
data
to
determine
if
the
TIC
is
a
listed
hazardous
waste
in
the
waste
stream.
TICs
identified
through
headspace
gas
analyses
that
meet
the
Appendix
VIII
list
criteria
and
the
25
percent
reporting
criteria
for
a
waste
stream
are
added
to
the
headspace
gas
waste
stream
target
list,
regardless
of
the
hazardous
waste
listing
associated
with
the
waste
stream.
TICs
subject
to
inclusion
on
the
target
analyte
list
that
are
toxicity
characteristic
parameters
are
added
to
the
target
analyte
list
regardless
of
origin
because
the
hazardous
waste
designation
for
these
codes
is
not
based
on
source.
However,
for
toxicity
characteristic
and
nontoxic
F003
constituents,
the
AMWTP
may
take
concentration
into
account
when
assessing
whether
to
add
a
hazardous
waste
code.
TICs
reported
from
the
Totals
or
Toxicity
Characterization
Leaching
Procedure
(
TCLP)
VOC
or
SVOC
analyses
may
be
excluded
from
the
target
analyte
list
for
a
waste
stream
if
the
TIC
is
a
constituent
in
an
Flisted
waste
whose
presence
is
attributable
to
waste
packaging
materials
or
radiolytic
degradation
from
AK
documentation.
Refer
to
Section
B3
for
additional
information
on
TIC
identification.

If
the
TIC
associated
with
a
total
VOC
or
SVOC
analysis
cannot
be
identified
as
a
component
of
waste
packaging
materials
or
as
a
product
of
radiolysis,
the
AMWTP
will
add
these
TICs
to
the
list
of
hazardous
constituents
for
the
waste
stream
(
and
assign
additional
EPA
listed
hazardous
waste
codes,
if
appropriate).
For
toxicity
characteristic
compounds
and
non­
toxic
F003
constituents,
the
AMWTP
may
consider
waste
concentration
when
determing
whether
to
change
a
hazardous
waste
code.
Refer
to
Section
B3
for
additional
requirements
on
TIC
identification.

Waste
characterization
solid
sampling
and
analysis
activities
may
differ
for
retrievably
stored
waste
and
newly
generated
waste.
The
waste
characterization
data
collection
design
for
each
type
of
waste
is
described
in
the
following
sections.
Table
B­
1
provides
a
summary
of
hazardous
waste
characterization
requirements
for
all
TRU
waste
by
waste
characterization
parameters.

Table
B­
6
summarizes
the
parameters,
methods,
and
rationales
for
stored
and
newly
generated
CH­
TRU
wastes
according
to
their
waste
forms.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

25
It
is
acceptable
to
ship
TRU
waste
which
has
been
repackaged
or
treated
to
the
WIPP
facility.
Repackaged
or
treated
waste
undergoes
characterization
required
of
newly
generated
waste
except
that
solids
sampling
for
repackaged
or
treated
S3000
waste
may
be
characterized
as
retrievable
stored
waste
if
the
AMWTPdemonstrates
that
control
charting
cannot
be
applied
effectively
to
the
repackaging
or
treatment
process.
Repackaged
waste
also
undergoes
headspace
gas
analysis,
and
payload
container
headspace
is
sampled
after
repackaging,
as
long
as
the
criteria
specified
in
Section
B1­
1
are
met.
Treated
waste
shall
retain
e
original
waste
stream's
listed
hazardous
waste
code
designation.

B­
3d(
1)
Newly
Generated
Waste
The
RCRA­
regulated
constituents
in
newly
generated
wastes
are
documented
at
the
time
of
generation
based
on
AK
for
the
waste
stream.
Newly
generated
TRU
waste
characterization
begins
with
the
verification
that
the
processes
generating
the
waste
have
operated
within
established
written
procedures.
Waste
containers
are
then
delineated
into
waste
streams
using
AK.
Verification
that
the
physical
form
of
the
waste
(
Summary
Category
Group)
corresponds
to
the
physical
form
of
the
assigned
waste
stream
is
accomplished
either
during
packaging
(
using
the
VE
technique)
or
by
performing
radiography
as
specified
in
Attachment
B1­
3
for
retrievable
stored
waste.
AMWTP
may
use
either
the
VE
technique
or
radiography,
separately
or
together,
as
long
as
100%
of
the
containers
undergo
confirmation
of
AK.
If
the
VE
technique
is
used,
it
is
different
than
the
VE
process
described
in
Section
B1­
3b(
3)
and
consists
of
the
operator
confirming
that
the
waste
is
assigned
to
a
waste
stream
that
has
the
correct
Summary
Category
Group
for
the
waste
being
packaged.
If
a
confirmation
cannot
be
made,
a
NCR
is
completed
and
corrective
actions
are
taken
as
specified
in
Section
B3.
The
packaging
configuration,
type
and
number
of
filters,
and
rigid
liner
vent
hole
presence
and
diameter
necessary
to
determine
the
appropriate
drum
age
criteria
(
DAC)
in
accordance
with
Permit
Attachment
B1,
Section
B1­
1,
shall
be
documented
as
part
of
the
characterization
information
collected
during
the
packaging
of
newly
generated
waste
or
repackaging
of
retrievably
stored
waste.

Instead
of
using
a
video/
audio
tape
as
required
with
VE
in
support
of
radiography
in
Section
B1­
3b(
3),
the
VE
technique
for
newly
generated
waste
(
or
repackaged
retrievably
stored
waste)
uses
a
second
operator,
who
is
equally
trained
to
the
requirements
specified
in
Section
B1,
to
provide
additional
verification
by
reviewing
the
contents
of
the
waste
container
to
ensure
correct
reporting.
If
the
second
operator
cannot
provide
concurrence,
corrective
actions
are
taken
as
specified
in
Section
B3.
The
subsequent
waste
characterization
activities
depend
on
the
assigned
Summary
Category
Group,
since
waste
within
the
Homogeneous
Solids
and
Soils/
Gravel
Summary
Category
Groups
is
characterized
using
different
techniques
than
the
waste
in
the
Debris
Waste
Summary
Category
Group.
If
retrievably
stored
waste
is
characterized
in
the
same
manner
as
newly
generated
waste
due
to
unacceptable
AK
(
see
Section
B­
1a),
the
option
to
perform
radiography
in
lieu
of
or
in
combination
with
the
VE
technique
does
not
apply.

Containers
of
newly
generated
waste
undergo
headspace
gas
analysis
for
VOC
concentrations
prior
to
shipment
in
accordance
with
the
requirements
of
B­
3a(
1).
All
containers
of
newly
generated
waste
or
newly
generated
waste
containers
randomly
selected
from
waste
streams
that
meet
the
conditions
for
reduced
headspace
gas
sampling
listed
in
Section
B­
3a(
1)
will
undergo
headspace
gas
analysis
for
VOC
prior
to
shipment.
The
headspace
gas
sampling
method
is
provided
in
Section
B1.
Headspace
gas
data
is
used
to
confirm
AK
waste
characterization
as
specified
in
Section
B4.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

26
B­
3d(
1)(
a)
Sampling
of
Newly
Generated
Homogeneous
Solids
Newly
generated
mixed
waste
streams
of
homogeneous
solids
are
randomly
sampled
a
minimum
of
once
per
year
for
total
VOCs,
SVOCs,
PCBs
and
metals.
An
initial
ten­
sample
set,
however,
is
collected
to
develop
the
baseline
control
chart.
Sampling
frequency
of
once
per
year
is
only
allowed
if
a
process
has
operated
within
procedurally
established
bounds
without
any
process
changes
or
fluctuations
which
would
result
in
either
a
new
waste
stream
or
the
identification
of
a
new
hazardous
waste
constituent
in
that
waste
stream.
Otherwise,
the
waste
is
considered
as
process
batches
and
each
batch
undergoes
sampling
and
analysis.

Process
changes
and
process
fluctuations
are
determined
using
statistical
process
control
charting
techniques;
these
techniques
require
the
ten­
sample
set
and
historical
data
for
determining
limits
for
indicator
species
and
subsequent
periodic
sampling
to
assess
process
behavior
relative
to
historical
limits.

If
the
limits
are
exceeded,
the
waste
stream
is
recharacterized,
and
the
characterization
is
performed
according
to
procedures
required
for
retrievably
stored
waste
(
i.
e.,
waste
sampling
frequency
will
be
increased).
The
process
for
control
charting
technique
is
described
in
Section
B2­
4.

Also,
as
another
control
of
waste
generated
from
a
particular
process,
the
bounds
for
a
waste
generating
process
are
established
by
specific
written
procedures
for
that
process.
Examples
of
parameter
bounds
that
could
affect
a
waste
generated
by
a
process
are
volumes
of
input
material,
change
in
the
input
material,
and
any
other
changes
that
would
change
the
output
of
that
process.

The
AMWTP
procedures
used
to
control
waste
generating
processes
contain
the
following
information:

 
Responsible
organizations
for
implementing
the
requirements
of
the
procedure
 
Material
inputs
 
Waste
streams
generated
 
Process
controls
and
range
of
operation
(
bounds)
that
affect
final
hazardous
waste
determinations
 
Rate
and
quantity
of
hazardous
waste
generated
 
List
of
applicable
operating
procedures
relevant
to
the
hazardous
waste
determination
Events
where
procedurally
established
bounds
are
exceeded
or
any
condition
of
normal
operation
is
not
being
met
could
trigger
an
increased
sampling
frequency
of
a
waste
stream.
As
long
as
a
process
does
not
change
outside
of
established
bounds
within
a
year,
the
waste
generated
by
that
process
has
the
same
characteristics,
and
therefore,
a
minimum
of
one
sample
is
collected
annually
to
verify
the
lack
of
variability
of
that
waste
stream.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

27
The
records
generated
by
the
process
procedures
will
be
examined
weekly
for
indications
of
process
changes
or
limits
being
exceeded
that
would
change
the
hazardous
constituents
identified
in
the
waste
stream
or
add
relevant
prohibited
materials.
If
these
changes
are
discovered,
the
AMWTP
will
notify
CBFO,
and
will
not
ship
this
waste
to
the
WIPP
for
disposal
until
a
follow­
up
sample
of
process
waste
is
collected
and
analyzed
to
assess
whether
the
container
contents
are
within
those
identified
on
the
WSPF.
If
the
second
analysis
is
not
consistent
with
the
WSPF
information,
all
waste
containers
in
question
will
be
segregated
and
a
new
WSPF
and
waste
generation
procedures/
bounds
will
be
established.
Records
of
the
analysis
will
be
available
for
examination
by
CBFO.

If
the
AMWTP
changes
a
process,
but
determines
that
increased
sampling
is
not
required
because
the
change
will
not
affect
waste
generated
by
that
process,
the
AMWTP
notifies
the
CBFO
in
the
form
of
a
memorandum
to
the
CBFO
Waste
Characterization
Manager.
The
CBFO
will
concur
with
the
decision
to
not
increase
the
sampling
frequency
before
any
additional
waste
from
that
process
is
shipped.

The
toxicity
characteristics
of
newly
generated
homogeneous
solids
and
soils/
gravel
waste
streams
are
determined
using
total
analysis
of
toxicity
characteristic
contaminants
or
TCLP.
To
determine
if
a
waste
exhibits
a
toxicity
characteristic
for
compounds
specified
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261,
Subpart
C),
TCLP
may
be
used
instead
of
total
analyses.
The
sampling
methods
for
homogeneous
solids
and
soil/
gravel
wastes
are
provided
in
Section
B1.

B­
3d(
1)(
b)
Sampling
of
Newly
Generated
Soils/
Gravels
Newly
generated
soils/
gravel
waste
is
generated
primarily
by
remediation
or
decontamination
and
decommissioning
(
D&
D)
activities.
Process
controls
for
these
types
of
waste
cannot
readily
be
defined
and,
therefore,
sampling
cannot
follow
that
used
for
newly
generated
homogeneous
waste.
The
number
of
newly
generated
soils/
gravel
waste
containers
to
be
sampled
is
determined
using
the
procedure
specified
in
Section
B­
3a(
2),
wherein
a
statistically
selected
portion
of
the
waste
is
sampled.
The
AMWTP
estimates
the
number
of
containers
to
be
sampled
within
the
waste
stream
based
on
the
expected
volume
of
the
waste
stream
and
whether
SWB
or
55­
gallon
drum
containers
will
be
used.
Refer
to
Section
B2
for
additional
information.

B­
3d(
2)
Retrievably
Stored
Waste
All
retrievably
stored
waste
containers
are
first
delineated
into
waste
streams
using
AK.
All
retrievably
stored
waste
containers
are
examined
using
radiography
to
confirm
the
physical
waste
form
(
Summary
Category
Group),
to
verify
the
absence
of
prohibited
items,
and
to
determine
the
waste
characterization
techniques
to
be
used
based
on
the
Summary
Category
Groups
(
i.
e.,
S3000,
S4000,
S5000).
Repackaged
retrievably
stored
waste,
or
any
retrievably
stored
waste
with
inadequate
AK,
is
characterized
using
either
the
retrievably
stored
or
newly
generated
waste
characterization
process,
whichever
results
in
greater
sampling
requirements,
Repackaged
retrievably
stored
waste,
or
any
retrievably
stored
waste
with
inadequate
acceptable
knowledge,
will
be
characterized
using
either
the
retrievably
stored
or
newly
generated
waste
characterization
process,
whichever
results
in
greater
sampling
requirements,
unless
it
is
demonstrated
that
control
charting
cannot
be
applied
effectively.
Solids
sampling
for
repackaged
or
treated
S3000
waste
may
be
characterized
as
retrievably
stored
waste
if
the
AMWTP
demonstrate
that
control
charting
cannot
be
applied
effectively
to
the
repackaging
or
treatment
process.
This
determination
by
the
must
be
documented
on
the
Characterization
Information
Summary
and
will
be
examined
by
the
Permittees
during
audits
(
Permit
Attachment
B6).
In
this
case,
the
minimum
number
of
solid
samples
required
for
any
S3000
waste
stream
or
waste
stream
lot
is
the
number
of
samples
determined
in
accordance
with
Section
B2­
2a.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

28
Radiographic
results
are
compared
to
AK
results
to
ensure
correct
Waste
Matrix
Code
assignment
and
identification
of
prohibited
items.
If
radiographic
analysis
does
not
confirm
the
physical
waste
form,
waste
is
reassigned
as
specified
in
Section
B­
3c.
The
AMWTP
may
elect
to
substitute
VE
for
radiographic
analysis.

To
confirm
the
results
of
radiography,
a
statistically
selected
number
of
the
TRU
waste
container
population
undergoes
VE
by
opening
containers
to
inspect
waste
contents
to
verify
radiography
results.
Section
B2
contains
the
approach
used
to
statistically
select
the
number
of
drums
to
undergo
VE.
For
homogeneous
waste
and
soils/
gravels
selected
for
sampling,
the
containers
opened
for
sampling
may
be
used
to
help
fulfill
the
VE
requirements.

All
retrievably
stored
containers
or
retrievably
stored
containers
randomly
selected
from
waste
streams
that
meet
the
conditions
for
reduced
headspace
gas
sampling
listed
in
Section
B­
3a(
1)
undergo
headspace
gas
analysis
for
VOC
concentrations.
Retrievably
stored
waste
that
is
repackaged
will
be
subject
to
the
DAC
determination
specified
in
Section
B­
3d(
1).
The
headspace
gas
sampling
method
is
provided
in
Section
B1­
1.
All
headspace
gas
data
is
used
to
confirm
AK
waste
characterization,
as
specified
in
Section
B4.

A
statistically
selected
portion
of
retrievably
stored
homogeneous
solids
and
soil/
gravel
wastes
are
sampled
and
analyzed
for
Total
or
VOCs,
SVOCs,
and
Metals.
The
approach
used
to
statistically
select
drums
for
homogeneous
solids
and
soil/
gravel
wastes
is
different
than
the
method
used
to
select
waste
containers
for
VE.
This
method
is
included
in
Section
B2­
2.
The
sampling
methods
for
these
wastes
are
provided
in
Section
B1.

The
toxicity
characteristic
of
retrievably
stored
homogeneous
solids
and
soil/
gravel
wastes
is
determined
using
total
analysis
of
toxicity
characteristic
parameters
or
TCLP.
To
determine
if
a
waste
exhibits
a
toxicity
characteristic
for
compounds
specified
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261,
Subpart
C),
TCLP
may
be
used
instead
of
total
analyses.
Appendix
C3
of
the
WIPP
RCRA
Part
B
Permit
Application
discusses
comparability
of
totals
analytical
results
to
those
of
the
TCLP
method.

Representativeness
of
containers
selected
for
VE
and
waste
subjected
to
homogeneous
solids
and
soil/
gravel
sampling
and
analysis
will
be
validated
by
the
AMWTP
via
examination
of
documentation
that
shows
that
true
random
samples
were
collected.
Because
representativeness
is
a
quality
characteristic
that
expresses
the
degree
to
which
a
sample
or
group
of
samples
represent
the
population
being
studied,
the
random
sampling
of
waste
streams
ensures
representativeness.
The
AMWTP
procedure
which
address
random
selection
is
MP­
TRUW­
8.19,
RTR/
VE
Drum
Selection
and
MP­
TRUW­
8.25,
RCRA
Statistical
Sampling.

B­
4
Data
Verification
and
Quality
Assurance
Data
validation,
usability
and
reporting
controls
are
used
to
ensure
that
the
TRU
waste
shipped
to
the
WIPP
facility
for
disposal
meets
WIPP­
WAP
requirements.
Verification
steps
are
taken
at
three
levels:
1)
the
AMWTP
Data
Generation
Level,
2)
the
AMWTP
Project
Level,
and
3)
the
CBFO
level.
The
validation
process
and
requirements
at
each
level
are
described
in
Section
B3­
10.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

29
B­
4a
Data
Generator
and
Site
Project
Level
Requirements
B­
4a(
1)
Data
Quality
Objectives
The
waste
characterization
data
obtained
through
implementation
of
the
QAPjP
will
be
used
to
ensure
that
the
waste
meets
regulatory
requirements
with
regard
to
regulatory
compliance.
To
satisfy
the
RCRA
regulatory
compliance
requirements,
the
following
DQOs
are
established
in
the
WIPP­
WAP:

 
Headspace
Gas
Sampling
and
Analysis
 
To
identify
VOCs
and
quantify
the
concentrations
of
VOC
constituents
in
the
total
waste
inventory
to
ensure
compliance
with
the
environmental
performance
standards
of
20
NMAC
4.1.500
[
incorporating
40
CFR,
§
264.601(
c)],
and
to
confirm
hazardous
waste
identification
by
AK.

 
Homogeneous
Waste
Sampling
and
Analysis
 
To
compare
upper
90%
confidence
level
(
UCL90)
values
for
the
mean
measured
contaminant
concentrations
in
a
waste
stream
with
specified
toxicity
characteristic
levels
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261),
to
determine
if
the
waste
is
hazardous,
and
to
confirm
hazardous
waste
identification
by
AK.

 
To
report
the
average
concentration
of
hazardous
constituents
in
a
waste
stream,
as
specified
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261)
Appendix
VIII,
with
a
90
percent
confidence
interval,
with
all
averages
greater
than
Program
Required
Quantitation
Limit
(
PRQL)
considered
a
detection
and
subsequent
assignment
of
the
waste
(
if
an
adequate
explanation
for
the
constituent
cannot
be
determined)
as
a
hazardous
waste,
and
to
confirm
hazardous
waste
identification
by
AK.

 
Radiography
 
To
verify
the
TRU
waste
streams
by
Waste
Matrix
Code
for
purposes
of
physical
waste
form
identification
and
determination
of
sampling
and
analytical
requirements,
to
identify
prohibited
items,
and
to
confirm
the
waste
stream
delineation
by
AK.

 
Visual
Examination
 
To
verify
the
TRU
waste
streams
by
Waste
Matrix
Code
for
purposes
of
physical
waste
form
identification,
determination
of
sampling
and
analytical
requirements,
and
to
identify
prohibited
items.

 
To
provide
a
process
check
on
a
sample
basis
by
verifying
the
information
determined
by
radiography
and
to
confirm
the
waste
stream
delineation
by
AK.

Reconciliation
of
these
DQOs
by
the
SPM
is
addressed
in
Section
B3.
Reconciliation
requires
determining
whether
sufficient
type,
quality,
and
quantity
of
data
have
been
collected
to
ensure
the
DQOs
cited
above
can
be
achieved
(
refer
to
MP­
TRUW­
8.11,
Data
Reconciliation).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

30
B­
4a(
2)
Quality
Assurance
Objectives
The
AMWTP
demonstrates
compliance
with
each
QAO
associated
with
the
various
characterization
methods
as
presented
in
Section
B3.
The
SPM
performs
a
reconciliation
at
the
Project
Level
of
the
data
sets
submitted
by
the
various
AMWTP
organizations
with
the
DQOs
established
in
the
WIPP­
WAP.
The
SPM
concludes
that
all
of
the
DQOs
have
been
met
for
the
characterization
of
the
waste
stream
prior
to
submitting
a
WSPF
to
the
WIPP
facility
for
approval
(
refer
to
Section
B3).
The
following
QAO
elements
are
considered
for
each
technique,
as
a
minimum:

 
Precision
 
Precision
is
a
measure
of
the
mutual
agreement
among
multiple
measurements.

 
Accuracy
 
Accuracy
is
the
degree
of
agreement
between
a
measurement
result
and
the
true
or
known
value.

 
Completeness
 
Completeness
is
a
measure
of
the
amount
of
valid
data
obtained
from
a
method
compared
to
the
total
amount
of
data
obtained
that
is
expressed
as
a
percentage.

 
Comparability
 
Comparability
is
the
degree
to
which
one
data
set
can
be
compared
to
another.

A
more
detailed
discussion
of
the
QAOs,
including
mathematical
representation,
where
appropriate,
can
be
found
in
Section
B3,
which
describes
the
QAOs
associated
with
each
method
of
sampling
and
analysis.

B­
4a(
3)
Sample
Control
The
AMWTP
has
implemented
a
sample
handling
and
control
program
that
includes
the
maintenance
of
field
documentation
records,
proper
labeling,
and
a
chain­
of­
custody
(
COC)
record.
This
QAPjP
and
the
referenced
procedures
document
the
AMWTP
sampling
handling
and
control
program.
COC
forms
to
control
the
sample
from
the
point
of
origin
to
the
final
analysis
result
reporting
are
included
in
this
QAPjP
and
INST­
OI­
16,
Drum
Coring
Operations.
Details
of
the
AMWTP
sample
control
program
are
provided
in
Section
B1
and
are
summarized
below
to
include:

 
Field
Documentation
of
samples
including:
point
of
origin,
date
of
sample,
container
ID,
sample
type,
analysis
requested,
and
COC
number.

 
Labeling
and/
or
tagging
including:
sample
numbering,
sample
ID,
sample
date,
sampling
conditions,
and
analysis
requested.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

31
 
COC
control
including:
name
of
sample
relinquisher,
sample
receiver,
and
the
date
and
time
of
the
sample
transfer.

 
Proper
sample
handling
and
preservation.

B­
4a(
4)
Data
Generation
Batch
Data
Reports,
in
a
format
approved
by
the
CBFO,
will
be
used
by
the
AMWTP
to
report
waste
characterization
data.
The
AMWTP
utilizes
formats
for
waste
characterization
batch
data
reports
that
include
all
of
the
elements
required
by
the
WIPP­
WAP
(
refer
to
Section
B3).
These
formats
are
defined
in
this
QAPjP
and
detailed
in
referenced
procedures.
The
required
formats
for
the
various
batch
data
reports
are
specified
and
will
include
all
of
the
elements
required
by
the
WIPP­
WAP.

The
CBFO
requires
all
analytical
laboratories
analyzing
WIPP
waste
characterization
samples
to
have
established,
documented
QA/
QC
programs.
In
addition,
the
AMWTP
will
conduct
audits
on
laboratories
analyzing
waste.
The
laboratory's
QA/
QC
program
includes
the
following:

 
Facility
organization
 
A
list
of
equipment/
instrumentation
 
Operating
procedures
 
Laboratory
QA/
QC
procedures
 
Quality
assurance
review
 
Laboratory
records
management
B­
4a(
5)
Data
Verification
Batch
Data
Reports
document
the
testing,
sampling,
and
analytical
results
from
the
required
characterization
activities,
and
include
documentation
of
required
QA/
QC
activities.
Data
validation
and
verification
at
both
the
data
generation
level
and
the
project
level
are
performed
before
the
required
data
are
transmitted
to
the
WIPP
facility.
Section
B3
discusses
the
data
validation
process
in
more
detail.
NMED
may
request,
through
the
CBFO,
copies
of
any
Batch
Data
Report,
and/
or
the
raw
data
validated
by
the
generator/
storage
sites,
to
check
the
CBFO'
audit
of
the
validation
process.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

32
B­
4a(
6)
Data
Transmittal
Batch
Data
Reports
include
information
required
by
Section
B3­
10
and
are
transmitted
by
hard
copy
or
electronically
(
provided
a
hard
copy
is
available
on
demand)
from
the
data
generation
level
to
the
project
level.
The
AMWTP
transmits
waste
container
information
electronically
via
the
WIPP
Waste
Information
System
(
WWIS).
Data
is
entered
into
the
WWIS
in
the
exact
format
required
by
the
database
(
refer
to
Section
B­
4b
for
WWIS
reporting
requirements
and
the
WIPP
Waste
Information
System
User's
Manual
for
use
by
Shippers/
Generators
for
the
WWIS
data
fields
and
format
requirements).

Once
a
waste
stream
is
fully
characterized,
the
SPM
also
submits
to
the
WIPP
facility
a
WSPF
accompanied
by
the
Characterization
Information
Summary
for
the
waste
stream
which
includes
reconciliation
with
DQOs
[
refer
to
Section
B3­
12b(
1)].
The
WSPF,
the
Characterization
Information
Summary,
and
information
from
the
WWIS
is
used
as
the
basis
for
acceptance
of
waste
characterization
information
on
TRU
mixed
waste
disposed
at
WIPP.

B­
4a(
7)
Records
Management
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.
Refer
to
MPDOCS
18.2,
AMWTP
Records
Management
and
MP­
TRUW­
8.28
Project
Administrative
Controls
for
the
Analytical
Laboratories
Department
for
a
detailed
description
of
records
management
procedures.

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
the
approved
implementing
procedure.
All
waste
characterization
data
and
related
QA/
QC
records
in
the
AMWTP
Records
Storage
Facility
for
TRU
waste
to
be
shipped
to
the
WIPP
facility
are
designated
as
either
Lifetime
Records
or
Non­
Permanent
Records.
Records
that
are
designated
as
Lifetime
Records
are
maintained
for
the
life
of
the
AMWTP
waste
characterization
program
plus
six
years.
These
records
will
then
be
offered
to
the
WIPP
facility
for
permanent
archival
of
information
of
the
records
in
the
appropriate
form,
or
transferred
to
the
appropriate
Federal
Records
Center
(
FRC).
Waste
characterization
records
designated
as
NonPermanent
Records
are
maintained
for
ten
years
from
the
date
of
(
record)
generation
and
then
dispositioned
according
to
the
requirements
defined
in
MP­
DOCS­
18.2,
AMWTP
Records
Management.
If
the
AMWTP
ceases
to
operate,
all
records
will
be
transferred
before
closeout.
Table
B­
7
provides
a
listing
of
records
designated
as
Lifetime
Records
and
Non­
Permanent
Records.
Nothing
in
this
QAPjP
is
intended
to
nor
should
it
be
interpreted
to
require
the
disclosure
of
any
U.
S.
Department
of
Energy
classified
information
to
persons
without
appropriate
clearance
to
view
such
information.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

33
B­
4b
Waste
Stream
Screening
and
Verification
of
TRU
Waste
After
the
AMWTP
had
prepared
this
QAPjP,
it
was
submitted
to
CBFO
for
approval.
After
approval,
the
QAPjP
was
implemented
and
the
program
subjected
to
audit
by
CBFO
prior
to
shipment
of
waste.
Additional
audits,
focusing
on
the
results
of
waste
characterization,
will
be
performed
at
least
annually.
CBFO
has
the
right
to
conduct
unannounced
audits
and
to
examine
any
records
that
are
related
to
the
scope
of
the
audit.

When
the
required
waste
stream
characterization
data
have
been
collected
by
the
AMWTP
and
the
initial
AMWTP
audit
has
been
successfully
completed,
the
SPM
will
verify
that
the
waste
stream
characterization
meets
the
applicable
QAPjP
requirements
as
part
of
the
project
level
verification.
If
the
waste
characterization
does
not
meet
the
applicable
requirements
of
the
QAPjP,
the
waste
stream
cannot
be
shipped
until
those
requirements
are
met.
The
SPM
will
then
complete
a
WSPF
(
Figure
B­
1)
and
submit
it
to
CBFO,
along
with
the
accompanying
Characterization
Information
Summary
for
that
waste
stream.
All
data
necessary
to
check
the
accuracy
of
the
WSPF
will
be
transmitted
to
CBFO
for
verification.
This
provides
notification
that
the
AMWTP
considers
that
the
waste
stream
(
identified
by
the
waste
stream
identification
number)
has
been
adequately
characterized
for
disposal
prior
to
shipment
to
WIPP.
If
the
waste
characterization
does
not
meet
the
applicable
requirements
of
the
WIPPWAP
the
mixed
waste
stream
cannot
be
managed,
stored,
or
disposed
of
at
WIPP
until
those
requirements
are
met.
If
the
CBFO
determines
(
through
the
data
comparison)
that
the
characterization
information
is
adequate,
the
WSPF
will
be
approved.
Prior
to
the
first
shipment
of
containers
from
the
approved
waste
stream,
the
approved
WSPF
and
accompanying
Characterization
Information
Summary
will
be
provided
to
NMED.
If
the
data
comparison
indicates
the
analyzed
containers
have
hazardous
wastes
not
present
on
the
WSPF,
or
a
different
Waste
Matrix
Code
applies,
the
WSPF
is
in
error
and
shall
be
resubmitted.
Ongoing
WSPF
examination
is
discussed
in
detail
in
Section
B­
4b(
1)(
ii)
of
the
WIPP­
WAP.

For
subsequent
shipments,
the
AMWTP
will
also
transmit
the
data
on
a
container
basis
via
the
WWIS
prior
to
shipment
of
that
container.
This
data
submittal
can
occur
at
any
time
as
the
data
are
being
collected,
but
will
be
complete
for
each
container
prior
to
shipment
of
that
container.
WWIS
will
conduct
internal
limit
checks
based
on
the
approved
WSPF.
The
WWIS
automatically
will
notify
the
AMWTP
if
any
of
the
supplied
data
fails
to
meet
the
requirements
of
the
edit
and
limit
checks
via
an
appropriate
error
message.
The
AMWTP
will
correct
the
discrepancy
with
the
waste
or
the
waste
data
and
re­
transmit
the
corrected
data
prior
to
acceptance
of
the
data
by
the
WWIS.
The
CBFO
will
compare
ongoing
sampling/
analysis
characterization
data
obtained
and
submitted
via
the
WWIS
to
the
approved
WSPF.
If
this
comparison
shows
that
containers
have
hazardous
wastes
not
reported
on
the
WSPF,
or
a
different
Waste
Matrix
Code
applies,
the
data
are
rejected
and
the
waste
containers
are
not
accepted
for
shipment.

AMWTP
will
only
have
access
to
the
data
transmitted
by
AMWTP,
and
only
until
the
data
have
been
formally
accepted
by
CBFO.
After
the
data
have
been
accepted,
the
data
can
only
be
changed
by
a
WWIS
Data
Administrator.

If
discrepancies
arise
as
a
result
of
the
CBFO
review
of
the
WSPF
or
any
other
data,
the
AMWTP
will
be
contacted
by
CBFO
and
required
to
provide
the
necessary
additional
information
to
resolve
the
discrepancy
and
resubmit
the
data
before
that
waste
stream
or
container
is
approved
for
disposal
at
the
WIPP
facility.
NCRs
will
be
issued
as
appropriate
to
identify,
document,
and
report
the
discrepancy.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

34
The
Characterization
Information
Summary
will
indicate
that
the
waste
has
been
checked
for
the
characteristics
of
ignitability,
corrosivity,
and
reactivity.

At
the
AMWTP,
the
Hazardous
Waste
Manifest
Information
will
include
at
a
minimum:

 
Generator/
storage
site
name
and
EPA
Idaho
(
ID)

 
Generator/
storage
site
contact
name
and
phone
number
 
Quantity
of
waste
 
List
of
the
hazardous
waste
codes
in
the
shipment
 
List
of
all
container
IDs
 
Signature
of
authorized
generator
representative.

Discrepancies
may
be
identified
during
manifest
examination
and
container
bar­
code
WWIS
data
comparison.
A
manifest
discrepancy
is
a
difference
between
the
quantity
or
type
of
hazardous
waste
designated
on
the
manifest
and
the
quantity
or
type
of
hazardous
waste
the
WIPP
facility
actually
receives.
The
AMWTP
technical
contact
(
as
listed
on
the
manifest)
will
be
contacted
to
resolve
the
discrepancy.
Errors
on
the
manifest
can
be
corrected
by
the
WIPP
facility
with
a
verbal
(
followed
by
a
mandatory
written)
concurrence
by
the
AMWTP
technical
contact.
All
discrepancies
that
are
unresolved
within
fifteen
days
of
receiving
the
waste
at
the
WIPP
facility
will
be
immediately
reported
to
the
NMED
in
writing
by
CBFO.
If
the
manifest
discrepancies
have
not
been
resolved
within
thirty
days
of
waste
receipt,
the
shipment
will
be
returned
to
the
AMWTP.

With
the
initial
shipment
of
a
TRU
mixed
waste
stream,
AMWTP
will
provide
WIPP
with
a
notice
that
the
waste
is
not
prohibited
from
land
disposal
[
The
Land
Disposal
Restriction
Notice(
LDR)].
The
Notice
will
be
prepared
per
the
requirements
of
20
NMAC
4.1.800
[
incorporating
40
CFR
268.7(
a)(
4)].
At
the
AMWTP,
the
LDR
Notice
Information
includes:

 
EPA
Hazardous
Waste
Number(
s)
and
manifest
number
of
first
shipment
of
a
mixed
waste
stream
 
Date
the
waste
is
subject
to
prohibition
 
Statement
that
the
waste
is
not
prohibited
from
land
disposal
at
WIPP.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

35
Table
B­
1,
Summary
of
Hazardous
Waste
Characterization
Requirements
for
Transuranic
Mixed
Waste
a
PARAMETER
TECHNIQUES
AND
PROCEDURE
SITE­
SPECIFIC
DATA
COLLECTION
PROCEDURES
SITE­
SPECIFIC
DATA
RELEASE
PROCEDURES
RTR/
Visual
Examination
Retrievably
Stored
Waste
Radiography
(
RTR)
And
VE
(
to
Confirm
RTR),
or
VE
in
lieu
of
RTR
RTR/
Visual
Examination
(
refer
to
Section
B1­
3
and
Section
B3­
4)

Retrievably
Stored
Waste
INST­
OI­
12,
Real
Time
Radiography
Operations
INST­
OI­
16,
Drum
Coring
Operations
(
VE
section)
RTR/
Visual
Examination
Retrievably
Stored
Waste
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Newly
Generated
Waste
Visual
Verification
of
Acceptable
Knowledge
Newly
Generated
Waste
INST­
OI­
16,
Drum
Coring
Operations
(
VE
section)
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
Newly
Generated
Waste
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Physical
Waste
Form
Summary
Category
Names
S3000
Homogeneous
Solid
S4000
Soil/
Gravel
Repackaging
of
Retrievably
Stored
Waste
Visual
Verification
of
Acceptable
Knowledge
Repackaging
of
Retrievably
Stored
Waste
INST­
OI­
16,
Drum
Coring
Operations
(
VE
section)

INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
Repackaging
of
Retrievably
Stored
Waste
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Summary
Category
Names
S5000
Debris
Waste
Retrievably
Stored
Waste
Radiography
(
RTR)
And
VE
(
to
Confirm
RTR),
or
VE
in
lieu
of
RTR
Retrievably
Stored
Waste
INST­
OI­
12,
Real
Time
Radiography
Operations
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
Retrievably
Stored
Waste
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Newly
Generated
Waste
Visual
Verification
of
Acceptable
Knowledge
Newly
Generated
Waste
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
Newly
Generated
Waste
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Repackaging
of
Retrievably
Stored
Waste
Visual
Verification
of
Acceptable
Knowledge
Repackaging
of
Retrievably
Stored
Waste
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
Repackaging
of
Retrievably
Stored
Waste
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

36
Table
B­
1,
Summary
of
Hazardous
Waste
Characterization
Requirements
for
Transuranic
Mixed
Waste
a
(
continued)
PARAMETER
TECHNIQUES
AND
PROCEDURE
SITE­
SPECIFIC
DATA
COLLECTION
PROCEDURES
SITE­
SPECIFIC
DATA
RELEASE
PROCEDURES
Headspace
Gas
Sampling/
Analysis
Gas
Volatile
Organic
Compounds
Benzene
Alcohols
and
Ketones
Bromoform
Acetone
Carbon
tetrachloride
Butanol
Chlorobenzene
Methanol
Chloroform
Cyclohexane
d
Methyl
ethyl
ketone
1,1­
Dichloroethane
Methyl
isobutyl
ketone
1,2­
Dichloroethane
1,1­
Dichloroethylene
(
cis)­
1,2­
Dichloroethylene
(
trans)­
1,2­
Dichloroethylene
Ethyl
benzene
Ethyl
ether
Formaldehydee
Hydrazinef
Methylene
chloride
1,1,2,2­
Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1­
Trichloroethane
Trichloroethylene
1,1,2­
Trichloro­
1,2,2­
trifluoroethane
1,2,4­
Trimethylbenzene
d
1,3,5­
Trimethylbenzene
d
Xylenes
Gas
Analysis
Gas
Chromatography/
Mass
Spectroscopy
(
GC/
MS),
EPA
TO­
14
or
modified
SW­
846
8240/
8260
GC/
Flame
Ionization
Detector
(
FID),
for
alcohols
and
ketones,
SW­
846
8015
Analysis
(
refer
to
Section
B1­
1
and
Section
B3­
5)

INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations
Analysis
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Total
Volatile
Organic
Compounds
Acetone
Benzene
Bromoform
Butanol
Carbon
disulfide
Carbon
tetrachloride
Chlorobenzene
Chloroform
1,4­
Dichlorobenzene
b
1,2­
Dichlorobenzene
b
1,2­
Dichloroethane
1,1­
Dichloroethylene
Ethyl
benzene
Ethyl
ether
Formaldehydee
Hydrazinef
Isobutanol
Methanol
Methyl
ethyl
ketone
Methylene
chloride
Pyridineb
1,1,2,2­
Tetrachloroethane
Tetrachloroethylene
Toluene
trans­
1,2­
Dichloroethylene
1,1,2­
Trichloro­
1,2,2­
trifluoroethane
Trichlorofluoromethane
1,1,1­
Trichloroethane
1,1,2­
Trichloroethane
Trichloroethylene
Vinyl
chloride
Xylenes
Total
Volatile
Organic
Compound
Analysis
TCLP,
SW­
846
1311
GC/
MS,
SW­
846
8260
or
8240
GC/
FID,
SW­
846
8015
Acceptable
Knowledge
for
Summary
Category
S5000
(
Debris
Wastes)
Analysis
(
refer
to
Section
B3­
6)

ACMM­
9260,
Volatile
Organic
Compounds
by
Gas
Chromatography
Mass
Spectrometry
(
GS/
MS)

ACMM­
9441,
Determination
of
Nonhalongenated
Volatile
Organics
by
Gas
Chromatography
Analysis
MCP­
2008,
Analytical
Data
Recording,
Review
&
Reporting
PLN­
342,
Analytical
Laboratories
Department
Quality
Assurance
Plan
for
the
AMWTP
MP­
TRUW­
8.9,
Level
II
Data
Validation
Total
Semivolatile
Organic
Compounds
Cresols
1,4­
Dichlorobenzene
c
1,2­
Dichlorobenzene
c
2,4­
Dinitrophenol
2,4­
Dinitrotoluene
Hexachlorobenzene
Hexachloroethane
Nitrobenzene
Polychlorinated
biphenyls
(
i.
e.,
Arochlors:
1016,
1221,
1232,
1242,
1248,
1254,
1260)
Pentachlorophenol
Pyridine
c
Total
Semivolatile
Organic
Compound
Analysis
TCLP,
SW­
846
1311
GC/
MS,
SW­
846
8250
or
8270
GC/
ECD
for
PCBs
,
SW­
846
8082
Acceptable
Knowledge
for
Summary
Category
S5000
(
Debris
Wastes)
Analysis
(
refer
to
Section
B3­
7)

ACMM­
9500,
Sample
Preparation
for
Semi­
volatile
Compounds
and
Polychlorinated
Biphenyls
ACMM­
9270,
Semivolatile
Organic
Compounds
by
Gas
Chromatography/
Mass
Spectrometry
ACMM­
9080,
Determination
Polychlorinated
Biphenyls
(
PCBs)
by
Gas
Chromatography
Analysis
MCP­
2008,
Analytical
Data
Recording,
Review
&
Reporting
PLN­
342,
Analytical
Laboratories
Department
Quality
Assurance
Plan
for
the
AMWTP
MP­
TRUW­
8.9,
Level
II
Data
Validation
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

37
Table
B­
1,
Summary
of
Hazardous
Waste
Characterization
Requirements
for
Transuranic
Mixed
Waste
a
(
continued)
PARAMETER
TECHNIQUES
AND
PROCEDURE
SITE­
SPECIFIC
DATA
COLLECTION
PROCEDURES
SITE­
SPECIFIC
DATA
RELEASE
PROCEDURES
Total
or
TCLP
Metals
Antimony
Mercury
Arsenic
Nickel
Barium
Selenium
Beryllium
Silver
Cadmium
Thallium
Chromium
Vanadium
Lead
Zinc
Total
or
TCLP
Metals
Analysis
TCLP,
SW­
846
1311
ICP­
MS,
SW­
846
6020,
ICP
Emission
Spectroscopy,
SW­
846
6010
Atomic
Absorption
Spectroscopy
,
SW­
846
7000
Acceptable
Knowledge
for
Summary
Category
S5000
(
Debris
Wastes)
Analysis
(
refer
to
Section
B3­
8)

ACMM­
8909,
Microwave
Assisted
Digestion
of
Homogeneous
Solids
and
Soil/
Gravel
ACMM­
2901,
Determination
of
Metals
by
ICP­
AES
for
TRU
Waste
Characterization
ACMM­
2810,
Determination
of
Mercury
by
CVAA
for
TRU
Waste
Characterization
Analysis
MCP­
2008,
Analytical
Data
Recording,
Review
&
Reporting
PLN­
342,
Analytical
Laboratories
Department
Quality
Assurance
Plan
for
the
AMWTP
MP­
TRUW­
8.9,
Level
II
Data
Validation
Homogeneous
Solids
and
Soil/
Gravel
Sampling
Homogeneous
Solids
and
Soil/
Gravel
Sampling
EPA
SW­
846
Sampling
(
refer
to
Section
B1­
2
and
Section
B3­
3)

INST­
0I­
16,
Drum
Coring
Sampling
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
Nondestructive
Assay
(
NDA)
NDA
Refer
to
MP­
TRUW­
18.1,
AMWTP
Certification
of
INEEL
Contact­
Handled
Transuranic
Waste
NDA
INST­
OI­
14,
Drum
Assay
Operations
NDA
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
a
Permit
Attachment
B
b
Can
also
be
analyzed
as
a
semi­
volatile
organic
compound.
c
Can
also
be
analyzed
as
a
volatile
organic
compound.
d
These
three
compounds
are
not
included
in
the
WIPP­
WAP,
but
are
included
in
the
list
of
Flammable
Volatile
Organic
Compounds
specified
in
the
TRUPACT­
II
SAR.
e
Only
required
for
homogeneous
solids
and
soil/
gravel
from
Los
Alamos
National
Laboratory
and
Savanna
River
Site.
f
Only
required
for
homogeneous
solids
and
soil/
gravel
from
Oak
Ridge
National
Laboratory
and
Savanna
River
Site.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

38
Table
B­
2.
Maximum
allowable
VOC
room­
averaged
headspace
concentration
limits
parts­
per­
million
by
volume
(
ppmv).

Compound
VOC
Headspace
Concentration
Limits
(
ppmv)
a,
b,
c
Carbon
Tetrachloride
9625
Chlorobenzene
13000
Chloroform
9930
1,1­
Dichloroethene
5490
1,2­
Dichloroethane
2400
Methylene
Chloride
100000
1,1,2,2­
Tetrachloroethane
2960
Toluene
11000
1,1,1­
Trichloroethane
33700
a.
No
headspace
limits
for
other
VOCs
exist
and
no
headspace
limits
for
individual
containers
exist.

b.
The
limits
identified
in
this
table
are
specific
to
WIPP
disposal
operations.
The
limits
identified
in
this
table
are
not
applicable
to
the
storage
of
containers
at
the
Site.

c.
At
the
AMWTP,
if
an
individual
container
has
been
analyzed
and
reported
to
contain
VOC
concentrations
higher
than
specified
in
this
table,
the
container
may
be
approved
for
disposal
by
WIPP
M&
O
Contractor
on
a
case­
by­
case
basis.
Approval
for
containers
exceeding
the
average
limits
will
be
obtained
through
the
WWIS
exception
process.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

39
Table
B­
3,
Headspace
Gas:
Target
Analyte
List
and
Methods
PARAMETER
EPA
SPECIFIED
ANALYTICAL
METHOD
Benzene
Bromoform
Carbon
tetrachloride
Chlorobenzene
Chloroform
Cyclohexane
d
1,1­
Dichloroethane
1,2­
Dichloroethane
1,1­
Dichloroethylene
(
cis)­
1,2­
Dichloroethylene
(
trans)­
1,
2­
Dichloroethylene
Ethyl
benzene
Ethyl
ether
Formaldehydeb
Hydrazine
c
Methylene
chloride
1,1,2,2­
Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1­
Trichloroethane
Trichloroethylene
1,1,2­
Trichloro­
1,2,2­
trifluoroethane
1,2,4­
Trimethylbenzene
d
1,3,5­
Trimethylbenzene
d
Xylenes
EPA:
Modified
TO­
14a;
Modified
8240/
8260
EPA
­
Approved
FTIRS
Acetone
Butanol
Methanol
Methyl
ethyl
ketone
Methyl
isobutyl
ketone
EPA:
Modified
TO­
14a;
Modified
8240/
8260
Method
8015
EPA
­
Approved
FTIRS
a
U.
S.
Environmental
Protection
Agency
(
EPA),
"
Compendium
Method
TO­
14,
the
Determination
of
Volatile
Organic
Compounds
(
VOC)
in
Ambient
Air
Using
SUMMA
®
Passivated
Canister
Sampling
and
Gas
Chromatographic
Analysis,"
in
Compendium
of
Methods
for
the
Determination
of
Toxic
Organic
Compounds
on
Ambient
Air.
Research
Triangle
Park,
North
Carolina,
Quality
Assurance
Division,
Monitoring
System
Laboratory,
U.
S.
EPA.
The
most
current
revision
of
the
specified
methods
may
be
used.
b
Required
only
for
containers
of
homogeneous
solids
and
soil/
gravel
waste
from
Los
Alamos
National
Laboratory
and
Savannah
River
Site.
c
Required
only
for
containers
of
homogeneous
solids
and
soil/
gravel
waste
from
Oak
Ridge
National
Laboratory
and
the
Savannah
River
Site.
d
These
three
compounds
are
not
included
in
the
WIPP­
WAP,
but
are
included
in
the
list
of
Flammable
Volatile
Organic
Compounds
specified
in
the
TRUPACT­
II
SAR.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

40
Table
B­
4,
Required
Organic
Analyses
and
Test
Methods
Organized
by
Organic
Analytical
Groups
ORGANIC
ANALYTICAL
GROUP
REQUIRED
ORGANIC
ANALYSES
EPA
SPECIFIED
ANALYTICAL
METHOD
a,
e
Nonhalogenated
Volatile
Organic
Compounds
(
VOCs)
Acetone
Isobutanol
Benzene
Methanol
n­
Butanol
Methyl
ethyl
ketone
Carbon
disulfide
Toluene
Ethyl
benzene
Xylenes
Ethyl
ether
Formaldehyde
Hydrazineb
8015
8240
8260
Halogenated
VOCs
Bromoform
Carbon
tetrachloride
Chlorobenzene
Chloroform
1,2­
Dichloroethane
1,1­
Dichloroethylene
(
trans)­
1,
2­
Dichloroethylene
Methylene
chloride
1,1,2,2­
Tetrachloroethane
Tetrachloroethylene
1,1,2­
Trichloroethane
1,1,1­
Trichloroethane
Trichloroethylene
Trichlorofluoromethane
1,1,2­
Trichloro­
1,2,2­
trifluoroethane
Vinyl
Chloride
8015
8240
8260
Semivolatile
Organic
Compounds
(
SVOCs)
Cresols
(
o,
m,
p)
1,2­
Dichlorobenzenec
1,4­
Dichlorobenzenec
2,4­
Dinitrophenol
2,4­
Dinitrotoluene
Hexachlorobenzene
Hexachloroethane
Nitrobenzene
Polychlorinated
biphenyls
(
PCB)
d
Pentachlorophenol
Pyridinec
8250
8270
8082
(
for
PCBs
only)

a
U.
S.
Environmental
Protection
Agency
(
EPA),
"
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods,"
SW­
846,
Third
Edition.
b
Generator/
Storage
Sites
will
have
to
develop
an
analytical
method
for
hydrazine.
This
method
will
be
submitted
to
the
CBFO
for
approval.
c
These
compounds
may
also
be
analyzed
as
VOCs
by
SW­
846
Methods
8240
and
8260.
d
Transformer
oils
containing
PCBs
have
been
identified
in
a
limited
number
of
waste
streams
included
in
the
organic
sludges
Waste
Matrix
Code.
Therefore,
only
waste
streams
included
in
the
solidified
organics
final
waste
form
or
which
AK
indicates
may
contain
PCBs
shall
be
analyzed
for
PCBs.
e
TCLP
(
SW­
846
Method
1311)
may
be
used
to
determine
if
compounds
in
20
NMAC
4.1.200
(
incorporating
40
CFR
261,
Subpart
C)
exhibit
a
toxicity
characteristic.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

41
Table
B­
5,
Summary
of
Sample
Preparation
and
Analytical
Methods
for
Metals
PARAMETERS
EPA
SPECIFIED
ANALYTICAL
METHODS
a,
b
Sample
Preparation
3051,
or
equivalent,
as
appropriate
for
analytical
method
Total
Antimony
6010,
6020,
7040,
7041,
7062
Total
Arsenic
6010,
6020,
7060,
7061,
7062
Total
Barium
6010,
6020,
7080,
7081
Total
Beryllium
6010,
6020,
7090,
7091
Total
Cadmium
6010,
6020,
7130,
7131
Total
Chromium
6010,
6020,
7190,
7191
Total
Lead
6010,
6020,
7420,
7421
Total
Mercury
7471
Total
Nickel
6010,
6020,
7520,
7521
Total
Selenium
6010,
7740,
7741,
7742
Total
Silver
6010,
6020,
7760,
7761
Total
Thallium
6010,
6020,
7840,
7841
Total
Vanadium
6010,
7910,
7911
Total
Zinc
6010,
6020,
7950,
7951
a
U.
S.
Environmental
Protection
Agency
(
EPA),
1996.
"
Test
Methods
for
Evaluating
Solid
Waste,"
Laboratory
Manual
Physical/
Chemical
Methods,
SW­
846,
3rd
ed.,
U.
S.
Environmental
Protection
Agency,
Office
of
Solid
Waste
and
Emergency
Response,
Washington,
D.
C.
b
TCLP
(
SW­
846
Method
1311)
may
be
used
to
determine
if
compounds
in
20
NMAC
4.1.200
(
incorporating
40
CFR
261,
Subpart
C)
exhibit
a
toxicity
characteristic.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

42
Table
B­
6,
Summary
of
Parameters,
Characterization
Methods,
and
Rationale
for
CH
Transuranic
Waste
(
For
Both
Retrievably
Stored
Waste
and
Newly
Generated
Waste
Unless
Otherwise
Specified)
WASTE
MATRIX
CODE
SUMMARY
CATEGORIES
WASTE
MATRIX
CODE
GROUPS
CHARACTERIZATION
PARAMETER
METHOD
RATIONALE
S3000­
Homogeneous
Solids
S4000­
Soil/
Gravel
 
Solidified
inorganics
 
Salt
waste
 
Solidified
organics
 
Contaminated
soil/
debris
Physical
waste
form
Retrievably
Stored
100%
radiography
or
visual
examination
Newly
Generated
Documentation
and
visual
verification
c
or
radiography.
Applies
to
100%
of
containers.
 
Verify
waste
matrix
 
Demonstrate
compliance
with
waste
acceptance
criteria
(
e.
g.,
no
free
liquids,
no
incompatible
wastes,
no
compressed
gases)

Headspace
gases
 
Gas
volatile
organic
compounds
(
VOCs)
100%
gas
sampling
and
analysis
or
statistical
sampling
a,

b
(
see
Table
B­
3)
 
Quantify
concentration
of
flammable
VOCs
 
Determine
potential
flammability
of
transuranic
(
TRU)
mixed
waste
headspace
gases
 
Quantify
concentrations
of
VOC
constituents
in
headspace
of
containers
 
Ensure
that
environmental
performance
standards
are
not
exceeded
Hazardous
constituents
 
TCLP
or
total
metals
 
TCLP
or
total
VOCs
 
TCLP
or
total
semi­
VOCs
Statistical
sampling
b
 
Determine
characteristic
metals
and
organics
 
Determine
total
quantity
of
metals,
VOCs,
and
semi­
VOCs
S5000
 
Debris
Waste
 
Uncategorized
metal
(
metal
waste
other
than
lead/
cadmium)
 
Lead/
cadmium
waste
 
Inorganic
nonmetal
waste
 
Combustible
waste
 
Graphite
waste
 
Heterogeneous
waste
 
Composite
filter
waste
Physical
waste
form
Retrievably
Stored
100%
Radiography
Visual
examination
(
statistical
sample)
b
or
visual
examination
Newly
Generated
Documentation
and
visual
verification
c
or
radiography.
Applies
to
100%
of
containers.
 
Verify
waste
matrix
 
Demonstrate
compliance
with
waste
acceptance
(
e.
g.,
no
free
liquids,
no
incompatible
wastes,
no
compressed
gases)

Headspace
gases
 
Gas
VOCs
100%
gas
sampling
and
analysis
 
Quantify
concentration
of
flammable
VOCs
 
Determine
potential
flammability
of
TRU
waste
headspace
gases
 
Quantify
concentrations
of
VOC
constituents
in
headspace
of
containers
 
Ensure
that
environmental
performance
standards
are
not
exceeded
 
Verify
AK
Hazardous
constituents
 
TCLP
or
total
metals
 
TCLP
or
total
VOCs
 
TCLP
or
total
semi­
VOCs
Acceptable
knowledge
 
Determine
characteristic
metals
and
organics
 
Determine
total
quantity
of
metals,
VOCs,
and
semi­
VOCs
a
Applies
to
certain
waste
streams
that
meet
the
conditions
in
Section
B­
3a(
1).
b
Number
determined
as
specified
in
Section
B2
of
this
document.
c
Refer
to
the
discussion
in
Section
B4
of
this
document.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

43
Table
B­
7,
Required
Program
Records
Maintained
in
AMWTP
Project
Files
LIFETIME
RECORDS
·
Field
sampling
data
forms
·
Field
and
laboratory
chain­
of­
custody
forms
·
Test
facility
and
laboratory
batch
data
reports
·
Waste
Stream
Characterization
Package
·
Sampling
Plans
·
Data
reduction,
validation,
and
reporting
documentation
·
Acceptable
knowledge
documentation
·
Data
reconciliation
report
·
Waste
Stream
Profile
Form
and
Characterization
Information
Summary
NON­
PERMANENT
RECORDS
·
Nonconformance
documentation
·
Variance
documentation
·
Assessment
documentation
·
Gas
canister
tags
·
Methods
performance
documentation
·
Performance
Demonstration
Program
documentation
·
Sampling
equipment
certifications
·
Calculations
and
related
software
documentation
·
Training/
qualification
documentation
·
QAPjPs
(
generator/
storage
sites)
documentation
(
all
revisions)
·
Calibration
documentation
·
Analytical
raw
data
·
Procurement
documentation
·
QA
procedures
(
all
revisions)
·
Technical
implementing
procedures
(
all
revisions)
·
Audio/
video
recording
(
radiography,
visual
examination
(
to
confirm
RTR),
etc.)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

44
Table
B­
8,
WIPP
Waste
Information
System
Data
Fields
a
CHARACTERIZATION
MODULE
DATA
FIELDS
b
Container
ID
c
Generator
EPA
ID
Generator
Address
Generator
Name
Generator
Contact
Hazardous
Code
Headspace
Gas
Sample
Date
Headspace
Gas
Analysis
Date
Layers
of
Packaging
Liner
Exists
]
Liner
Hole
Size
Filter
Model
Number
of
Filters
Installed
Headspace
Gas
Analyte
d
Headspace
Gas
Concentration
d
Headspace
Gas
Char.
Method
d
Total
VOC
Char.
Method
d
Total
Metals
Char.
Method
d
Total
Semi­
VOC
Char.
Method
d
Item
Description
Code
Haz.
Manifest
Number
NDE
Complete
e
PCB
Concentration
Total
VOC
Sample
Date
Total
VOC
Analysis
Date
Total
VOC
Analyte
Name
d
Total
VOC
Analyte
Concentration
d
Total
Metal
Sample
Date
Total
Metal
Analysis
Date
Total
Metal
Analyte
Name
d
Total
Metal
Analyte
Concentration
d
Semi­
VOC
Sample
Date
Semi­
VOC
Analysis
Date
Semi­
VOC
Analyte
Name
d
Semi­
VOC
Concentration
d
Transporter
EPA
ID
Transporter
Name
Visual
Exam
Container
e
Waste
Material
Parameter
d
Waste
Material
Weight
d
Waste
Matrix
Code
Waste
Matrix
Code
Group
Waste
Stream
Profile
Number
CERTIFICATION
MODULE
DATA
FIELDS
Container
ID
c
Container
type
Container
Weight
Contact
Dose
Rate
Container
Certification
date
Container
Closure
Date
Handling
Code
TRANSPORTATION
MODULE
DATA
Contact
Handled
Package
Number
Assembly
Number
f
Container
IDs
c,
d
ICV
Closure
Date
Ship
Date
Receive
Date
DISPOSAL
MODULE
DATA
Container
ID
c
Disposal
Date
Disposal
Location
a
This
is
not
a
complete
list
of
the
WWIS
data
fields.
b
Some
of
the
fields
required
for
characterization
are
also
required
for
certification
and/
or
transportation.
c
Container
ID
is
the
main
relational
field
in
the
WWIS
Database.
d
This
is
a
multiple
occurring
field
for
each
analyte,
nuclide,
etc.
e
These
are
logical
fields
requiring
only
a
yes/
no.
f
Required
for
7
packs
of
55­
gal.
drums,
4­
packs
of
85­
gal
drums,
or
3­
packs
of
100­
gal
drums
to
tie
all
of
the
drums
in
that
assembly
together.
This
facilitates
the
identification
of
waste
containers
in
a
shipment
without
need
to
breakup
the
assembly.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

45
WIPP
WASTE
STREAM
PROFILE
FORM
Waste
Stream
Profile
Number:
(
1)

Generator
site
name:
(
2)
Technical
contact:
(
3)

Generator
site
EPA
ID:
(
2)
Technical
contact
phone
number:
(
3)

Date
of
audit
approved
by
NMED:
(
4)

Title,
version
number,
and
date
of
documents
used
for
WIPP­
WAP
certification:
(
4)

Did
your
facility
generate
this
waste?
Yes
No
If
no,
provide
the
name
and
EPA
ID
of
the
original
generator:

(
5)

Waste
Stream
Information1
WIPP
ID:
(
6)
Summary
Category
Group:
(
7)
Waste
Matrix
Code
Group:
(
8)
Waste
Stream
Name:
(
9)
Description
from
the
WTWBIR:
(
10)
(
10)

Defense
TRU
Waste:
Yes
No
Check
one:
CH
RH
Number
of
SWBs
(
11)
Number
of
Drums
Number
of
Canisters
(
11)
Batch
Data
Report
numbers
supporting
this
waste
stream
characterization:
(
12)

List
applicable
EPA
Hazardous
Waste
Codes:
2
(
13)

Applicable
TRUCON
Content
Codes:
(
14)

Acceptable
Knowledge
Information1
[
For
the
following,
enter
supporting
the
documentation
used
(
i.
e.,
references
and
dates)]

Required
Program
Information
Map
of
site:
(
15)
Facility
mission
description:
(
15)
Description
of
operations
that
generate
waste:
(
15)
(
15)

Waste
identification/
categorization
schemes:
(
15)

Types
and
quantities
of
waste
generated:
(
15)

Correlation
of
waste
streams
generated
from
the
same
building
and
process,
as
appropriate:
(
15)
(
15)
Waste
certification
procedures:
(
15)

Required
Waste
Stream
Information
Area(
s)
and
building(
s)
from
which
the
waste
stream
was
generated:
(
16)

Waste
stream
volume
and
time
period
of
generation:
(
16)

Waste
generating
process
description
for
each
building:
(
16)

Process
flow
diagrams:
(
16)

Material
inputs
or
other
information
identifying
chemical/
radionuclide
content
and
physical
waste
form:
(
16)

(
16)

Figure
B­
1,
WIPP
Waste
Stream
Profile
Form
(
example
only)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

46
Which
Defense
Activity
generated
the
waste:
(
check
one)
(
16)

Weapons
activities
including
defense
inertial
confinement
fusion
Naval
Reactors
development
Verification
and
control
technology
Defense
research
and
development
Defense
nuclear
waste
and
material
by
products
management
Defense
nuclear
material
production
Defense
nuclear
waste
and
materials
security
and
safeguards
and
security
investigations
Supplemental
Documentation
Process
design
documents:
(
17)
Standard
operating
procedures:
(
17)
Safety
Analysis
Reports:
(
17)
Waste
packaging
logs:
(
17)
Test
plans/
research
project
reports:
(
17)
Site
databases:
(
17)
Information
from
site
personnel:
(
17)
Standard
industry
documents:
(
17)
Previous
analytical
data:
(
17)
Material
safety
data
sheets:
(
17)
Sampling
and
analysis
data
from
comparable/
surrogate
Waste:
(
17)
Laboratory
notebooks:
(
17)

Sampling
and
Analysis
Information2
For
the
following,
when
applicable,
enter
procedure
title(
s),
number(
s)
and
date(
s))
Radiography:
(
18)
Visual
Examination:
(
18)
Headspace
Gas
Analysis
VOCs:
(
19)
Flammable:
(
19)
Other
gases
(
specify):
(
19)
Homogeneous
Solids/
Soils/
Gravel
Sample
Analysis
Total
metals:
(
20)
PCBs:
(
20)
VOCs:
(
20)
Nonhalogenated
VOCs:
(
20)
Semi­
VOCs:
(
20)
Other
(
specify):
(
20)

Waste
Stream
Profile
Form
Certification:

I
hereby
certify
that
I
have
reviewed
the
information
in
this
Waste
Stream
Profile
Form,
and
it
is
complete
and
accurate
to
the
best
of
my
knowledge.
I
understand
that
this
information
will
be
made
available
to
regulatory
agencies
and
that
there
are
significant
penalties
for
submitting
false
information,
including
the
possibility
of
fines
and
imprisonment
for
knowing
violations.

(
21)

Signature
of
Site
Project
Manager
Printed
Name
and
Title
Date
NOTE:
(
1)
Use
back
of
sheet
or
continuation
sheets,
if
required.

(
2)
If
radiography,
visual
examination,
headspace
gas
analysis,
and/
or
homogeneous
solids/
soils/
gravel
sample
analysis
were
used
to
determine
EPA
Hazardous
Waste
Codes,
attach
signed
Characterization
Information
Summary
documenting
this
determination.

Figure
B­
1,
WIPP
Waste
Stream
Profile
Form
(
example
only,
continued)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

47
Package
Waste

Verify
initial
determination
of
waste
forms
through
VE,
during
packaging
or
perform
radiograpy

Weigh
,
measure,
categorize
waste
by
material
parameters
Newly
Generated
Waste
S3000
Homogenous
Do
NDA
results
support
previous
determinations
made
by
using
acceptable
knowledge?

Does
HSG
data
support
acceptable
knowledge
hazardous
waste
designation?

Do
S/
A
results
confirm
acceptable
knowledge?
Return
waste
to
population
or
other
problem
resolution
system
Unable
to
verify
AK
waste
form
during
packaging
using
VE?
Assign
waste
stream
and
make
initial
radionuclide
content
(
AK)
waste
material
parameters
(
AK)
hazardous
waste
determination
Verify
process
operated
within
administrative
controls?

Uncontrolled
or
unexpected
event
that
could
affect
waste
characteristics
verified
during
packaging
id'd?

Unable
to
reconcile
100%
NDA
or
previous
radioassay
reconciled
with
WAC
requirements
STOP
STOP
Add
additional
EPA
hazardous
waste
codes
Extract
sample
for
chemical
analysis

minimum
of
1container/
year/
waste
stream
sampled/
analyzed
Radiography
performed?
Verifications
with
original
acceptable
knowledge
determination
performance?
See
retrievably
stored
waste
process
No
chemical
analysis:
hazardous
waste
characterized
by
acceptable
knowledge
only
Final
Waste
Characterization
Add
additional
EPA
codes
Prepare
Waste
Stream
Profile
For
or
compare
to
existing
form
Waste
within
existing
profile?
Initiate/
Continue
verification
process
Re­
evaluate/
Reassign
Conduct
HSG
analysis
S4000
Soil/
Gravel
S5000
Debris
Waste
unacceptable
at
WIPP
W/
O
additional
characterization
considered
a
batch
process
No
Yes
Yes
No
Yes
No
No
Yes
Yes
No
No
No
Yes
Yes
Yes
Not
Specified
in
WAP
Not
Specified
in
WAP
*
AK
=
Acceptable
Knowledge
VE
=
Visual
Examination
Newly
Generated
TRU
Waste
Containers:
Characterization
Process
Figure
B­
2,
Data
Collection
Design
for
Characterization
of
Newly
Generated
Waste
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

48
Figure
B­
3,
Data
Collection
Design
for
Characterization
of
Retrievably
Stored
Waste
Retrievably
Stored
Waste
Use
acceptable
knowledge
to
assign
summary
waste
category
group
and
waste
stream
and
make
initial
designations
(
e.
g.,
radionuclide
content
and
hazardous
waste
designation).

Perform
radiography
or
visual
examination
­
100%
examination
100%
NDA
or
previous
radioassay
reconciled
with
WAC
requirements
Repackaged?
Becomes
Newly
Generated
Prohibited
item(
s)
identified?
Repackage/
reassign
waste
stream,
if
required
Visual
exam
and/
or
radiography
verify
acceptable
knowledge
characterization?

Unable
to
reconcile
Perform
Radioassay
Revise
AK
for
Radionuclides
Do
NDA
results
support
previous
determinations
made
by
using
acceptable
knowledge?

Conduct
HSG
analysis
Does
HSG
data
support
acceptable
knowledge
hazardous
waste
designation?
Add
Additional
EPA
hazardous
waste
codes
Sample
and
analyze
a
statistically
selected
population
from
each
waste
stream
­
minimum
of
5
drums/
waste
stream
or
process
batch
­
cycle
process
if
5
not
enough,
could
characterize
entire
waste
stream
Visual
examination
of
statistically
selected
portion
of
drums
that
were
radioassayed
No
chemical
analysis,
hazardous
waste
characterized
by
acceptable
knowledge
only
S3000
Homogenous
S4000
Soil/
Gravel
S5000
Debris
Do
S/
A
results
confirm
acceptable
knowledge?
Does
VE
support
radiographic
results?
Redefine
waste
stream
and
increase
frequency
of
visual
examination
Add
Additional
EPA
hazardous
waste
codes
Final
Waste
Characterization
Prepare
Waste
Stream
Profile
Form
Waste
within
existing
waste
profile?
Initiate/
Continue
verification
process
Re­
evaluate/
reassign
No
No
No
Yes
Yes
Yes
Yes
No
No
Yes
Yes
No
Yes
No
Yes
No
No
Yes
AK
=
Acceptable
Knowledge
VE
=
Visual
Examination
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

49
Figure
B­
4,
TRU
Mixed
Waste
Screening
Flow
Diagram
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

50
B1.
WASTE
CHARACTERIZATION
SAMPLING
METHODS
The
AMWTP
uses
the
following
methods
for
the
characterization
of
TRU
waste
to
be
disposed
of
at
the
WIPP
facility.
These
methods
include
requirements
for
HSGS,
sampling
of
homogeneous
solids
and
soils/
gravel,
and
radiography.
Additionally,
this
section
provides
quality
control,
sample
custody,
and
sample
packing
and
shipping
requirements.

B1­
1
Headspace
Gas
Sampling
and
Analysis
Using
an
On­
Line
System
The
AMWTP
utilizes
an
On­
Line
Integrated
Headspace
Gas
Sampling
and
Analysis
System.

The
On­
Line
Integrated
HSG
Systems
analyzes
VOCs
using
the
GC/
MS
method.
The
on­
line
system
is
operated
in
compliance
with
the
requirements
of
the
WIPP­
WAP
as
presented
in
this
document.

The
On­
Line
Integrated
HSG
sampling
operations
are
described
in
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations,
which
list
the
specific
activities
and
requirements
necessary
to
prepare
and
test
the
sampling
equipment
to
ensure
sampling
readiness
and
for
obtaining
the
required
field
blank,
field
reference
standard,
and
headspace
samples.
These
activities
and
requirements
assure
that
the
sampling
and
analytical
QA
objectives
are
met.

B1­
1a
Method
Requirements
HSG
sampling
is
performed
in
an
appropriate
contamination
area
that
meets
the
facility
and
the
AMWTP
radiological
controls.

Before
sampling,
waste
containers
are
in
compliance
with
the
container
equilibrium
requirement
(
i.
e.,
72
hours
at
18
°
C
or
higher).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

51
B1­
1a(
1)
Summary
Category
S5000
Requirements
All
waste
containers
or
randomly
selected
containers
from
waste
streams
that
meet
the
conditions
for
reduced
headspace
gas
sampling
(
Section
B­
3a(
1);
designated
as
summary
category
S5000
(
Debris
waste)
shall
be
categorized
under
one
of
the
sampling
scenarios
shown
in
Table
B1­
5
and
depicted
in
Figure
B1­
1.
If
the
container
is
categorized
under
Scenario
1,
the
applicable
drum
age
criteria(
DAC)
from
Table
B1­
6
must
be
met
prior
to
headspace
gas
sampling.
If
the
container
is
categorized
under
Scenario
2,
the
applicable
Scenario
1
DAC
from
Table
B1­
6
must
be
met
prior
to
venting
the
container
and
then
the
applicable
Scenario
2
DAC
from
Table
B1­
7
must
be
met
after
venting
the
container.
The
DAC
for
Scenario
2
containers
that
contain
filters
or
rigid
liner
vent
holes
other
than
those
listed
in
Table
B1­
7
shall
be
determined
using
footnotes
"
a"
and
"
b"
in
Table
B1­
7.
Containers
that
have
not
met
the
Scenario
1
DAC
at
the
time
of
venting
must
be
categorized
under
Scenario
3.
Containers
categorized
under
Scenario
3
must
be
placed
into
one
of
the
Packaging
Configuration
Groups
listed
in
Table
B1­
8.
If
a
specific
packaging
configuration
cannot
be
determined
based
on
the
data
collected
during
packaging
and/
or
repackaging
(
Attachment
B,
Section
B­
3(
d)(
1),
a
conservative
default
Packaging
Configuration
Group
of
3
for
drums
and
6
for
Standard
Waste
Boxes
(
SWBs)
must
be
assigned,
provided
the
drums
do
not
contain
pipe
component
packaging.
If
a
container
is
designated
as
Packaging
Configuration
Group
4
(
i.
e.,
a
pipe
component),
the
headspace
gas
sample
must
be
taken
from
the
pipe
component
headspace.
The
DAC
for
Scenario
3
containers
that
contain
rigid
liner
vent
holes
that
are
undocumented
during
packaging
(
Attachment
B,
Section
B­
3(
d)(
1),
repackaging
(
Attachment
B,
Section
B­
3(
d)(
1),
and/
or
venting
(
Section
B1­
1a[
6][
ii])
shall
be
determined
using
the
default
conditions
in
footnote
"
b"
in
Table
1­
9.
The
DAC
for
Scenario
3
containers
that
contain
filters
that
are
either
undocumented
or
are
other
than
those
listed
in
Table
B1­
9
shall
be
determined
using
footnote
"
a"
in
Table
B1­
9.
Each
of
the
Scenario
3
containers
shall
be
sampled
for
headspace
gas
after
waiting
the
DAC
in
Table
B1­
9
based
on
its
packaging
configuration
(
note:
Packaging
Configuration
Groups
4,
5,
and
6
are
not
summary
category
group
dependent,
and
SWB
requirements
apply
when
the
SWB
itself
is
used
for
the
direct
loading
of
waste).

Drum
age
criteria
apply
only
to
55­
gallon
drums
and
standard
waste
boxes.
Drum
age
criteria
for
all
other
container
types
must
be
established
through
permit
modification
prior
to
acceptance
of
these
containers.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

52
B1­
1a(
2)
Summary
Category
S3000/
S4000
Requirements
All
waste
containers
or
randomly
selected
containers
from
waste
streams
that
meet
the
conditions
for
reduced
headspace
gas
sampling
(
Section
B­
3a(
1);
designated
as
summary
categories
S3000
(
Homogeneous
solids)
and
S4000
(
Soil/
gravel)
shall
be
categorized
under
one
of
the
sampling
scenarios
shown
in
Table
B1­
5
and
depicted
in
Figure
B1­
1.
If
the
container
is
categorized
under
Scenario
1,
the
applicable
DAC
from
Table
B1­
6
must
be
met
prior
to
headspace
gas
sampling.
If
the
container
is
categorized
under
Scenario
2,
the
applicable
Scenario
1
DAC
from
Table
B1­
6
must
be
met
prior
to
venting
the
container
and
then
the
applicable
Scenario
2
DAC
from
Table
B1­
7
must
be
met
after
venting
the
container.
The
DAC
for
Scenario
2
containers
that
contain
filters
or
rigid
liner
vent
holes
other
than
those
listed
in
Table
B1­
7
shall
be
determined
using
footnotes
"
a"
and
"
b"
in
Table
B1­
7.
Containers
that
have
not
met
the
Scenario
1
DAC
at
the
time
of
venting
must
be
categorized
under
Scenario
3.
Containers
categorized
under
Scenario
3
must
be
placed
into
one
of
the
Packaging
Configuration
Groups
listed
in
Table
B1­
8.
If
a
specific
packaging
configuration
cannot
be
determined
based
on
the
data
collected
during
packaging
and/
or
repackaging
(
Attachment
B,
Section
B­
3(
d)(
1),
a
conservative
default
Packaging
Configuration
Group
of
3
for
drums
and
6
for
Standard
Waste
Boxes
(
SWBs)
must
be
assigned,
provided
the
drums
do
not
contain
pipe
component
packaging.
If
a
container
is
designated
as
Packaging
Configuration
Group
4
(
i.
e.,
a
pipe
component),
the
headspace
gas
sample
must
be
taken
from
the
pipe
component
headspace.
The
DAC
for
Scenario
3
containers
that
contain
rigid
liner
vent
holes
that
are
undocumented
during
packaging
(
Attachment
B,
Section
B­
3(
d)(
1),
repackaging
(
Attachment
B,
Section
B­
3(
d)(
1),
and/
or
venting
(
Section
B1­
1a[
6][
ii])
shall
be
determined
using
the
default
conditions
in
footnote
"
b"
in
Table
B1­
10.
The
DAC
for
Scenario
3
containers
that
contain
filters
that
are
either
undocumented
or
are
other
than
those
listed
in
Table
B1­
10
shall
be
determined
using
footnote
"
a"
in
Table
B1­
10.
Each
of
the
Scenario
3
containers
shall
be
sampled
for
headspace
gas
after
waiting
the
DAC
in
Table
B1­
10
based
on
its
packaging
configuration
(
note:
Packaging
Configuration
Groups
4,
5,
and
6
are
not
summary
category
group
dependent,
and
SWB
requirements
apply
when
the
SWB
itself
is
used
for
the
direct
loading
of
waste).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

53
B1­
1a(
3)
General
Requirements
The
determination
of
packaging
configuration
consists
of
identifying
the
number
of
confinement
layers
and
the
identification
of
rigid
poly
liners
when
present.
AMWTP
shall
use
either
the
default
conditions
specified
in
Tables
B1­
7
through
B1­
10
for
retrievably
stored
waste
or
the
data
documented
during
packaging
(
Attachment
B,
Section
B­
3(
d)(
1),
repackaging
(
Attachment
B,
Section
B­
3(
d)(
1),
and/
or
venting
(
Section
B1­
1a[
6][
ii])
for
determining
the
appropriate
DAC
for
each
container
from
which
a
headspace
gas
sample
is
collected.
These
drum
age
criteria
are
to
ensure
that
the
container
contents
have
reached
90
percent
of
steady
state
concentration
within
each
layer
of
confinement
(
Lockheed
1995,
BWXT
2000).
The
following
information
must
be
reported
in
the
headspace
gas
sampling
documents
for
each
container
from
which
a
headspace
gas
sample
is
collected:

­
sampling
scenario
from
Table
B1­
5
and
associated
information
from
Tables
B1­
6
and/
or
TableB1­
7;
­
the
packaging
configuration
from
Table
B1­
8
and
associated
information
from
Tables
B1­
9,
or
B1­
10,
including
the
diameter
of
the
rigid
liner
vent
hole,
the
number
of
inner
bags,
the
number
of
liner
bags,
the
presence/
absence
of
drum
liner,
and
the
filter
hydrogen
diffusivity;
­
the
permit
 
required
equilibrium
time;
and
­
the
drum
age
For
all
retrievably
stored
waste
containers,
the
rigid
liner
vent
hole
diameter
must
be
assumed
to
be
0.3
inches
unless
a
different
size
is
documented
during
drum
venting
or
repackaging.
For
all
retrievably
stored
waste
containers,
the
filter
hydrogen
diffusivity
must
be
assumed
to
be
the
most
restrictive
unless
container­
specific
information
clearly
identifies
a
filter
model
and/
or
filter
diffusivity
characteristic
that
is
less
restrictive.
For
all
retrievably
stored
waste
containers
that
have
not
been
repackaged,
acceptable
knowledge
shall
not
be
used
to
justify
and
packaging
configuration
less
conservative
than
the
default
(
i.
e.,
Packaging
Configuration
Group
3
for
drums
and
6
for
SWBs).
For
information
reporting
purposes
listed
above,
AMWTP
may
report
the
default
packaging
configuration
for
retrievably
stored
waste
without
further
confirmation.

All
waste
containers
with
unvented
rigid
containers
greater
than
4
liters
(
exclusive
of
rigid
poly
liners)
are
either
subject
to
innermost
layer
of
containment
sampling
or
are
vented
prior
to
initiating
drum
age
and
equilibrium
criteria.
When
sampling
the
rigid
poly
liner
under
Scenario
1,
the
sampling
device
must
form
an
airtight
seal
with
the
rigid
poly
liner
to
ensure
that
a
representative
sample
is
collected
(
using
a
sampling
needle
connected
to
the
sampling
head
to
pierce
the
rigid
poly
liner,
and
that
allows
for
the
collection
of
a
representative
sample,
satisfies
this
requirement).
HSG
samples
are
analyzed
for
the
analytes
listed
in
Table
B3­
2.
Consistent
with
the
footnote
"
a"
in
Table
B1­
8,
any
waste
container
that
cannot
be
assigned
a
packaging
configuration
specified
in
Table
B1­
8,
shall
not
be
shipped
to,
or
accepted
for
disposal
at
WIPP.
If
additional
packaging
configurations
are
identified,
an
appropriate
Permit
Modification
will
be
submitted
to
incorporate
the
DAC
using
the
methodology
BWXT
(
2000).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

54
Drum
age
criteria
apply
only
to
55­
gallon
drums
and
standard
waste
boxes.
Drum
age
criteria
for
all
other
container
types
must
be
established
through
permit
modification
prior
to
acceptance
of
these
containers
at
WIPP.

The
sampling
manifold
and
sampling
heads
used
with
the
On­
Line
Integrated
HSG
System
and
SUMMA
®
or
equipment
meet
the
appropriate
general
guidelines
established
in
EPA's
Compendium
Method
TO­
14
as
modified
and
amended
in
the
WIPP
RCRA
Part
B
Permit,
Attachment
B,
Waste
Analysis
Plan.
Samples
are
directed
to
an
analytical
instrument
instead
of
being
collected
in
SUMMA
or
equivalent
canisters
when
a
singlesample
on­
line
integrated
manifold
system
is
used.
The
leak
proof
and
inert
nature
of
the
integrated
holding
area
interior
surface
has
been
demonstrated
and
documented.
Since
samples
will
not
be
transported
to
another
location
when
using
on­
line
integrated
sampling/
analysis
systems,
the
sample
custody
requirements
of
Section
B1­
4
and
B1­
5
do
not
apply.
The
same
sampling
manifold
and
sampling
heads
are
used
with
on­
line
integrated
sampling/
analysis
systems
and
all
of
the
requirements
associated
with
sampling
manifolds
and
sampling
heads
will
be
met.
The
HSG
On­
Line
Integrated
System
utilize
combined
on­
line
batch
QC
samples
as
specified
in
Section
B1­
1b,
Table
B1­
2,
and
Table
B1­
3.

HSG
sampling
of
waste
drums
at
the
AMWTP
is
conducted
per
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

55
B1­
1a(
4)
Manifold
Headspace
Gas
Sampling
The
HSG
sampling
protocol
employs
a
multiport
manifold
capable
of
collecting
samples
from
a
single
sample
head
or
from
in­
line
QC
sample
gas
cylinders
(
blank/
nitrogen
and
reference
standard),
and
routing
the
sample
directly
to
the
GC/
MS
unit
for
analysis
and
QC
purposes.
The
sampling
equipment
is
leak
checked
and
cleaned
prior
to
first
use
and
as
needed
thereafter.
The
manifold
is
evacuated
to
0.0039
inches
Hg
(
0.10
mm
Hg)
prior
to
sample
collection.
The
manifold
inlet
valve
is
attached
to
a
changeable
filter
connected
to
either
a
side
port
needle
sampling
head
capable
of
forming
an
airtight
seal
(
for
puncturing
the
filter
or
rigid
poly
liner
when
necessary),
or
a
drum
punch
sampling
head
capable
of
forming
an
airtight
seal
(
capable
of
punching
through
the
metal
lid
of
a
drum
for
sampling
through
the
drum
lidThis
filter/
drum
punch
sampling
head
uses
a
combination
drill/
hollow
stem
sampling
tube/
carbon
composite
filter
to
penetrate
the
drum
lid
and
liner
without
sparking.
The
filter/
drum
punch
sampling
head
design
allows
for
the
collection
of
the
headspace
gas
sample
under
the
liner
lid,
and
assembly
is
seated
to
provide
a
WIPP­
WAP
compliant
filter
for
the
drum.

The
manifold
is
equipped
with
a
purge
assembly
that
allows
applicable
QC
samples
to
be
collected
through
all
sampling
components
that
may
affect
compliance
with
the
QAOs.
AMWTP
will
demonstrate
and
document
the
effectiveness
of
the
sampling
equipment
design
in
meeting
the
QAOs.
Field
blanks
are
samples
of
room
air
collected
in
the
sampling
area
in
the
immediate
vicinity
of
the
waste
container
to
be
sampled.

The
manifold,
associated
sampling
head,
and
headspace
gas
sample
volume
are
designed
to
ensure
the
collection
of
representative
samples.
The
manifold
internal
volume
must
be
calculated
and
documented
in
a
field
logbook
dedicated
to
headspace­
gas
sampling
collection.
Internal
manifold
and
sample
line
volume
is
small
in
comparison
to
the
volume
of
the
headspace.
The
total
volume
of
headspace
gases
collected
during
each
sampling
operation
is
obtained
by
adding
the
sampled
volume
with
the
manifold
volume
and
is
documented
in
design
verification
documentation.

The
sample
side
of
the
sampling
manifold
consists
of
the
following
major
components:

 
A
sampling
head
with
leak
tight
connections
to
the
headspace
sampling
manifold.

 
GC
grade
stainless
steel
tubing
with
sufficient
flexibility
to
allow
any
necessary
movement
of
the
sampling
head
caused
by
compression
of
the
waste
container
to
the
sample
head.

 
The
headspace
sampling
manifold
pressure
sensor(
s)
is
pneumatically
connected
to
the
headspace
sampling
manifold.
The
headspace
sampling
manifold
pressure
sensor(
s)
is
capable
of
measuring
absolute
pressure
in
the
range
from
0.05
to
1,000
mm
Hg.
Its
resolution
is
±
0.01
mm
Hg
at
0.05
mm
Hg.
The
pressure
sensor(
s)
has
an
operating
range
from
approximately
15
°
C
to
50
°
C.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

56
 
The
On­
Line
Integrated
HSG
System
needs
only
one
port
for
the
collection
of
samples.
All
ports
(
inlet
and
outlet)
utilize
solenoid
actuated,
normally­
closed
valves
to
ensure
an
air­
tight
seal
when
the
system
not
in
use.
All
sampling
ports
and
piping
have
VCR
®
fittings
for
connection
to
ensure
air­
tight
connections
and
to
prevent
degradation
of
the
fittings
on
the
manifold.

 
An
oil
vacuum
pump
is
used
to
reduce
the
pressure
in
the
headspace
sampling
manifold
to
less
than
or
equal
to
0.05
mm
Hg.
Precautions
have
been
taken
to
prevent
diffusion
of
oil
vapors
back
to
the
manifold
including
the
use
of
a
non­
interfering
silicone­
based
lubricant,
continuous
pump
operation
and
piping
dimensioning
from
the
pump
to
the
manifold.
Compliance
is
demonstrated
by
several
months
of
operation
and
equipment
blank
analyses
without
indication
of
contamination
due
to
oil
diffusion.

 
The
system
was
designed
with
a
minimum
distance
between
the
sample
head
and
the
valve
that
isolates
the
pump
from
the
manifold
in
order
to
minimize
the
dead
volume
in
the
manifold.

 
The
manifold
is
equipped
with
an
PID
(
photoionization
detector)
capable
of
detecting
the
analytes
listed
in
Table
B3­
2.
The
Organic
Vapor
Analyzer
(
OVA)
measures
total
VOC
concentration
below
the
lowest
headspace
gas
PRQL
based
on
manufacturer's
specifications.
Detection
of
l,
l,
2­
trichloro­
l,
2,2­
trifluoroethane
is
not
possible
using
the
photoionization
detector
used.
The
OVA
measurement
is
confirmed
by
the
collection
and
GC/
MS
analysis
of
field
blanks
and
as
specified
in
the
method
requirements,
equipment
blanks
to
check
for
manifold
cleanliness.

The
standard
side
of
the
sampling
manifold
consists
of
the
following
major
components:

 
A
cylinder
of
compressed
zero
nitrogen
is
used
to
clean
the
manifold
between
samples
and
provide
gas
for
the
collection
of
equipment
blanks
or
on­
line
blanks.
The
high­
purity
gas
is
certified
by
the
manufacturer
to
contain
less
than
one­
ppm
total
VOCs.
The
gases
are
metered
into
the
standard
side
of
the
manifold
using
solenoid
controlled
valves
that
are
corrosion
proof
and
that
do
not
allow
for
the
introduction
of
manifold
gas
into
the
purge
gas
cylinders.
Gas
quality
is
of
ultra­
high
purity
grade
and
metered
by
a
two­
stage
stainless
steel
regulator.

 
Cylinders
of
field
reference
standard
gases
or
on­
line
control
sample
gases
are
used
for
evaluating
the
accuracy
of
the
headspace
sampling
process.
Field
reference
standard
gas
is
delivered
through
a
flow
regulating
two­
stage
stainless
steel
regulator.
The
field
reference
standard
gas
is
certified
by
the
manufacturer
to
contain
analytes
from
Table
B3­
2
of
Permit
Attachment
B3
at
known
concentrations.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

57
 
A
humidifier
filled
with
ASTM
Dl
193­
77
(
ASTM
1983b)
Type
I
or
Type
II
water
is
connected
to
the
headspace
sampling
manifold
between
the
compressed
gas
cylinder
and
the
sampling
manifold.
Dry
gases
flowing
to
the
purge
assembly
pick
up
moisture
from
the
humidifier.
Moisture
is
added
to
the
dry
gases
to
assist
with
system
cleaning
between
headspace
gas
sample
collection
and
to
condition
equipment
blanks
and
field
reference
standards.

 
A
purge
assembly
allows
the
sampling
head
(
sample
side)
to
be
connected
to
the
standard
side
of
the
manifold.

 
A
pressure
regulator
connected
to
the
purge
assembly
monitors
the
gas
flow
rate
through
the
purge
assembly.
The
pressure
through
the
purge
assembly
is
monitored
to
assure
excess
flow
during
cleaning
activities
and
during
QC
sample
collection.
Maintaining
excess
flow
prevents
ambient
air
from
contaminating
QC
samples
and
allow
samples
of
gas
from
the
compressed
gas
cylinders
to
be
collected
near
ambient
pressures.

 
An
ambient­
pressure
sensor
with
a
measurement
range
for
the
ambient
barometric
pressures
is
in
the
sampling/
manifold
location.
It
is
kept
in
the
sampling
area
during
sampling
operations.
The
ambient
pressure
sensor
has
a
full
range
of
at
least
500
to
800
mm
Hg
and
is
kept
in
the
sampling
area
during
sampling
operations.
Resolution
is
1.0
mm
Hg
or
less
and
calibration
performed
by
the
manufacturer
is
based
on
National
Institute
of
Standards
and
Technology
(
NIST),
or
equivalent,
standards.

 
A
temperature
sensor
with
a
minimum
range
of
18
°
C
to
50
°
C
is
in
the
sampling/
manifold
location.
The
temperature
sensor
calibration
is
traceable
to
NIST,
or
equivalent,
standards.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

58
B1­
1a(
5)
Direct
Canister
Headspace
Gas
Sampling
This
Section
is
not
applicable
to
the
AMWTP.

B1­
1a(
6)
Sampling
Heads
The
AMWTP
samples
through
the
filter
and
preserves
the
integrity
of
the
drum
to
contain
radionuclides
(
e.
g.,
replace
the
damaged
filter,
replace
set
screw
in
filter
housing,
seal
the
punched
drum
lid).

B1­
1a(
6)(
i)
Sampling
Through
the
Filter
To
sample
the
drum­
headspace
gas
through
the
drum's
filter,
the
AMWTP
uses,
a
side­
port
needle
(
e.
g.,
a
hollow
needle
sealed
at
the
tip
with
a
small
opening
on
its
side
close
to
the
tip)
pressed
through
the
filter
and
into
the
headspace
beneath
the
drum
lid.
This
permits
the
gas
to
be
drawn
into
the
manifold
or
directly
into
the
canister(
s).
All
of
the
general
method
requirements,
sampling
apparatus
requirements,
and
QC
requirements
described
in
this
section
are
met
in
addition
to
the
following
requirements
that
are
pertinent
to
drum
headspacegas
sampling
through
the
filter:

 
The
lid
of
the
drum's
90­
mil
poly
rigid
liner
shall
contain
a
hole
for
venting
to
the
drum
headspace.
A
representative
sample
cannot
be
collected
from
the
drum
headspace
until
the
90­
mil
poly­
liner
has
been
vented
to
the
drum.
If
the
DAC
for
Scenario
1
is
met,
a
sample
may
be
collected
from
inside
the
90­
mil
rigid
poly
liner.
If
the
sample
is
collected
by
removing
the
drum
lid,
the
sampling
device
shall
form
an
airtight
seal
with
the
rigid
poly
liner
to
prevent
the
intrusion
of
outside
air
into
the
sample
(
using
a
sampling
needle
connected
to
the
sampling
head
to
pierce
the
rigid
poly
liner
satisfies
this
requirement).
If
headspace­
gas
samples
are
collected
from
the
drum
headspace
prior
to
venting
the
90­
mil
rigid
poly
liner,
the
sample
is
not
acceptable
and
a
nonconformance
report
shall
be
prepared,
submitted,
and
resolved.
Nonconformance
procedures
are
outlined
in
Section
B3.

 

For
sample
collection,
the
drum's
filter
shall
be
sealed
to
prevent
outside
air
from
entering
the
drum
and
diluting
and/
or
contaminating
the
sample.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

59
The
sampling
head
for
collecting
drum
headspace
by
penetrating
the
filter
consists
of
a
side­
port
needle,
a
filter
to
prevent
particles
from
contaminating
the
gas
sample,
and
an
adapter
to
connect
the
side­
port
needle
to
the
filter.
To
prevent
cross
contamination,
the
sampling
head
is
cleaned
or
replaced
after
sample
collection,
after
field­
reference
standard
collection,
and
after
field­
blank
collection.
The
following
requirements
shall
also
be
met:

 

The
housing
of
the
filter
shall
allow
insertion
of
the
sampling
needle
through
the
filter
element
or
a
sampling
port
with
septum
that
bypasses
the
filter
element
into
the
drum
headspace.

 
The
side­
port
needle
shall
be
used
to
reduce
the
potential
for
plugging.

 
The
purge
assembly
shall
be
modified
for
compatibility
with
the
side­
port
needle.

B1­
1a(
6)(
ii)
Sampling
Through
the
Drum
Lid
by
Drum
Lid
Punching
A
HSG
sample
is
collected
through
the
drum
lid
at
the
time
of
drum
punching
(
i.
e.,
samples
are
not
collected
through
the
carbon
filter).
This
sampling
method
and
the
overall
system
preserves
the
integrity
of
the
drum
to
contain
radionuclides
and
maintaining
an
air
tight
seal
by
the
installation
and
seating
of
the
sampling
stem
and
carbon
composite
filter
into
the
drum
lid.

The
process
of
sampling
through
the
drum
lid
begins
by
raising
the
waste
container
up
to
the
sample
chamber
seal
and
applying
a
minimum
of
200
pounds
force
between
the
drum
and
the
seal,
which
creates
an
airtight
seal
around
the
area
to
be
penetrated.
Seal
integrity
is
tested
by
pumping
the
volume
within
the
seal
to
300
torr
or
less.
The
pressure
transducer
measures
the
seal
housing
chamber
initial
and
final
pressures
over
a
15
second
period.
An
acceptable
seal
test
has
a
leak
rate
of
less
than
50
torr
per
minute.
To
sample
the
drum
headspace
gas
through
the
drum
lid,
the
lid
is
breached
using
a
sparkless
drill/
filter
assembly.
To
assure
that
the
sample
collected
is
representative,
all
of
the
appropriate
general
method
requirement
for
TRU
waste
characterization,
sampling
apparatus
requirements,
and
QC
requirements
specified
in
EPA's
Compendium
Method
TO­
14
are
met
in
addition
to
the
following
requirements:

 
The
seal
between
the
drum
lid
and
sampling
head
minimizes
the
intrusion
of
ambient
air.

 
All
components
of
the
drum
sampling
system
that
come
into
contact
with
sample
gases
are
purged
with
humidified
nitrogen
prior
to
sample
collection.

 
On­
line
blanks
and
on­
line
field
reference
standards
are
collected
through
all
the
components
of
the
punch
that
contact
the
headspace
gas
sample.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

60
 
Once
the
drum
lid
has
been
breached
and
the
filter
seated,
drill
rotation
ceases.
This
ensures
liner
penetration.

 
Because
pressure
increases
may
occur
during
sealing
of
the
drum
punch
to
the
drum
lid,
provisions
are
made
to
relieve
potential
drum
pressure
increases
during
drum­
punch
operations.

 
The
lid
of
the
drum's
90­
mil
rigid
poly
liner
shall
contain
a
hole
for
venting
to
the
drum
headspace.
The
drill
filter
assembly
design
ensures
penetration
of
drum
poly
liners.
A
representative
sample
cannot
be
collected
from
the
drum
headspace
until
the
90­
mil
rigid
poly
liner
has
been
vented
to
the
drum.
If
the
DAC
for
Scenario
1
is
met,
a
sample
may
be
collected
from
inside
the
90­
mil
rigid
poly
liner.
If,
for
any
reason,
headspace
gas
samples
are
collected
from
the
drum
headspace
prior
to
venting
the
poly
liner,
the
sample
is
not
acceptable
and
a
nonconformance
report
is
prepared,
submitted,
and
resolved.
Nonconformance
procedures
are
outlined
in
Section
B3­
13.

 
During
sampling,
if
the
drum
contains
an
existing
carbon­
composite
filter,
it
is
sealed
to
prevent
outside
air
from
entering
the
drum
using
a
tested
sealing
cap
and
clamp
mechanism.

 
A
flow
indicating
device,
which
monitors
excess
flow
of
purge
gases
(
for
system
purge)
is
pneumatically
connected
to
the
drum
punch
assembly
and
controlled
by
means
of
the
system's
programmable
logic
control
(
PLC)
software.

 
The
drum
sampling
system
is
firmly
seated
to
the
drum
lid
using
a
pneumatic
lifting
bladder;
lifting
the
drum
and
creating
a
minimum
of
200
pounds
of
seal
force
between
the
drum
lid
and
seal.
This
is
continuously
monitored
and
adjusted
by
the
PLC
software.

 
If
the
headspace
gas
sample
is
not
taken
at
the
time
of
drum
punching,
the
presence
and
diameter
of
the
rigid
liner
vent
hole
shall
be
documented
during
the
punching
operation
for
use
in
determining
an
appropriate
Scenario
2
DAC.

B1­
1a(
6)(
iii)
Sampling
Through
a
Pipe
Overpack
Container
Filter
Vent
Hole
This
Section
is
not
applicable
to
the
AMWTP.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

61
B1­
1b
Quality
Control
For
the
On­
Line
Integrated
HSG
System,
QC
samples
are
collected
and
analyzed
on
a
per
on­
line
batch
basis.
An
on­
line
batch
is
the
number
of
headspace­
gas
samples
collected
within
a
12­
hour
period
using
the
same
online
integrated
analysis
system
as
described
in
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operations.
The
analytical
batch
requirements
are
specified
by
the
analytical
method
being
used
in
the
on­
line
system.
Table
B1­
2
provides
a
summary
of
field
QC
sample
frequency
requirements,
and
Table
B1­
3
provides
a
summary
of
QC
sample
acceptance
criteria.

For
the
On­
Line
Integrated
HSG
System,
the
on­
line
batch
QC
samples
serve
as
combined
sampling
batch/
analytical
batch
QC
samples
as
follows:

 
The
on­
line
blank
replaces
the
equipment
blank
and
laboratory
blank.

 
The
on­
line
control
sample
replaces
the
field
reference
standard
and
laboratory
control
sample.

 
The
on­
line
duplicate
replaces
the
field
duplicate
and
laboratory
duplicate.

The
acceptance
criteria
for
on­
line
batch
QC
samples
are
the
same
as
for
the
sampling
batch
and
analytical
batch
QC
samples
they
replace.
Acceptance
criteria
are
shown
in
Table
B1­
3.
A
separate
field
blank
is
collected
and
analyzed
for
each
on­
line
batch.
However,
if
the
results
of
a
field
blank
collected
through
the
sampling
manifold
meets
the
acceptance
criterion,
a
separate
on­
line
blank
need
not
be
collected
and
analyzed.

The
Site
Quality
Assurance
Officer
(
SQAO)
monitors
and
documents
field
QC
sample
results
and
fills
out
a
nonconformance
report
if
acceptance
or
frequency
criteria
are
not
met.
The
SPM
also
ensures
appropriate
corrective
action
is
taken
if
acceptance
criteria
are
not
met.

B1­
1b(
1)
Field
Blanks
Field
blanks
are
collected
to
evaluate
background
levels
of
program­
required
analytes.
Field
blanks
are
collected
prior
to
sample
collection,
and
at
a
frequency
of
one
per
sampling
batch.
The
SPM
uses
the
field
blank
data
to
assess
impacts
of
ambient
contamination,
if
any,
on
the
sample
results.
Field
blank
results
determined
by
gas
GC/
MS
or
gas
chromatography/
flame
ionization
(
GC/
FID)
detection
are
acceptable
if
the
concentration
of
each
VOC
analyte
is
less
than
or
equal
to
three
times
the
method
detection
limit
(
MDL)
listed
in
Table
B3­
2.
A
nonconformance
report
is
initiated
and
resolved
if
the
final
reported
QC
sample
results
do
not
meet
the
acceptance
criteria.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

62
B1­
1b(
2)
Equipment
Blanks
Equipment
blanks
shall
be
collected
to
assess
cleanliness
prior
to
first
use
after
cleaning
of
all
sampling
equipment.
On­
line
equipment/
manifold
blanks
are
collected
to
assess
cleanliness
prior
to
first
use
after
cleaning
of
all
sampling
equipment.
On­
line
blanks
are
used
to
assess
equipment
cleanliness
as
well
as
analytical
contamination.
After
the
initial
cleanliness
check,
equipment
blanks
collected
through
the
manifold
shall
be
collected
at
a
frequency
of
one
per
sampling
batch
for
VOC
analysis
or
one
per
day,
whichever
is
more
frequent.
The
SPM
uses
the
on­
line
equipment/
manifold
blank
data
to
assess
impacts
of
potentially
contaminated
sampling
equipment
on
the
sample
results.
Equipment
blank
results
determined
by
GC/
MS
or
GC/
FID
are
acceptable
if
the
concentration
of
each
VOC
analyte
is
less
than
or
equal
to
three
times
the
MDL
listed
in
Table
B3­
2.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

63
B1­
1b(
3)
Reference
Standards
Field
reference
standards
are
used
to
assess
the
accuracy
with
which
the
sampling
equipment
collects
VOCs
samples
into
SUMMA
®
or
equivalent
canisters
prior
to
first
use
of
the
sampling
equipment.
The
on­
line
control
sample
is
used
to
assess
the
accuracy
with
which
the
sampling
equipment
collects
VOC
samples
as
well
as
an
indicator
of
analytical
accuracy
for
the
on­
line
sampling
system.
Field
reference
standards
for
VOC
analysis
contains
a
minimum
of
six
of
the
analytes
listed
in
Table
B3­
2
at
concentrations
within
a
range
of
10
to
100
ppmv
and
greater
than
the
MDL
for
each
compound.

Field
reference
standards
have
a
known
valid
relationship
to
a
nationally
recognized
standard
(
e.
g.,
NIST).
If
NIST
traceable
standards
are
not
available
and
commercial
gases
are
used,
a
Certificate
of
Analysis
from
the
manufacturer
documenting
traceability
is
required.
Commercial
stock
gases
are
not
used
beyond
their
manufacturer­
specified
shelf
life.

After
the
initial
accuracy
check,
on­
line
control
samples
are
collected
through
the
system
at
a
frequency
of
one
per
on­
line
batch.
The
QAOs
for
accuracy
for
each
tested
compound
has
a
recovery
of
70
to
130
percent.
For
the
direct
canister
method,
field
reference
standards
collection
may
be
discontinued
if
the
field
reference
standard
results
demonstrate
the
QAO
for
accuracy
specified
in
Section
B3.
Field
reference
standard
results
are
acceptable
if
the
accuracy
for
each
tested
compound
has
a
recovery
of
70
to
130
percent.

B1­
1b(
4)
Field
Duplicates
Duplicates
are
collected
sequentially
and
in
accordance
with
Table
B1­
1.
Field
duplicates
also
serve
as
a
measure
of
analytical
precision
for
the
on­
line
sampling
system.
Field
duplicate
results
are
acceptable
if
the
relative
percent
difference
is
less
than
or
equal
to
25
for
each
tested
compound
found
in
concentrations
greater
than
the
PRQL
in
both
duplicates.

B1­
1c
Equipment
Testing,
Inspections,
and
Maintenance
All
sampling
equipment
components
that
come
into
contact
with
headspace
sample
gas
are
constructed
of
relatively
inert
materials
such
as
stainless
steel
or
Teflon
®
.
Stainless
steel
components
are
cleaned,
passivated,
or
procured
as
GC­
grade.

To
minimize
the
potential
for
cross­
contamination
of
samples,
the
headspace
gas
sampling
manifolds
and
On­
Line
Integrated
HSG
System
are
cleaned
and
leak­
checked
prior
to
each
sampling
event.
Procedures
used
for
cleaning
and
preparing
the
manifold
use
the
general
guidelines
that
are
appropriate
for
TRU
waste
characterization
established
by
the
EPA
in
the
Compendium
Method
TO­
14
and
is
discussed
in
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operation.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

64
B1­
1c(
1)
Headspace
Gas
Sample
Canister
Cleaning
This
Section
is
not
applicable
to
the
AMWTP.

B1­
lc(
2)
Sampling
Equipment
Initial
Cleaning
and
Leak­
Check
The
on­
line
system
and
sampling
heads
that
come
into
contact
with
headspace
gas
are
thoroughly
inspected
and
cleaned
prior
to
assembly.
The
on­
line
system
is
purged
with
humidified
nitrogen
and
leak
checked
after
assembly.
This
cleaning
is
repeated
if
the
on­
line
system
is
contaminated
to
the
extent
that
the
routine
system
cleaning
is
inadequate.

B1­
1c(
3)
Sampling
Equipment
Routine
Cleaning
and
Leak­
Check
The
on­
line
system
and
sampling
head
is
cleaned
and
checked
for
leaks
in
accordance
with
the
cleaning
and
leak
check
procedures
described
in
EPA's
Compendium
Method
TO­
14.
The
cleaning
procedure
is
conducted
after
headspace
gas
samples;
after
on­
line
duplicate
collection;
after
on­
line
blank
collection;
and
after
the
additional
cleaning
required
for
field
reference
standard
(
on­
line
control
sample)
collection
has
been
completed.

VOCs
are
removed
from
the
internal
surfaces
of
the
on­
line
system
to
levels
that
are
less
than
or
equal
to
three
times
the
MDLs
of
the
analytes
listed
in
Table
B3­
2,
as
determined
by
analysis
of
an
equipment
blank
or
through
use
of
an
OVA.
When
not
in
use,
the
manifold
shall
be
demonstrated
clean
before
storage
with
a
positive
pressure
of
high
purity
gas
(
i.
e.,
zero
air,
nitrogen,
or
helium)
in
both
the
standard
and
sample
sides.

Sampling
is
suspended
and
corrective
actions
are
taken
when
the
analysis
of
an
equipment
blank
indicates
that
the
VOC
limits
have
been
exceeded
or
if
a
leak
test
fails.
The
SPM
ensures
that
corrective
action
has
been
taken
prior
to
resumption
of
sampling.

B1­
1c(
4)
On­
Line
System
Cleaning
After
Field
Reference
Standard
Collection
The
sampling
system
is
specifically
cleaned
after
a
field
reference
standard
has
been
collected.
The
HSG
sampling
system
is
designed
to
automatically
flush/
clean
the
entire
system
(
evacuate
and
pressurize
with
humidified
nitrogen)
and
adequately
clean
the
system's
internal
surfaces
for
both
the
sample
and
standard
side.
After
completing
this
protocol
and
prior
to
collecting
another
sample,
the
system
cleaning
verification
using
the
OVA
and
leak
check
is
also
performed
in
accordance
with
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operations.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

65
B1­
1c(
5)
Sample
Head
Cleaning
To
prevent
cross­
contamination,
the
needle,
drill/
filter
assembly,
airtight
fitting
,
sample
chamber
and
replaceable
filter
of
the
sampling
heads
are
cleaned
in
accordance
with
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operation,
procedures
which
use
the
cleaning
procedures
described
in
EPA
in
the
Compendium
Method
TO­
14
prior
to
use
or
reuse.

The
sampling
system
is
designed
to
automatically
flush
the
entire
system
(
evacuate
and
pressurize
with
humidified
zero
nitrogen)
and
adequately
clean
the
system's
internal
surfaces.
After
completing
this
protocol
and
prior
to
collecting
another
sample,
the
system
cleaning
verification
using
the
OVA
and
leak
check
is
also
performed.

B1­
1d
Equipment
Calibration
and
Frequency
The
manifold
pressure
sensor
are
certified
prior
to
initial
use
and
then
periodically
(
annually
or
shorter
frequency)
as
described
in
MP­
CMNT­
10.1,
Maintenance
Management,
using
NIST,
or
equivalent
traceable
standards.
If
necessary,
the
pressure
indicated
by
the
pressure
is
temperature
compensated.
The
ambient
air
temperature
sensor,
if
present,
is
certified
prior
to
initial
use,
then
annually,
to
NIST
traceable,
or
equivalent,
temperature
standards.

The
OVA
is
calibrated
once
per
day,
prior
to
first
use,
or
as
necessary
according
to
the
manufacturer's
specifications
in
accordance
with
INST­
TRUW­
8.2.1,
HSG
Calibration.
If
OVA
calibration
period
is
greater
than
one
day,
verification
of
calibration
is
performed
each
day.
Calibration
gases
for
the
OVA
are
certified
to
contain
isobutylene
at
the
manufacturers
recommended
concentrations.
The
balance
of
the
OVA
calibration
gas
is
consistent
with
the
manifold
purge
gas
when
the
OVA
is
used
(
i.
e.,
zero
air,
nitrogen,
or
helium).

Analytical
equipment
is
calibrated
and
verified
as
specified
in
Table
B3­
3
for
Gas
VOCs.

B1­
2
Sampling
of
Homogeneous
Solids
and
Soil/
Gravel
This
section
describes
the
requirements
for
collecting
samples
of
TRU
waste
classified
as
homogeneous
solids
and
soils/
gravels.
Sampling
protocols
are
based
upon
methods
similar
to
those
approved
by
EPA
methods
and
American
Society
for
Testing
and
Materials
(
ASTM)
and
are
implemented
in
INST­
OI­
16,
Drum
Coring
Operations.

Sampling
protocols
are
designed
for
characterization
of
solid
process
residues
and
soils
on
a
waste
stream
basis.
They
are
also
designed
to
ensure
that
representative
samples
of
these
wastes,
including
QC
samples,
are
consistently
collected
and
transferred
to
the
responsible
laboratory
in
a
manner
that
maintains
their
full
integrity.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

66
The
chosen
strategy
is
designed
to
provide
the
analytical
laboratories
the
minimum
amount
of
required
sample,
to
minimize
sample
handling
and
the
quantity
of
investigation­
derived
waste.
The
waste
is
analyzed
for
the
target
analytes
specified
in
Tables
B3­
4,
B3­
6,
and
B3­
8.

Sampling
methods
not
identified
in
this
section
shall
not
be
used.
If
a
sampling
method
is
proposed
for
use
which
has
not
been
identified
in
this
section,
the
sampling
method,
protocol
and
detailed
sampling
plan
shall
be
submitted
to
the
SPM
for
submittal
to
the
CBFO
for
approval.
The
CBFO
will
determine
the
need
for
permit
modification
and
approval
by
NMED.
As
new
methods
are
submitted
to
CBFO
and
approved
by
NMED,
they
will
be
added
to
this
section.

B1­
2a
Methods
Requirements
The
methods
used
to
collect
samples
of
TRU
waste
classified
as
homogeneous
solids
and
soil/
gravel
from
waste
containers
is
such
that
the
samples
are
representative
of
the
waste
from
which
they
are
taken.
To
minimize
the
quantity
of
investigation­
derived
waste,
the
laboratories
conducting
the
analytical
work
will
receive
no
more
than
is
required
for
analysis,
based
on
the
analytical
methods.
Homogeneous
solids
and
soil/
gravel
samples
are
handled
in
accordance
with
the
specifications
presented
in
Table
B1­
4.

A
sufficient
number
of
samples
are
collected
to
adequately
represent
the
waste
being
sampled.
Debris
waste
(
S5000)
is
not
sampled,
and
debris
that
may
be
present
in
waste
streams
defined
as
Summary
Category
Groups
S3000
or
S4000
is
not
sampled.

Samples
of
retrievably
stored
waste
containers
will
be
collected
using
appropriate
coring
equipment
or
other
EPA
approved
methods
to
collect
a
representative
sample.
Newly
generated
wastes
that
are
sampled
from
a
process
as
it
is
generated
may
be
sampled
using
EPA
approved
methods,
including
scoops
and
ladles,
that
are
capable
of
collecting
a
representative
sample.
All
sampling
and
core
sampling
will
comply
with
the
QC
requirements
specified
in
B1­
2b.

B1­
2a(
1)
Core
Collection
Coring
tools
are
used
to
collect
cores
of
homogenous
solids
and
soil/
gravel
from
waste
containers,
when
possible,
in
a
manner
that
minimizes
disturbance
to
the
core.
A
rotational
coring
tool
(
i.
e.,
a
tool
that
is
rotated
longitudinally),
similar
to
a
drill
bit,
to
cut,
lift
the
waste
cuttings,
and
collect
a
core
from
the
bore
hole,
is
used
to
collect
sample
cores
from
waste
containers.
For
homogenous
solids
and
soil/
gravel
that
are
relatively
soft,
non­
rotational
coring
tools
may
be
used
in
lieu
of
a
rotational
coring
tool.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

67
The
following
requirements
apply
to
the
use
of
coring
tools:

 
Each
coring
tool
shall
contain
a
removable
tube
(
liner)
that
is
constructed
of
fairly
rigid
material
unlikely
to
affect
the
composition
and/
or
concentrations
of
target
analytes
in
the
sample
core.
Materials
that
are
acceptable
for
use
for
coring
device
sleeves
and
end
caps
are
polycarbonate,
teflon,
or
glass
for
most
samples,
and
stainless
steel
or
brass
if
samples
are
not
to
be
analyzed
for
metals.
The
AMWTP
uses
polycarbonate
sleeves
and
Teflon
lined
end
caps
that
are
cleaned
in
accordance
with
B1­
2b
prior
to
use.
An
equipment
blank
is
taken
prior
to
first
use
to
ensure
the
absence
of
target
analytes.
Liner
outer
diameter
is
no
more
than
2
in.
and
no
less
than
one
in.
Liner
wall
thickness
is
recommended
to
be
no
greater
than
1/
16
in.
Before
use,
the
liner
is
cleaned
in
accordance
the
requirements
in
Section
B1­
2b.
The
liner
fits
flush
with
the
inner
wall
of
the
coring
tool
and
shall
be
of
sufficient
length
to
hold
a
core
that
is
representative
of
the
waste
along
the
entire
depth
of
the
waste.
The
depth
of
the
waste
is
calculated
as
the
distance
from
the
top
of
the
sludge
to
the
bottom
of
the
drum
(
based
on
the
thickness
of
the
liner
and
the
rim
at
the
bottom
of
the
drum).

The
liner
material
is
sufficientiently
transparent
to
allow
visual
examination
of
the
core
after
sampling.
If
sub­
sampling
is
not
conducted
immediately
after
core
collection
and
liner
extrusion,
then
end
caps
constructed
of
material
unlikely
to
affect
the
composition
and/
or
concentrations
of
target
analytes
in
the
core
(
e.
g.,
Teflon
®
)
is
placed
over
the
ends
of
the
liner.
End
caps
shall
fit
tightly
to
the
ends
of
the
liner.

 
A
spring
retainer
is
used
with
each
coring
tool
when
the
physical
properties
of
the
waste
are
such
that
the
waste
may
fall
out
of
the
coring
tool's
liner
during
sampling
activities.
The
spring
retainer
is
constructed
of
relatively
inert
material
(
e.
g.,
stainless
steel
or
Teflon
®
)
and
its
inner
diameter
shall
not
be
less
than
the
inner
diameter
of
the
liner.
Before
use,
spring
retainers
are
cleaned
in
accordance
with
the
requirements
given
in
Section
B1­
2b.

 
Coring
tools
may
have
an
air­
lock
mechanism
that
opens
to
allow
air
inside
the
liners
to
escape
as
the
tool
is
pressed
into
the
waste
(
e.
g.,
ball
check
valve).
If
used,
this
air­
lock
mechanism
shall
also
close
when
the
core
is
removed
from
the
waste
container.

 
After
disassembling
the
coring
tool,
a
device
(
extruder)
to
forcefully
extrude
the
liner
from
the
coring
tool
is
used
if
the
liner
does
not
slide
freely.
All
surfaces
of
the
extruder
that
may
come
into
contact
with
the
core
have
been
cleaned
in
accordance
with
the
requirements
in
Section
B1­
2(
b)
prior
to
use.

 
Coring
tools
are
of
sufficient
length
to
hold
the
liner
and
have
been
constructed
to
allow
placement
of
the
liner
leading
edge
as
close
as
possible
to
the
coring
tools
leading
edge.

 

All
surfaces
of
the
coring
tool
that
have
the
potential
to
contact
the
sample
core
or
sample
media
are
cleaned
in
accordance
with
the
requirements
in
Section
B1­
2(
b)
prior
to
use.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

68
 
The
leading
edge
of
the
coring
tools
may
be
sharpened
and
tapered
to
a
diameter
equivalent
to,
or
slightly
smaller
than,
the
inner
diameter
of
the
liner
to
reduce
the
drag
of
the
homogenous
solids
and
soil/
gravel
against
the
internal
surfaces
of
the
liner,
thereby
enhancing
sample
recovery.

 
Rotational
coring
tools
have
a
mechanism
to
minimize
the
rotation
of
the
liner
inside
the
coring
tool
during
coring
activities,
thereby
minimizing
physical
disturbance
to
the
core.

 
Rotational
coring
is
conducted
in
a
manner
that
minimizes
transfer
of
frictional
heat
to
the
core,
thereby
minimizing
potential
loss
of
VOCs.

 
Non­
rotational
coring
tools
shall
be
designed
such
that
the
tool's
Kerf
width
is
minimized.
Kerf
width
is
defined
as
one­
half
of
the
difference
between
the
outer
diameter
of
one
tool
and
the
inner
diameter
of
the
tool's
inlet.

B1­
2a(
2)
Sample
Collection
Sampling
of
cores
are
conducted
in
accordance
with
the
following
requirements:

 
Sampling
is
conducted
as
soon
as
possible
after
core
collection.
If
a
substantial
delay
(
i.
e.,
more
than
60
minutes)
is
expected
between
core
collection
and
sampling,
the
core
shall
remain
in
the
liner
and
the
liner
shall
be
capped
at
each
end.
If
the
liner
containing
the
core
is
not
extruded
from
the
coring
tool
and
capped,
then
two
alternatives
are
permissible:
1)
the
liner
shall
be
left
in
the
coring
tool
and
the
coring
tool
shall
be
capped
at
each
end,
or
2)
the
coring
tool
shall
remain
in
the
waste
container
with
the
air­
lock
mechanism
attached.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

69
 
Samples
of
homogenous
solids
and
soil/
gravel
for
VOC
analyses
are
collected
prior
to
extruding
the
core
from
the
liner.
These
samples
may
be
collected
by
collecting
a
single
sample
from
the
representative
subsection
of
the
core,
or
three
sub­
samples
may
be
collected
from
the
vertical
core
to
form
a
single
15­
gram
composite
sample.
Smaller
sample
sizes
may
be
used
if
method
PRQL
requirements
are
met
for
all
analytes.
The
sampling
locations
shall
be
randomly
selected.
If
a
single
sample
is
used,
the
representative
subsection
is
chosen
by
randomly
selecting
a
location
along
the
portion
of
the
core
(
i.
e.
core
length).
If
the
three
sub­
sample
method
is
used,
the
sampling
locations
shall
be
randomly
selected
within
three
equal­
length
subsections
of
the
core
along
the
long
axis
of
the
liner
and
access
to
the
waste
shall
be
gained
by
making
a
perpendicular
cut
through
the
liner
and
the
core.
The
procedures
to
select,
and
record
the
selection,
of
random
sampling
locations
is
given
in
INSTOI
16,
Drum
Coring
Operations.
True
random
sampling
involves
the
proper
use
of
random
numbers
for
identifying
sampling
locations.
A
sampling
device
such
as
the
metal
coring
cylinder
described
in
EPA's
SW­
846
Manual
(
1996),
or
equivalent,
is
immediately
used
to
collect
the
sample
once
the
core
has
been
exposed
to
air.
Immediately
after
sample
collection,
the
sample
shall
be
extruded
into
40­
ml
volatile
organics
analysis
(
VOA)
vials
(
or
other
containers
specified
in
appropriate
SW­
846
methods),
the
top
rim
of
the
vial
visually
inspected
and
wiped
clean
of
any
waste
residue,
and
the
vial
cap
secured.
Sample
handling
requirements
are
outlined
in
Table
B1­
4.
Additional
guidance
for
this
type
of
sampling
can
be
found
in
SW­
846.

 

Samples
of
the
homogenous
solids
and
soil/
gravel
for
semi­
volatile
organic
compound,
polychlorinated
biphenyls,
and
metals
analyses
are
collected.
These
samples
may
be
collected
from
the
same
subsample
locations
and
in
the
same
manner
as
the
sample
collected
for
VOC
analysis,
or
they
may
be
collected
by
splitting
or
compositing
the
representative
subsection
of
the
core.
The
representative
subsection
is
chosen
by
randomly
selecting
a
location
along
the
portion
of
the
core
(
i.
e.
core
length).
The
procedures
to
select,
and
record
the
selection,
of
random
sampling
locations
is
given
in
INST­
OI­
16.
True
random
sampling
involves
the
proper
use
of
random
numbers
for
identifying
sampling
locations.
The
procedures
used
to
select
the
random
sampling
locations
will
be
subject
to
review
as
part
of
annual
audits
by
the
CBFO.
Guidance
for
splitting
and
compositing
solid
materials
can
be
found
in
SW­
846.
All
surfaces
of
the
sampling
tools
that
have
the
potential
to
come
into
contact
with
the
sample
shall
be
constructed
of
materials
unlikely
to
affect
the
composition
or
concentrations
of
target
analytes
in
the
waste
(
e.
g.,
Teflon
®
)
.
In
addition,
all
surfaces
that
have
the
potential
to
come
into
contact
with
core
sample
media
shall
either
be
disposed
or
decontaminated
according
to
the
procedures
found
in
Section
B1­
2(
b).
Sample
sizes
and
handling
requirements
are
outlined
in
Table
B1­
4.

Newly
generated
waste
samples
may
be
collected
using
methods
other
than
coring,
as
discussed
in
Section
B1­
2a.
Newly
generated
wastes
samples
will
be
collected
as
soon
as
possible
after
sampling,
but
the
spatial
and
temporal
homogeneity
of
the
waste
stream
dictate
whether
a
representative
grab
sample
or
composite
sample
shall
be
collected.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

70
B1­
2b
Quality
Control
Requirements
Quality
control
(
QC)
requirements
for
homogeneous
waste
sampling
include
collecting
co­
located
samples
from
cores
or
other
sample
types
to
determine
precision,
collection
equipment
blanks
to
verify
cleanliness
of
the
sampling
and
coring
tools
and
sampling
equipment;
and
analysis
of
reagent
blanks
to
ensure
reagents,
such
as
deionized
and
high
pressure
liquid
chromatography
(
HPLC)
water,
are
of
sufficient
quality.
Coring
and
sampling
of
homogeneous
solids
and
soil/
gravel
comply,
at
a
minimum,
with
the
quality
control
requirements
in
Sections
Bl­
2b(
l),
B1­
2b(
2),
and
B1­
2b(
3).

B1­
2b(
1)
Co­
located
Samples
In
accordance
with
the
requirement
to
collect
field
duplicates
required
by
the
Environmental
Protection
Agency
(
EPA)
methods
found
in
SW­
846,
samples
are
collected
to
determine
the
combined
precision
of
the
coring
and
sampling
procedures.
The
co­
located
core
methodology
is
a
duplicate
sample
collection
methodology
intended
to
collect
samples
from
a
second
core
placed
at
approximately
the
same
location
within
the
drum
when
samples
are
collected
by
coring.
Waste
may
not
be
amenable
to
coring
in
some
instances.
In
this
case,
a
co­
located
sample
may
be
collected
from
a
sample
(
e.
g.
scoop)
collected
from
approximately
the
same
location
in
the
waste
stream.
A
sample
from
each
co­
located
core
or
waste
sample
collected
by
other
means
is
collected
side
by
side
as
close
as
feasible
to
one
another,
handled
in
the
same
manner,
visually
inspected
through
the
transparent
liner
(
if
cored),
and
sampled
in
the
same
manner
at
the
same
randomly
selected
sample
location(
s).
If
the
visual
examination
detects
inconsistencies
such
as
color,
texture,
or
waste
type
in
the
waste
at
the
sample
location,
another
sampling
location
may
be
randomly
selected,
or
the
samples
may
be
invalidated
and
colocated
samples
or
cores
may
again
be
collected.
Co­
located
samples,
from
either
core
or
other
sample
type,
shall
be
collected
at
a
frequency
of
one
per
sampling
batch
or
once
per
week,
whichever
is
more
frequent.
A
sampling
batch
is
a
suite
of
homogenous
solids
and
soil/
gravel
samples
collected
consecutively
using
the
same
sampling
equipment
within
a
specific
time
period.
A
sampling
batch
can
be
up
to
20
samples
(
excluding
field
QC
samples),
all
of
which
shall
be
collected
within
14
days
of
the
first
sample
in
the
batch.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

71
B1­
2b(
2)
Equipment
Blanks
In
accordance
with
SW­
846
equipment
blanks
are
collected
from
fully
assembled
sampling
and
coring
tools
(
i.
e.,
at
least
those
portions
of
the
sampling
equipment
that
contact
the
sample)
prior
to
first
use
after
cleaning
at
a
frequency
of
one
per
"
equipment
cleaning
batch".
The
equipment
blank
shall
be
collected
from
the
fully
assembled
sampling
or
coring
tool
in
the
area
where
the
sampling
or
coring
tools
are
cleaned,
prior
to
covering
with
protective
wrapping
and
storage.
The
equipment
blank
is
collected
by
pouring
clean
water
(
e.
g.,
deionized
water,
HPLC
water)
down
the
inside
of
the
assembled
sampling
or
coring
tool.
The
water
is
collected
in
a
clean
sample
container
placed
at
the
leading
edge
of
the
sampling
or
coring
tool
and
analyzed
for
the
analytes
listed
in
Tables
B3­
4,
B3­
6
and
the
PRDLs,
and
B3­
8.
The
results
of
the
equipment
blank
will
be
considered
acceptable
if
the
analysis
indicates
no
analyte
at
a
concentration
greater
than
three
times
the
MDLs
listed
in
Tables
B3­
4
and
B3­
6
or
in
the
Program
Required
Detection
Limits
(
PRDLs)
in
Table
B3­
8.
If
analytes
are
detected
at
concentrations
greater
than
three
times
the
MDLs
(
or
PRDLs
for
metals),
then
the
associated
equipment
cleaning
batch
of
sampling
or
coring
tools
shall
be
cleaned
again
and
another
equipment
blank
collected.
Equipment
from
an
equipment
cleaning
batch
may
not
be
used
until
analytical
results
have
been
received
verifying
an
adequately
low
level
of
contamination
in
the
equipment
blank.

Equipment
blanks
for
coring
tools
are
collected
from
liners
that
are
cleaned
separately
from
the
coring
tools.
These
equipment
blanks
shall
be
collected
at
a
frequency
of
one
per
equipment
cleaning
batch.
The
equipment
blanks
shall
be
collected
by
randomly
selecting
a
liner
from
the
equipment
cleaning
batch,
pouring
clean
water
(
e.
g.,
deionized
water
or
HPLC
water)
across
its
internal
surface,
collecting
the
water
in
a
clean
sample
container,
and
analyzing
the
water
for
the
analytes
listed
in
Tables
B3­
4,
B3­
6,
and
the
analytes
in
Table
B3­
8
of
Permit
Attachment
B3.
The
results
of
the
equipment
blank
analysis
will
be
considered
acceptable
if
the
results
indicate
no
analyte
at
a
concentration
greater
than
three
times
the
MDLs
listed
in
Tables
B3­
4,
B3­
6,
or
the
PRDLs
in
Table
B3­
8
of
Permit
Attachment
B3.
If
analytes
are
detected
at
concentrations
greater
than
three
times
the
MDLs
(
or
PRDLs
for
metals),
then
the
associated
equipment
cleaning
batch
of
liners
shall
be
cleaned
again
and
another
equipment
blank
collected.
Equipment
from
an
equipment
cleaning
batch
may
not
be
used
until
analytical
results
have
been
received
verifying
an
adequately
low
level
of
contamination
in
the
equipment
blank.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

72
Sampling
equipment
(
e.
g.,
bowls,
spoons,
chisel,
VOC
sub­
sampler)
are
also
to
be
cleaned.
Equipment
blanks
are
collected
for
the
sampling
equipment
at
a
frequency
of
one
per
equipment
cleaning
batch.
After
the
sampling
equipment
has
been
cleaned,
one
item
from
the
equipment
cleaning
batch
is
randomly
selected,
water
(
e.
g.,
deionized
water,
HPLC
water)
is
passed
over
its
surface,
collected
in
a
clean
container,
and
analyzed
for
the
analytes
listed
in
Tables
B3­
4,
B3­
6,
and
B3­
8.
The
results
of
the
equipment
blank
will
be
considered
acceptable
if
the
results
indicate
no
analyte
present
at
a
concentration
greater
than
three
times
the
MDLs
listed
in
Tables
B3­
4
and
B3­
6
and
in
the
PRDLs
in
B3­
8.
If
analytes
are
detected
at
concentrations
greater
than
three
times
the
MDLs
(
or
PRDLs
for
metals),
then
the
associated
equipment
cleaning
batch
of
sampling
equipment
shall
be
cleaned
again
and
another
equipment
blank
collected.
Equipment
from
an
equipment
cleaning
batch
may
not
be
used
until
analytical
results
have
been
received
verifying
an
adequately
low
level
of
contamination
in
the
equipment
blank.
The
above
equipment
blanks
may
be
performed
on
a
purchased
batch
basis
for
sampling
equipment
purchased
sterile
and
sealed
in
protective
packaging.
Equipment
blanks
need
not
be
performed
for
equipment
purchased
in
sealed
protective
packaging
accompanied
by
a
certificate
certifying
cleanliness.

The
results
of
equipment
blanks
are
traceable
to
the
items
in
the
equipment
cleaning
batch
that
the
equipment
blank
represents.
All
sampling
items
should
be
identified,
and
the
associated
equipment
cleaning
batch
should
be
documented.
The
method
of
documenting
the
connection
between
equipment
and
equipment
cleaning
batches
shall
be
documented.
Equipment
blank
results
for
the
coring
tools,
liners,
and
sampling
equipment
shall
be
reviewed
prior
to
use.
A
sufficient
quantity
of
these
items
should
be
maintained
in
storage
to
prevent
disruption
of
sampling
operations.
The
AMWTP
may
use
certified
clean
disposable
sampling
equipment
and
discard
liners
and
sampling
tools
after
one
use.
As
a
result,
cleaning
and
equipment
blank
collection
is
not
required.

B1­
2b(
3)
Coring
Tool
and
Sampling
Equipment
Cleaning
Coring
tools
and
sampling
equipment
must
be
cleaned
in
accordance
with
the
following
requirements:

 
All
surfaces
of
sampling
equipment
or
tools
that
will
come
into
contact
with
the
samples
are
cleaned
prior
to
use.
All
items
of
sampling
equipment
and
tools
are
cleaned
in
the
same
manner.
Immediately
following
cleaning,
equipment
and
tools
are
assembled
and
sealed
inside
clean
protective
wrapping
(
plastic
bags).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

73
 
Each
reusable
sampling
or
coring
tool(
e.
g.,
drill
heads,
ball
mills,
sample
splitters,
etc)
have
a
unique
identification
number.
Each
number
is
referenced
to
the
waste
container
on
which
it
was
used.
This
information
is
recorded
in
the
field
records.
One
sampling
or
coring
tool
from
each
cleaning
batch
is
tested
for
cleanliness
in
accordance
with
the
requirements
specified
above.
The
identification
number
of
the
sampling
or
coring
tool
from
which
the
equipment
blank
was
collected
is
recorded
in
the
field
records.
The
results
of
the
equipment
blank
analysis
for
the
equipment
cleaning
batch
in
which
each
sampling
or
coring
tool
was
cleaned
are
submitted
to
the
sampling
site
with
the
identification
numbers
of
all
sampling
or
coring
tools
in
the
equipment
cleaning
batch.
If
analytes
are
detected
at
concentrations
greater
than
three
times
the
MDLs
(
or
PRDLs
for
metals),
then
the
associated
equipment
cleaning
batch
of
sampling
equipment
shall
be
cleaned
again
and
another
equipment
blank
collected.
Equipment
from
an
equipment
cleaning
batch
may
not
be
used
until
analytical
results
have
been
received
verifying
an
adequately
low
level
of
contamination
in
the
equipment
blank.

 
Sample
containers
should
be
purchased
pre­
cleaned
per
EPA
cleaning
protocols.
If
sampling
containers
are
not
purchased
pre­
cleaned,
they
are
cleaned
in
accordance
with
SW­
846
criteria.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

74
B1­
2c
Equipment
Testing,
Inspection,
and
Maintenance
Prior
to
initiation
of
sampling
or
coring
activities,
sampling
and
coring
tools
are
tested
in
accordance
with
manufacturer
specifications
to
ensure
operation
within
manufacturer's
tolerance
limits.
Other
specifications
specific
to
the
sampling
operations
(
e.
g.,
operation
of
containment
structure
and
safety
systems)
are
also
tested
and
verified
as
operating
properly
prior
to
initiating
sampling
activities.
Coring
tools
shall
be
assembled,
including
liners,
and
tested.
Air
lock
mechanism,
if
present,
and
rotation
mechanism
shall
be
inspected
for
free
movement
of
critical
parts.
Sampling
and
coring
tools
found
to
be
malfunctioning
are
repaired
or
replaced
prior
to
use.

Coring
tools
and
sample
collection
equipment
shall
be
maintained
in
accordance
with
manufacturer's
specifications.
Clean
sampling
and
coring
tools
and
sampling
equipment
shall
be
sealed
inside
clean
protective
wrapping
and
maintained
in
a
clean
storage
area
prior
to
use.
Sampling
equipment
shall
be
properly
maintained
to
avoid
contamination.
A
sufficient
supply
of
spare
parts
should
be
maintained
to
prevent
delays
in
sampling
activities
due
to
equipment
down
time.
Records
of
equipment
maintenance
and
repair
are
maintained
in
the
field
records
in
accordance
with
INSTCMNT
10.1.2,
Maintenance
Management
System.

Inspection
of
sampling
equipment
and
work
areas
shall
include
the
following:

 
Sample
collection
equipment
in
the
immediate
area
of
sample
collection
are
inspected
daily
for
cleanliness.
Visible
contamination
on
any
equipment
(
e.
g.,
waste
on
floor
of
sampling
area,
hydraulic
fluid
from
hoses)
that
has
the
potential
to
contaminate
a
waste
sample
is
thoroughly
cleaned
upon
its
discovery.
Inspection
records
are
maintained
in
the
field
databank
or
appropriate
data
sheet.

 
The
waste
coring
and
sampling
work
areas
are
maintained
in
a
clean
condition
to
minimize
cross
contamination
between
waste
(
including
cores)
and
samples.

 
Expendable
equipment
(
e.
g.,
plastic
sheeting,
plastic
gloves,
pans)
are
visually
inspected
for
cleanliness
prior
to
use
and
properly
discarded
after
use.

 
Prior
to
removal
of
the
protective
wrapping
from
a
coring
tool
designated
for
use,
the
condition
of
the
protective
wrapping
is
visually
assessed.
Coring
tools
with
torn
protective
wrapping
are
returned
for
cleaning.
Coring
tools
visibly
contaminated
after
the
protective
wrapping
has
been
removed
shall
not
be
used
and
shall
be
returned
for
cleaning
or
properly
discarded.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

75
 
Sampling
equipment
are
visually
inspected
prior
to
use.
All
sampling
equipment
that
comes
into
contact
with
waste
samples
must
be
stored
in
a
protective
wrapping
until
use.
Prior
to
removal
of
the
protective
wrappings
from
sampling
equipment,
the
condition
of
the
protective
wrappings
is
visually
assessed.
Sampling
equipment
with
torn
protective
wrapping
should
be
discarded
or
returned
for
cleaning.
Sampling
equipment
visibly
contaminated
after
the
protective
wrapping
has
been
removed
shall
not
be
used
and
shall
be
returned
for
cleaning
or
properly
discarded.

 
Cleaned
sampling
and
coring
equipment
will
be
physically
segregated
from
all
equipment
that
has
been
used
for
a
sampling
event
and
has
not
been
decontaminated.

B1­
2d
Equipment
Calibration
and
Frequency
The
scales
used
for
weighing
samples
are
calibrated
as
necessary
to
maintain
scale
operation
within
manufacture's
specifications,
and
after
repairs
and
routine
maintenance.
Weights
used
for
calibration
are
traceable
to
nationally
recognized
standards.
Calibration
records
are
maintained
in
the
field
records.

B1­
3
Radiography
Radiography
is
a
nondestructive
technique
that
involves
X­
ray
scanning
of
waste
containers
to
identify
and
verify
waste
container
contents.
Radiography
requirements
are
prescribed
in
INST­
OI­
12,
Real
Time
Radiography
Operations.
The
objectives
of
the
radiography
are
as
follows:

 
Verify
Waste
Matrix
Code;

 
Estimate
waste
material
parameter
weights;

 
Verify
the
waste
stream
description;
and
 
Verify
prohibited
items
(
refer
to
section
B­
1c).

B1­
3a
Methods
Requirements
Radiography
at
the
AMWTP
aids
in
the
examination
and
identification
of
containerized
waste.
All
activities
required
to
achieve
radiography
objectives
are
described
in
the
AMWTP
QAPjP
and
Operating
Instructions
(
OIs).
These
documents
include
instructions
specific
to
the
radiography
system(
s)
used
at
the
AMWTP.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

76
A
radiography
system
(
e.
g.,
real
time
radiography
digital,
digital
radiography/
computed
tomography)
normally
consists
of
an
X­
ray
producing
device,
an
imaging
system,
an
enclosure
for
radiation
protection,
a
waste
container
handling
system,
an
audio/
video
recording
system,
and
an
operator
control
and
data
acquistion
station.
The
radiography
system
at
the
AMWTP
has
controls
which
allow
the
operator
to
vary
the
voltage,
thereby
controlling
image
quality.
It
is
possible
to
vary
the
voltage
between
150
and
400
kilovolts
to
provide
an
optimum
degree
of
penetration
through
the
waste.

To
perform
radiography,
the
waste
container
is
scanned
while
the
operator
views
the
video
monitor.
An
audio/
video
tape
or
equivalently
non­
alterable
media
is
made
of
the
waste
container
scan
and
is
maintained
as
a
non­
permanent
record.
A
radiography
data
form
is
also
used
to
document
the
Waste
Matrix
Code
and
estimated
waste
material
parameter
weights
of
the
waste.
The
estimated
waste
material
parameter
and
weights
are
determined
by
compiling
an
inventory
of
waste
items,
residual
materials,
and
packaging
materials.
The
items
on
this
look­
up
table
provide
an
estimate
of
waste
material
parameter
weights.
Containers
whose
contents
prevent
full
examination
of
the
remaining
contents,
shall
be
subject
to
visual
examination
unless
the
AMWTP
certifies
that
visual
examination
would
provide
no
additional
relevant
information
for
that
container.

Radiography
is
conducted
in
accordance
with
INST­
OI­
12,
Real
Time
Radiography
Operations.

Waste
containers
whose
packaging
configuration
or
contents
prevent
full
radiography
examination
of
the
remaining
contents
(
e.
g.,
lead­
lined
drums)
must
be
subjected
to
VE
in
lieu
of
radiography.
If
radiography
indicates
that
the
waste
does
not
match
the
waste
stream
description
a
nonconformance
report
(
NCR)
is
initiated
in
accordance
with
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions.
If
a
prohibited
nonconforming
item
is
discovered
in
a
waste
container,
the
container
is
rejected
and
disposition
for
special
case
handling
in
the
Waste
Tracking
System.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

77
B1­
3b
Quality
Control
The
radiography
system
involves
qualitative
and
semiquantitive
evaluations
of
visual
displays.
Operator
training
and
experience
are
the
most
important
considerations
for
assuring
quality
controls
in
regard
to
the
operation
of
the
radiography
system
and
for
interpretation
and
disposition
of
radiography
results.
Only
trained
and
qualified
radiography
operators
are
allowed
to
operate
radiography
equipment.

Standardized
training
and
qualification
requirements
for
radiography
operators
are
based
upon
existing
industry
standard
training
requirements
and
comply
with
the
training
and
qualification
requirements
of
the
WIPP­
WAP
as
detailed
in
the
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.

The
AMWTP
has
developed
a
training
program
that
provides
radiography
operators
with
both
formal
and
on­
the­
job
(
OJT)
training.
Radiography
operators
shall
be
instructed
in
the
specific
waste
generating
practices,
typical
packaging
configurations,
and
associated
waste
material
parameters
expected
to
be
found
in
each
Waste
Matrix
Code
at
the
site.
The
OJT
and
apprenticeship
shall
be
conducted
by
an
experienced,
qualified
radiography
operator
prior
to
qualification
of
the
training
candidate.
Radiography
operators
are
trained
on
the
types
of
waste
that
are
generated,
stored,
and
characterized
at
the
AMWTP.
All
of
the
radiography
QC
requirements
specified
in
the
WIPP­
WAP
are
incorporated
into
the
AMWTP
training
program
and
radiography
operations
to
ensure
data
quality
and
comparability.

The
training
program
contains
the
following
elements.
The
elements
of
the
radiography
training
program
include
formal
and
OJT,
as
presented
below.
These
elements
are
addressed
in
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

78
B1­
3b(
1)
Formal
Training
 
Project
Requirements
 
State
and
Federal
Regulations
 
Basic
Principles
of
Radiography
 
Radiographic
Image
Quality
 
Radiographic
Scanning
Techniques
 
Application
Techniques
 
Radiography
of
Waste
Forms
 
Standards,
Codes,
and
Procedures
for
Radiography
 
Site­
Specific
Instruction
B1­
3b(
2)
On­
the­
Job
Training
 
System
Operation
 
Identification
of
Packaging
Configurations
 
Identification
of
Waste
Material
Parameters
 
Weight
and
Volume
Estimation
 
Identification
of
Prohibited
Items
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

79
Radiography
test
drums
contain
items
common
to
the
waste
streams
to
be
generated
and
stored
at
the
AMWTP.
Test
drum(
s)
representative
of
the
Waste
Matrix
Codes
for
the
WSPFs
are
examined
and
successfully
identified
as
part
of
the
radiography
operator
qualification
process.
The
test
drums
are
divided
into
layers
with
varying
packing
densities
that
are
representative
of
the
waste
streams.
Test
drums
are
representative
of
the
waste
matrix
codes
for
which
Waste
Stream
Profile
Form
approval
is
sought,
are
examined
and
successfully
identified
prior
to
waste
stream
shipment.
The
following
is
a
list
of
required
elements
of
a
radiography
test
drum:

 
A
punctured
aerosol
can
 
Pigtails
on
poly
liners
(
horsetail
bag)

 
Pair
of
coveralls
 
Empty
bottle
 
Irregular
shaped
pieces
of
wood
 
Empty
one­
gallon
paint
can
 
Full
container
 
Aerosol
can
with
fluid
 
One­
gallon
bottle
with
three
tablespoons
of
fluid
 
One­
gallon
bottle
with
one
cup
of
fluid
(
upside
down)

 
Leaded
glove
or
leaded
apron
 
Wrench
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

80
These
items
shall
be
successfully
identified
by
the
operator
as
part
of
the
qualification
process.
Qualifications
of
radiography
operators
shall,
at
a
minimum,
encompass
the
following
requirements:

 
Successfully
pass
a
comprehensive
exam
based
upon
training
enabling
objectives.
The
comprehensive
exam
will
address
all
of
the
radiography
operations,
documentation,
characterization
and
procedural
elements
stipulated
in
this
QAPjP.

 
Perform
a
practical
capability
demonstration
in
the
presence
of
appointed
site
radiography
subject
matter
expert.
The
person
will
be
an
experienced
radiography
operator
who
is
also
qualified
as
an
OJT
trainer.

Requalifications
of
operators
are
based
on
evidence
of
continued
satisfactory
performance
(
primarily
audio/
video
tape
reviews)
and
shall
be
done
at
least
every
two
years
.
Unsatisfactory
performance
will
result
in
disqualification.
Unsatisfactory
performance
is
defined
as
the
misidentification
of
a
prohibited
item
in
a
training
drum
or
a
score
of
less
than
80%
on
the
comprehensive
exam.
Retraining
and
demonstration
of
satisfactory
performance
are
required
before
a
disqualified
operator
is
again
allowed
to
operate
the
radiography
system.

A
training
drum
with
internal
containers
of
various
sizes
is
scanned
biannually
by
each
operator.
The
audio/
video
tape
or
equivalent
media
is
then
reviewed
by
a
supervisor
to
ensure
that
operator's
interpretations
remain
consistent
and
accurate.
Imaging
system
characteristic
are
verified
on
a
routine
basis.

Independent
replicate
scans
and
replicate
observations
of
the
video
output
of
the
radiography
process
is
performed
under
uniform
conditions
and
procedures.
Independent
replicate
scans
are
performed
on
one
waste
container
per
day
or
once
per
testing
batch,
whichever
is
less
frequent.
Independent
observation
of
one
scan
(
not
the
replicate
scan)
are
also
made
once
per
day
or
once
per
testing
batch,
whichever
is
less
frequent,
by
a
qualified
radiography
operator
other
than
the
individual
who
performed
the
first
examination.
A
testing
batch
is
a
suite
of
waste
containers
undergoing
radiography
using
the
same
testing
equipment.
A
testing
batch
can
be
up
to
20
waste
containers
without
regard
to
waste
matrix.

Oversight
functions
include
periodic
audio/
videotape
reviews
of
accepted
waste
containers
by
a
qualified
radiography
operator
other
than
the
operator
who
dispositioned
the
waste
container
.
The
results
of
this
independent
verification
are
available
to
the
radiography
operator.
The
AMWTP
SQAO
is
responsible
for
monitoring
the
quality
of
the
radiography
data
and
calling
for
corrective
action,
when
necessary.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

81
B1­
3b(
3)
Visual
Examination
As
an
additional
QC
check
or
in
lieu
of
radiography,
the
waste
container
contents
are
verified
directly
by
performing
VE
on
the
waste
container
contents
using
MP­
TRUW­
8.19,
RTR/
VE
Drum
Selection).
VE
is
performed
on
a
statistically
determined
portion
of
waste
containers
to
verify
the
results
of
radiography.
With
the
exception
of
items
or
conditions
that
could
pose
a
hazard
to
VE
personnel,
the
radiography
results
are
not
made
available
until
after
the
VE
is
completed.
This
verification
includes
the
Waste
Matrix
Code
and
waste
material
parameter
weights.
This
verification
is
performed
through
a
comparison
of
radiography
and
VE
examination
results.
The
Waste
Matrix
Code
is
determined
and
waste
material
parameter
weights
are
estimated
to
confirm
that
the
container
is
properly
included
in
the
appropriate
waste
stream.
The
VE
results
are
validated
per
Section
B3­
10
and
the
results
transmitted
to
the
RTR
facility.

Visual
examination
is
conducted
to
describe
all
contents
of
a
waste
container
and
includes
estimated
or
measured
weights
of
the
contents.
The
description
clearly
identifies
all
discernible
waste
items,
residual
materials,
packaging
materials,
or
(
waste
material
parameter).
Visual
examination
experts
that
are
experienced
and
trained,
assess
the
need
to
open
individual
bags
or
packages
of
waste.
If
individual
bags/
packages
are
not
opened
estimated
weights
are
recorded.

Estimated
weights
are
established
through
the
use
of
historically
derived
waste
weight
tables
and
an
estimation
of
the
waste
volumes.
It
may
not
be
possible
to
see
through
inner
bags
because
of
discoloration,
dust,
or
because
inner
containers
are
sealed.
In
these
instances,
documented
AK
is
used
to
identify
the
Waste
Matrix
Code
and
estimated
waste
material
parameter
weights.
If
AK
is
insufficient
for
individual
bags/
packages,
actual
weights
of
waste
items,
residual
materials,
packaging
materials,
or
waste
material
parameters
are
recorded.
VE
activities
are
documented
on
VE
data
forms
and/
or
the
WTS.
In
addition,
VE
for
confirmation
of
radiography
results
is
documented
on
audio/
videotape
recording
and
on
VE
data
forms
as
specified
in
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
or
INST­
OI­
16,
Drum
Coring
Operations.

Visual
examination
consists
of
a
semi­
quantitative
and
qualitative
evaluation
of
the
waste
container
contents
and
is
recorded
on
audio/
video
tape.
Standardized
training
for
VE
has
been
developed
to
include
both
formal
classroom
training
and
OJT.
Personnel
performing
VE
are
instructed
in
the
specific
waste
generating
processes,
typical
packaging
configurations,
and
the
waste
material
parameters
expected
to
be
found
in
each
Waste
Matrix
Code
at
the
AMWTP.
The
OJT
and
apprenticeship
is
conducted
by
an
operator
experienced
and
qualified
in
VE
prior
to
qualification
of
the
candidate.
Visual
examination
personnel
are
requalified
once
every
two
years.
Refer
to
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification,
for
specific
requirements
for
qualification
and
requalification
of
VE
operators.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

82
The
elements
of
the
VE
training
program
are
presented
below:

B1­
3b(
4)
Formal
Training
 
Project
Requirements
 
State
and
Federal
Regulations
 
Application
Techniques
 
Site­
Specific
Instruction
B1­
3b(
5)
On­
the­
Job
Training
 
Identification
of
Packaging
Configurations
 
Identification
of
Waste
Material
Parameters
 
Weight
and
Volume
Estimation
 
Identification
of
Prohibited
Items
The
AMWTP
designates
visual
examination
experts
(
VEE).
The
VEE
is
selected
based
on
experience
and
training
in
the
types
of
waste
being
characterized.
The
VEE
will
be
familiar
with
the
waste
generating
processes
that
have
taken
place
at
the
AMWTP
and
will
also
be
familiar
with
all
types
of
waste
being
characterized
at
the
AMWTP.
The
VEE
is
responsible
for
the
overall
direction
and
implementation
of
the
visual
examination
at
the
AMWTP.
The
VEE
will
receive
training
in
the
same
elements
as
the
visual
examination
personnel
with
both
formal
training
and
on­
the­
job
training.
Qualification
of
a
VEE
is
based
on
familiarity
with
waste
generating
processes,
familiarity
with
the
types
of
waste
being
characterized,
and
meeting
the
training
requirements
discussed
above.
The
SPM
evaluates
personnel,
using
the
above
criteria,
and
designates
VEEs
accordingly.
Consistent
with
other
VE
personnel,
the
VEE
will
be
requalified
once
every
two
years.
VEEs
selected
will
meet
the
qualification
and
training
requirements
specified
in
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.

If
the
waste
is
homogeneous,
the
VEE
may
decide
that
a
limited
VE
involving
a
confirmation
of
the
radiography
data
is
appropriate.
If
the
waste
is
heterogeneous
the
VEE
may
decide
a
full
VE
by
opening
bags
and
segregating
waste
is
warranted.
Various
degrees
of
segregation
are
possible
based
on
the
VEE's
judgment
and
availability
of
AK
data.
The
decision
making
criteria
for
this
decision
is
for
the
VEE
to
assess
the
subject
waste
using
AK
information,
training,
and
past
experience
with
the
subjet
waste
stream
to
determine
the
extent
of
examination
necessary.
The
VEE's
decisions
are
documented
on
the
VE
data
form.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

83
A
description
of
the
waste
container
contents
is
recorded
on
a
VE
data
form
and/
or
the
WTS.
The
description
clearly
identifies
all
waste
material
parameters
and
provides
enough
information
to
estimate
weights
of
waste
material
parameters.
In
cases
where
bags
are
not
opened,
a
brief
written
description
of
the
contents
of
the
bags
and
an
estimate
of
the
amount
of
each
waste
type
in
the
bags
must
be
provided.
The
basis
of
all
decision
made
by
the
VEE
will
be
documented.
The
written
records
of
VE
are
supplemented
with
the
audio/
videotape
recording.
All
work
will
be
conducted
in
accordance
with
INST­
OI­
34,
VE
Operating
Procedure
&
Data
Reporting
or
INST­
OI­
16,
Drum
Coring
Operations.

B1­
4
Custody
of
Samples
Chain­
of­
Custody
on
field
samples
(
including
field
QC
samples)
is
initiated
immediately
after
sample
collection
or
preparation
(
refer
to
INST­
OI­
16,
Drum
Coring
Operations).
Sample
custody
is
maintained
by
ensuring
that
samples
are
custody
sealed
during
shipment
to
the
laboratory.
After
samples
are
accepted
by
the
analytical
laboratory,
custody
is
maintained
in
accordance
with
MCP­
2002,
Analytical
Sample
Management
by
assuring
samples
are
as
follows:

 
in
the
possession
of
an
authorized
individual;
or
 
in
that
individual's
view;
or
 
in
sealed
or
locked
container
controlled
by
that
individual;
or
 
in
a
secure
controlled
access
location.

Sample
custody
is
maintained
until
the
sample
is
released
by
the
SPM
or
until
the
sample
is
expended.
The
AMWTP
Chain
of
Custody
includes
provisions
for
each
of
the
following:

 
Signature
of
individual
initiating
custody
control,
along
with
data
and
time.

 
Documentation
of
sample
numbers
for
each
sample
under
custody.
Sample
numbers
will
be
referenced
to
a
specific
sampling
event
description
that
will
identify
the
sampler(
s)
through
signature,
the
date
and
time
of
sample
collection,
type/
number
containers
for
each
sample,
sample
matrix,
preservatives
(
if
applicable),
requested
methods
of
analysis,
place/
address
of
sample
collection
and
the
waste
container
number.

 
For
off­
site
shipping,
method
of
shipping
transfer,
responsible
shipping
organization
or
corporation,
and
associated
air
bill
or
lading
number.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

84
 
Signatures
of
custodians
relinquishing
and
receiving
custody,
along
with
date
and
time
of
the
transfer.

 
Description
of
final
sample
container
disposition,
along
with
signature
of
individual
removing
sample
container
from
custody.

 
Comment
section.

 
Documentation
of
discrepancies,
breakage
or
tampering.

All
samples
and
sampling
equipment
are
identified
with
unique
identification
numbers.
Sampling
Coring
tools
and
equipment
are
identified
with
unique
equipment
numbers
to
ensure
that
all
sampling
equipment,
coring
tools,
and
sampling
canisters
are
traceable
to
equipment
cleaning
batches.

All
samples
are
uniquely
identified
to
ensure
the
integrity
of
the
sample
and
can
be
used
to
identify
the
AMWTP
and
date
of
collection.
Sample
tags
and
labels
identify
at
a
minimum
the
following:

 
Sample
ID
number
 
Sampler
initials
and
organization
 
Ambient
temperature
and
pressure
(
for
gas
samples
only)

 
Sample
description
 
Requested
analyses
 
Date
and
time
of
collection
 
QC
designation
(
if
applicable)

B1­
5
Sample
Packing
and
Shipping
Samples
are
packaged
at
the
AMWTP
and
shipped
to
the
ALD.
In
the
event
that
analytical
facilities
are
not
at
the
site,
the
samples
will
be
packaged
and
shipped
to
an
off­
site
laboratory.
Sample
containers
are
packed
to
prevent
damage
to
the
sampling
container
and
to
maintain
the
preservation
temperature,
if
necessary.
Department
of
Transportation
(
DOT)
regulations
are
adhered
to
for
shipment
of
the
package.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

85
When
preparing
SUMMA
®
or
equivalent
canisters
for
shipment,
special
care
is
taken
with
the
pressure
gauge
and
the
associated
connections.
Metal
boxes
which
have
separate
compartments
or
cardboard
boxes
with
foam
inserts
are
standard
shipping
containers.
The
chosen
shipping
container
shall
meet
selected
DOT
regulations.
Cold
packs
are
added
to
the
approved
shipping
container
when
it
is
necessary
to
maintain
the
preservation
temperatures
in
the
package.

A
uniform
Hazardous
Waste
Manifest
is
not
required,
since
samples
are
exempted
from
the
definition
of
hazardous
waste
under
RCRA.

Glass
jars
are
wrapped
in
bubble
wrap
or
similarly
protected.
The
wrapped
jars
are
placed
in
plastic
bags
inside
of
the
shipping
container
so
that
the
inside
of
the
shipping
container
and
the
other
samples
in
the
shipping
container
are
not
contaminated
in
the
event
that
one
of
the
jars
breaks.
The
plastic
bag
enables
the
receiving
laboratory
to
prevent
contamination
of
their
shipping
and
receiving
area.
Plastic
jars
do
not
present
a
shipping
problem.

Shipping
containers
contain
appropriate
blank
samples
to
detect
VOC
cross­
contamination.
A
DOT
approved
cooler,
or
similar
package,
is
used
as
a
shipping
container.
When
sample
preservation
temperatures
must
be
maintained,
an
adequate
number
of
cold
packs
are
placed
in
the
shipping
container.
If
fill
material
is
needed,
the
compatibility
between
the
sample
containers
and
the
fill
material
is
evaluated
prior
to
use.

Sample
containers
are
affixed
with
signed
tamper
proof
seals
or
devices
so
that
is
apparent
if
the
sample
integrity
has
been
compromised
and
to
ensure
that
the
seal
or
device
is
traceable
to
the
individual
who
affixed
the
seal.
A
seal
is
also
placed
outside
the
shipping
container
for
the
same
reason.
Sample
custody
documentation,
with
the
signature
of
the
current
custodian
showing
sample
custody
release,
is
placed
inside
the
shipping
container.
A
seal
is
then
placed
on
the
outside
of
the
shipping
container,
or
the
shipping
container
is
locked,
so
that
the
integrity
of
the
custody
of
the
sample
inside
the
shipping
container
is
evident.
Transfer
of
sample
custody
is
complete
when
the
receiving
custodian
opens
shipping
container
and
signs
the
sample
custody
documentation.
The
sample
custody
documentation
serves
to
track
the
physical
transfer
of
samples
between
the
two
custodians.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

86
Table
B1­
1,
Gas
Sample
Requirements
PARAMETER
HEADSPACE
SAMPLE
MINIMUM
VOLUME
(
ML)
HOLDING
TEMPERATURE
VOCs
250a,
b
0­
40
o
C
a
Alternatively,
if
available
headspace
is
limited,
100
mL
samples
may
be
collected
for
determination
of
volatiles.
b
Alternatively,
canisters,
that
meet
QAOs
may
be
used.

Table
B1­
2,
Headspace
Gas:
Summary
of
Field
Quality
Control
Sample
Frequencies
QC
SAMPLES
MANIFOLD
DIRECT
CANISTER
ON­
LINE
SYSTEMS
Field
Blanksa
1
per
sampling
batchd
1
per
sampling
batchd
1
per
on­
line
batchf
Sampling
Equipment
Blanksb
Or
On­
Line
Equipment
Blanksb
1
per
sampling
batchd
Oncee
1
per
on­
line
batchf
Field
Reference
Standards
Or
On­
Line
Control
Samplesc
1
per
sampling
batchd
Oncee
1
per
on­
line
batchf
Field
Duplicates
Or
On­
Line
Duplicates
1
per
sampling
batchd
1
per
sampling
batchd
1
per
on­
line
batchf
a
Analysis
of
field
blanks
for
VOCs
(
Table
B3­
2),
only,
is
required.
For
on­
line
integrated
sampling/
analytical
systems,
if
field
blank
results
meet
the
acceptance
criteria,
a
separate
on­
line
blank
is
not
required.
b
One
equipment
blank
or
on­
line
equipment
blank
must
be
collected,
analyzed
for
VOCs
(
Table
B3­
2),
and
demonstrated
as
clean
prior
to
first
use
of
the
headspace
sampling
equipment
with
each
of
the
sampling
heads,
then
at
the
specified
frequency,
for
VOCs,
only
thereafter.
Daily,
prior
to
work,
the
sampling
manifold,
if
in
use,
must
be
verified
as
clean.
c
One
field
reference
standard
or
on­
line
control
sample
must
be
collected,
analyzed,
and
demonstrated
to
meet
the
QAOs
specified
in
Table
B3­
2
prior
to
first
use,
then
at
the
specified
frequency
thereafter.
d
A
sampling
batch
is
a
suite
of
samples
collected
consecutively
using
the
same
sampling
equipment
within
a
specific
time
period.
A
sampling
batch
can
be
up
to
20
samples
(
excluding
field
QC
samples),
all
of
which
must
be
collected
within
14
days
of
the
first
sample
in
the
batch.
e
One
equipment
blank
and
field
reference
standard
must
be
collected
after
equipment
purchase,
cleaning,
and
assembly.
f
An
on­
line
batch
is
the
number
of
samples
collected
within
a
12­
hour
period
using
the
same
on­
line
integrated
sampling/
analysis
system.
The
analytical
batch
requirements
are
specified
by
the
analytical
method
being
used
in
the
on­
line
system.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

87
Table
B1­
3,
Headspace
Gas:
Summary
of
Field
Quality
Control
Sample
Acceptance
Criteria
QC
SAMPLES
ACCEPTANCE
CRITERIA
CORRECTIVE
ACTION
a
Field
Blanks
VOC
amounts
 
3
x
MDLs
in
Table
B3­
2
for
GC/
MS
or
GC/
FID;
 
PRQLs
in
Table
B3­
2
for
FTIRS
Nonconformance
if
any
VOC
amount
>
3
x
MDLs
in
Table
B3­
2
for
GC/
MS
or
GC/
FID;
>
PRQLs
in
Table
B3­
2
for
FTIRS
Sampling
Equipment
Blanks
VOC
amounts
 
3
x
MDLs
in
Table
B3­
2
for
GC/
MS
or
GC/
FID;
 
PRQLs
in
Table
B3­
2
for
FTIRS
Nonconformance
if
any
analyte
amount
>
3
x
MDLs
in
Table
B3­
2
for
GC/
MS
or
GC/
FID;
>
PRQLs
in
Table
B3­
2
for
FTIRS
Field
Reference
Standards
Or
On­
Line
Control
Samples
70
­
130
%
R
Nonconformance
if
%
R
<
70
or
>
130
Field
Duplicates
Or
On­
Line
Duplicates
RPD
<
25
%
Nonconformance
if
RPD
>
25
%

a
Corrective
action
is
only
required
if
the
final
reported
QC
sample
results
do
not
meet
the
acceptance
criteria.

MDL
=
Method
detection
limit
%
R
=
Percent
recover
RPD
=
Relative
percent
difference
Table
B1­
4,
Sample
Handling
Requirements
for
Homogeneous
Solids
and
Soil/
Gravel
PARAMETER
SUGGESTED
QUANTITYa
REQUIRED
PRESERVATIVE
SUGGESTED
CONTAINER
MAXIMUM
HOLDING
TIMEc
VOCs
15
grams
Cool
to
4
o
C
Glass
Viald
14
Days
Prep/
40
Days
Analyzee
SVOCs
50
grams
Cool
to
4
o
C
Glass
Jarf
14
Days
Prep/
40
Days
Analyzee
PCBsg
50
grams
Cool
to
4
o
C
Glass
Jarf
14
Days
Prep/
40
Days
Analyzee
Metals
10
grams
Cool
to
4
o
C
Plastic
Jarh
180
Daysi
a
Quantity
may
be
increased
or
decreased
according
to
the
requirements
of
the
analytical
laboratory,
as
long
as
the
QAOs
are
met.
c
Holding
time
begins
at
sample
collection
(
holding
times
are
consistent
with
SW­
846
requirements).
d
40­
mL
VOA
vial
or
other
appropriate
containers
shall
have
an
airtight
cap.
e
40­
day
holding
time
allowable
only
for
methanol
extract
­
14­
day
holding
time
for
non­
extracted
VOCs.
f
Appropriate
containers
(
e.
g.,
opaque
glass
container)
should
be
used
and
should
have
Teflon
®
lined
caps.
g
Analysis
for
PCBs
is
required
only
for
waste
streams
in
waste
matrix
code
S3220
(
organic
sludges)
or
for
waste
forms
indicated
by
AK.
h
Polyethylene
or
polypropylene
is
preferred,
glass
jar
is
allowable.
i
Holding
time
for
mercury
analysis
is
28
days.

NOTE:
Preservation
requirements
in
the
most
recent
version
of
SW­
846
may
be
used
if
appropriate.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

88
TABLE
B1­
5
HEADSPACE
GAS
DRUM
AGE
CRITERIA
SAMPLING
SCENARIOS
Scenario
Description
1
A.
Unvented
drums
without
rigid
poly
liners
are
sampled
through
the
drum
lid
at
the
time
of
venting.
B1.
Unvented
drums
with
unvented
rigid
poly
liners
are
sampled
through
the
rigid
poly
liner
at
the
time
of
venting
or
prior
to
venting.
B2.
Vented
drums
with
unvented
rigid
poly
liners
are
sampled
through
the
rigid
poly
liner
at
the
time
of
venting
or
prior
to
venting.
C.
Unvented
drums
with
vented
rigid
poly
liners
are
sampled
through
the
drum
lid
at
the
time
of
venting.

2
Drums
that
have
met
the
criteria
for
Scenario
1
and
then
are
vented,
but
not
sampled
at
the
time
of
venting.
a
3
Containers
(
i.
e.,
drums,
SWBs,
and
pipe
components)
that
are
initially
packaged
in
a
vented
condition
and
sampled
in
the
container
headspace
and
containers
that
are
not
sampled
under
Scenario
1
or
2.

a
Containers
that
have
not
met
the
Scenario
1
DAC
at
the
time
of
venting
must
be
categorized
under
Scenario
3.
This
requires
the
additional
information
required
of
each
container
in
Scenario
3
(
i.
e.,
determination
of
packaging
configuration),
and
such
containers
can
only
be
sampled
after
meeting
the
appropriate
Scenario
3
DAC.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

89
TABLE
B1­
6
SCENARIO
1
DRUM
AGE
CRITERIA
(
in
days)
MATRIX
Summary
Category
Group
DAC
(
days)

S3000/
S4000
127
S5000
53
NOTE:
Containers
that
are
sampled
using
the
Scenario
1
DAC
do
not
require
information
on
the
packaging
configuration
because
the
Scenario
1
DAC
are
based
on
a
bounding
packaging
configuration.
In
addition,
Information
on
the
rigid
liner
vent
hole
presence
and
diameter
do
not
apply
to
containers
that
are
sampled
using
the
Scenario
1
DAC
because
they
are
unvented
prior
to
sampling.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

90
TABLE
B1­
7
SCENARIO
2
DRUM
AGE
CRITERIA
(
in
days)
MATRIX
Summary
Category
Group
S3000/
S4000
Summary
Category
Group
S5000
Filter
H2
Diffusivity
a
Rigid
Liner
Vent
Hole
Diameter
(
in)
b
Rigid
Liner
Vent
Hole
Diameter
(
in)
b
(
mol/
s/
mod
fraction)
0.30
0.375
0.75
1.0
0.30
0.375
0.75
1.0
1.9
x
10­
6
36
30
23
22
29
22
13
12
3.7
x
10­
6
30
25
19
18
25
20
12
11
3.7
x
10­
5
13
11
11
11
7
6
6
4
a
The
documented
filter
H2
diffusivity
must
be
greater
than
or
equal
to
the
listed
value
to
use
the
DAC
for
the
listed
filter
H2
diffusivity
(
e.
g.,
a
container
with
a
filter
H2
diffusivity
of
4.2
x
10­
6
must
use
a
DAC
for
a
filter
with
a
3.7
x
10­
6
filter
H2
diffusivity).
If
a
filter
H2
diffusivity
for
a
container
is
undocumented
or
unknown
or
is
less
than
1.9
x
10­
6
filter
H2
diffusivity,
a
filter
of
known
H2
diffusivity
that
is
greater
than
or
equal
to
1.9
x
10­
6
filter
H2
diffusivity
must
be
installed
prior
to
initiation
of
the
relevant
DAC
period.

b
The
documented
rigid
liner
vent
hole
diameter
must
be
greater
than
or
equal
to
the
listed
value
to
use
the
DAC
for
the
listed
rigid
liner
vent
hole
diameter
(
e.
g.,
a
container
with
a
rigid
liner
vent
hole
of
0.5
in.
must
use
a
DAC
for
a
rigid
liner
vent
hole
of
0.375
in.).
If
the
rigid
liner
vent
hole
diameter
for
a
container
is
undocumented
during
packaging
(
Attachment
B,
Section
B­
3(
d)
1),
repackaging
(
Attachment
B,
Section
B­
3(
d)
1),
and/
or
venting
(
Section
B1­
1a[
6][
ii]),
that
container
must
use
a
DAC
for
a
rigid
liner
vent
hole
diameter
of
0.30
in.

NOTE:
Containers
that
are
sampled
using
the
Scenario
2
DAC
do
not
require
information
on
the
packaging
configuration
because
the
Scenario
2
DAC
are
based
on
a
bounding
packaging
configuration.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

91
TABLE
B1­
8
SCENARIO
3
PACKAGING
CONFIGURATION
GROUPS
Packaging
Configuration
Group
Covered
S3000/
S4000
Packaging
Configuration
Groups
Covered
S5000
Packaging
Configuration
Groups
Packaging
Configuration
Group
1,
55­
gal.
drums
a
 
No
layers
of
confinement,
filtered
inner
lid
b
 
No
inner
bags,
no
liner
bags
(
bounding
case)
 
No
layers
of
confinement,
filtered
inner
lid
b
 
No
inner
bags,
no
liner
bags
(
bounding
case)

Packaging
Configuration
Group
2,
55­
gal.
drums
a
 

1
inner
bag
 
1
filtered
inner
bag
 
1
liner
bag
(
bounding
case)
 
1
filtered
liner
bag
 
1
inner
bag
 
1
filtered
inner
bag
 
1
liner
bag
 
1
filtered
liner
bag
 
1
inner
bag,
1
liner
bag
 
1
filtered
inner
bag,
1
filtered
liner
bag
 
2
inner
bags
 
2
filtered
inner
bags
 
2
inner
bags,
1
liner
bag
 
2
filtered
inner
bags,
1
filtered
liner
bag
 
3
inner
bags
 
3
filtered
inner
bags
 
3
filtered
inner
bags,
1
filtered
liner
bag
 
3
inner
bags,
1
liner
bag
(
bounding
case)

Packaging
Configuration
Group
3,
55­
gal.
drums
a
 

1
inner
bag,
1
liner
bag
 
1
filtered
inner
bag,
1
filtered
liner
bag
 
2
inner
bags
 

2
liner
bags
 
2
filtered
liner
bags
 
1
inner
bag,
2
liner
bags
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

92
 
2
filtered
inner
bags
 
2
liner
bags
(
bounding
case)
 
2
filtered
liner
bags
 
1
filtered
inner
bag,
2
filtered
liner
bags
 
2
inner
bags,
2
liner
bags
 
2
filtered
inner
bags,
2
filtered
liner
bags
 
3
filtered
inner
bags,
2
filtered
liner
bags
 
4
inner
bags
 
3
inner
bags,
2
liner
bags
 
4
inner
bags,
2
liner
bags
(
bounding
case)

Packaging
Configuration
Group
4,
pipe
components
 

No
layers
of
confinement
inside
a
pipe
component
 
1
filtered
inner
bag,
1
filtered
metal
can
inside
a
pipe
component
 
2
inner
bags
inside
a
pipe
component
 
2
filtered
inner
bags
inside
a
pipe
component
 
2
filtered
inner
bags,
1
filtered
metal
can
inside
a
pipe
component
 
2
inner
bags,
1
filtered
metal
can
inside
a
pipe
component
(
bounding
case)
 
No
layers
of
confinement
inside
a
pipe
component
 
1
filtered
inner
bag,
1
filtered
metal
can
inside
a
pipe
component
 
2
inner
bags
inside
a
pipe
component
 
2
filtered
inner
bags
inside
a
pipe
component
 
2
filtered
inner
bags,
1
filtered
metal
can
inside
a
pipe
component
 
2
inner
bags,
1
filtered
metal
can
inside
a
pipe
component
(
bounding
case)

Packaging
Configuration
Group
5,
Standard
Waste
Box
a
 

No
layers
of
confinement
 
1
SWB
liner
bag
(
bounding
case)
 

No
layers
of
confinement
 
1
SWB
liner
bag
(
bounding
case)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

93
Packaging
Configuration
Group
6,
Standard
Waste
Box
a
 

any
combination
of
inner
and/
or
liner
bags
that
is
less
than
or
equal
to
6
 
5
inner
bags,
1
SWB
liner
bag
(
bounding
case)
 
any
combination
of
inner
and/
or
liner
bags
that
is
less
than
or
equal
to
6
 
5
inner
bags,
1
SWB
liner
bag
(
bounding
case)

a
If
a
specific
Packaging
Configuration
Groups
cannot
be
determined
based
on
the
data
collected
during
packaging
(
Attachment
B,
Section
B­
3(
d)
1)
and/
or
repackaging
(
Attachment
B,
Section
B­
3(
d)
1),
a
conservative
default
Packaging
Configuration
Group
of
3
for
55­
gal.
drums
and
6
for
SWBs
must
be
assigned
provided
the
55­
gal.
drums
do
not
contain
pipe
component
packaging.
If
pipe
components
are
present
as
packaging
in
the
55­
gal.
drums,
the
pipe
components
must
be
sampled
following
the
requirements
for
Packaging
Configuration
Group
4.

b
A
filtered
inner
lid@
is
the
inner
lid
on
a
double
lid
drum
that
contains
a
filter.

Definitions:
Liner
Bags:
One
or
more
optional
plastic
bags
that
are
used
to
control
radiological
contamination.
Liner
bags
for
drums
have
a
thickness
of
approximately
11
mils.
SWB
liner
bags
have
a
thickness
of
approximately
14
mils.
Liner
bags
are
typically
similar
in
size
to
the
container.

Inner
Bags:
One
or
more
optional
plastic
bags
that
are
used
to
control
radiological
contamination.
Inner
bags
have
a
thickness
of
approximately
5
mils
and
are
typically
smaller
than
liner
bags.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

94
TABLE
B1­
9
SCENARIO
3
DRUM
AGE
CRITERIA
(
in
days)
MATRIX
FOR
S5000
WASTE
BY
PACKAGING
CONFIGURATION
GROUP
Packaging
Configuration
Group
1
Rigid
Liner
Vent
Hole
Diameter
b
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
0.3­
inch
Diameter
Hole
0.375­
inch
Diameter
Hole
0.75­
inch
Diameter
Hole
1­
inch
Diameter
Hole
No
Liner
Lid
No
Liner
1.9
x
10­
6
131
95
37
24
4
4
3.7
x
10­
6
111
85
36
24
4
4
3.7
x
10­
5
28
28
23
19
4
4
Packaging
Configuration
Group
2
Rigid
Liner
Vent
Hole
Diameter
b
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
0.3­
inch
Diameter
Hole
0.375­
inch
Diameter
Hole
0.75­
inch
Diameter
Hole
1­
inch
Diameter
Hole
No
Liner
Lid
No
Liner
1.9
x
10­
6
175
138
75
60
30
11
3.7
x
10­
6
152
126
73
59
30
11
3.7
x
10­
5
58
57
52
47
28
8
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

95
Packaging
Configuration
Group
3
Rigid
Liner
Vent
Hole
Diameter
b
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
0.3­
inch
Diameter
Hole
0.375­
inch
Diameter
Hole
0.75­
inch
Diameter
Hole
1­
inch
Diameter
Hole
No
Liner
Lid
No
Liner
1.9
x
10­
6
199
161
96
80
46
16
3.7
x
10­
6
175
148
93
79
46
16
3.7
x
10­
5
72
72
67
62
42
10
Packaging
Configuration
Group
4
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
Headspace
Sample
Taken
Inside
Pipe
Component
>
1.9
x
10­
6
152
Packaging
Configuration
Group
5
Filter
H2
Diffusivity
a,
c
(
mol/
s/
mol
fraction)
Headspace
Sample
Taken
Inside
SWB
>
7.4
x
10­
6
15
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

96
Packaging
Configuration
Group
6
Filter
H2
Diffusivity
a,
c
(
mol/
s/
mol
fraction)
Headspace
Sample
Taken
Inside
SWB
>
7.4
x
10­
6
56
a
The
documented
filter
H2
diffusivity
must
be
greater
than
or
equal
to
the
listed
value
to
use
the
DAC
for
the
listed
filter
H2
diffusivity
(
e.
g.,
a
container
with
a
filter
H2
diffusivity
of
4.2
x
10­
6
must
use
a
DAC
for
a
filter
with
a
3.7
x
10­
6
filter
H2
diffusivity).
If
a
filter
H2
diffusivity
for
a
container
is
undocumented
or
unknown
or
is
less
than
1.9
x
10­
6
filter
H2
diffusivity,
a
filter
of
known
H2
diffusivity
that
is
greater
than
or
equal
to
1.9
x
10­
6
filter
H2
diffusivity
must
be
installed
prior
to
initiation
of
the
relevant
DAC
period.

b
The
documented
rigid
liner
vent
hole
diameter
must
be
greater
than
or
equal
to
the
listed
value
to
use
the
DAC
for
the
listed
rigid
liner
vent
hole
diameter
(
e.
g.,
a
container
with
a
rigid
liner
vent
hole
of
0.5
in.
must
use
a
DAC
for
a
rigid
liner
vent
hole
of
0.375
in.).
If
the
rigid
liner
vent
hole
diameter
for
a
container
is
undocumented
during
packaging
(
Attachment
B,
Section
B­
3(
d)
1),
repackaging
(
Attachment
B,
Section
B­
3(
d)
1),
and/
or
venting
(
Section
B1­
1a[
6][
ii]),
that
container
must
use
a
DAC
for
a
rigid
liner
vent
hole
diameter
of
0.30
in.

C
The
filter
H2
diffusivity
for
SWBs
is
the
sum
of
the
diffusivities
for
all
of
the
filters
on
the
container
because
SWBs
have
more
than
1
filter.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

97
TABLE
B1­
10
SCENARIO
3
DRUM
AGE
CRITERIA
(
in
days)
MATRIX
FOR
S3000
AND
S4000
WASTE
BY
PACKAGING
CONFIGURATION
GROUP
Packaging
Configuration
Group
1
Rigid
Liner
Vent
Hole
Diameter
b
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
0.3­
inch
Diameter
Hole
0.375­
inch
Diameter
Hole
0.75­
inch
Diameter
Hole
1­
inch
Diameter
Hole
No
Liner
Lid
No
Liner
1.9
x
10­
6
131
95
37
24
4
4
3.7
x
10­
6
111
85
36
24
4
4
3.7
x
10­
5
28
28
23
19
4
4
Packaging
Configuration
Group
2
Rigid
Liner
Vent
Hole
Diameter
b
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
0.3­
inch
Diameter
Hole
0.375­
inch
Diameter
Hole
0.75­
inch
Diameter
Hole
1­
inch
Diameter
Hole
No
Liner
Lid
No
Liner
1.9
x
10­
6
213
175
108
92
56
18
3.7
x
10­
6
188
161
105
90
56
17
3.7
x
10­
5
80
80
75
71
49
10
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

98
Packaging
Configuration
Group
3
Rigid
Liner
Vent
Hole
Diameter
b
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
0.3­
inch
Diameter
Hole
0.375­
inch
Diameter
Hole
0.75­
inch
Diameter
Hole
1­
inch
Diameter
Hole
No
Liner
Lid
No
Liner
1.9
x
10­
6
283
243
171
154
107
34
3.7
x
10­
6
253
225
166
151
106
31
3.7
x
10­
5
121
121
115
110
84
13
Packaging
Configuration
Group
4
Filter
H2
Diffusivity
a
(
mol/
s/
mol
fraction)
Headspace
Sample
Taken
Inside
Pipe
Component
>
1.9
x
10­
6
152
Packaging
Configuration
Group
5
Filter
H2
Diffusivity
a,
c
(
mol/
s/
mol
fraction)
Headspace
Sample
Taken
Inside
SWBS
>
7.4
x
10­
6
15
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

99
Packaging
Configuration
Group
6
Filter
H2
Diffusivity
a,
c
(
mol/
s/
mol
fraction)
Headspace
Sample
Taken
Inside
SWBS
>
7.4
x
10­
6
56
a
The
documented
filter
H2
diffusivity
must
be
greater
than
or
equal
to
the
listed
value
to
use
the
DAC
for
the
listed
filter
H2
diffusivity
(
e.
g.,
a
container
with
a
filter
H2
diffusivity
of
4.2
x
10­
6
must
use
a
DAC
for
a
filter
with
a
3.7
x
10­
6
filter
H2
diffusivity).
If
a
filter
H2
diffusivity
for
a
container
is
undocumented
or
unknown
or
is
less
than
1.9
x
10­
6
filter
H2
diffusivity,
a
filter
of
known
H2
diffusivity
that
is
greater
than
or
equal
to
1.9
x
10­
6
filter
H2
diffusivity
must
be
installed
prior
to
initiation
of
the
relevant
DAC
period.

b
The
documented
rigid
liner
vent
hole
diameter
must
be
greater
than
or
equal
to
the
listed
value
to
use
the
DAC
for
the
listed
rigid
liner
vent
hole
diameter
(
e.
g.,
a
container
with
a
rigid
liner
vent
hole
of
0.5
in.
must
use
a
DAC
for
a
rigid
liner
vent
hole
of
0.375
in.).
If
the
rigid
liner
vent
hole
diameter
for
a
container
is
undocumented
during
packaging
(
Attachment
B,
Section
B­
3(
d)
1),
repackaging
(
Attachment
B,
Section
B­
3(
d)
1),
and/
or
venting
(
Section
B1­
1a[
6][
ii]),
that
container
must
use
a
DAC
for
a
rigid
liner
vent
hole
diameter
of
0.30
in.

C
The
filter
H2
diffusivity
for
SWBs
is
the
sum
of
the
diffusivities
for
all
of
the
filters
on
the
container
because
SWBs
have
more
than
1
filter.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

100
Select
Container
Was
container
packaged
in
vented
condition?

Will
container
be
sampled
at
the
time
of
venting?

Was
Scenario
1
DAC
satisfied
at
time
of
venting?
(
Table
B1­
6)

Was
rigid
liner
vent
hole
diameter
documented
during
venting
by
lid
punching
per
Section
B1­
1a(
6)(
ii)?

Select
appropriate
filter
diffusivity
and
documented
rigid
liner
vent
hole
diameter
from
Table
B1­
7
Select
appropriate
filter
diffusivity
and
default
rigid
liner
vent
hole
diameter
from
Table
B1­
7
Satisfy
appropriate
Scenario
1
DAC
before
sampling
(
Table
B1­
6)

Satisfy
appropriate
Scenario
2
DAC
before
sampling
Table
B1­
7
Were
packaging
configuration
and
rigid
liner
vent
hole
presence
and
diameter
documented
during
packaging/
repackaging
per
Section
B­
3d(
1)?

Select
default
packaging
configuration
for
Scenario
3
(
Table
B1­
8)

Select
appropriate
filter
diffusivity
and
documented
rigid
liner
vent
hole
diameter
from
Table
B1­
9:
S5000
Table
B1­
10:
S3000/
4000
Select
appropriate
filter
diffusivity
and
default
rigid
liner
vent
hole
diameter
from:
Table
B1­
9:
S5000
Table
B1­
10:
S3000/
4000
Select
appropriate
packaging
configuration
for
Scenario
3
based
on
packaging
documentation
(
Table
B1­
8)

Satisfy
appropriate
Scenario
3
DAC
before
sampling
Table
B1­
9:
S5000
Table
B1­
10:
S3000/
4000
No
Yes
Yes
Yes
Yes
Yes
No
No
No
No
Figure
B1­
1,
Headspace
Gas
Drum
Age
Criteria
Sampling
Scenario
Selection
Process
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

101
AMWTP
COC
No.

Waste
Characterization
Facility
Chain
of
Custody
Sampling
Location
AMWTP
Analytical
Location
INEEL
Sampling
Batch
No.
Sample
Matrix
SOLID
Container
ID
IDC
Sample
ID
Sample
Date
Sample
Time
Size
Weight
VOC
NHVOC
Semi
VOC
PCB
Metals
Comments
All
samples
are
preserved
by
cooling
to
4
+/­
2
Degrees
C
Sampler
Initiating
Custody:__
_______________________________________________________________________

Print
Name:
Signature:
TID:
Date/
Time:

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by:
Date
Time
Received
by:
Date
Time
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by:
Date
Time
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by:
Date
Time
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by:
Date
Time
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by:
Date
Time
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by:
Date
Time
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by:
Date
Time
Discrepancies:

Figure
B1­
2,
Example
of
the
AMWTP
Chain­
of­
Custody
for
Homogeneous
Solids
and
Soil/
Gravel
Samples
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

102
Figure
B1­
3,
Overall
Programmatic
Approach
to
Visual
Examination
of
the
Waste
for
Confirmation
of
RTR
NO
YES
Use
radiography
to
determine/
verify
the
matrix
parameter
category
and
estimate
waste
material
parameter
weights.

Perform
visual
examination
Visually
examine
unopened
waste
bags/
packages.

Can
Waste
Matrix
Code
and
waste
material
parameter
weights
be
determined
without
opening
bags/
packages?
Perform
a
limited
visual
examination
through
the
unopened
bags/
packages.

Confirm
radiography­
indicated
WMC
and
determine
waste
material
parameter
weights.
Perform
a
full
visual
examination.

Open
bags/
packages.

Determine
Waste
Matrix
Code
and
waste
material
parameter
weights.

Based
on
the
results
of
visual
examination,
calculate
the
percentage
of
waste
containers
with
incorrectly
assigned
waste
matrix
code.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

103
B2.
STATISTICAL
METHODS
USED
IN
SAMPLING
AND
ANALYSIS
The
AMWTP
uses
the
following
statistical
methods
for
sampling
and
analysis
of
TRU
waste.
These
statistical
methods
include
methods
for
selecting
waste
containers
for
visual
inspection,
selecting
retrievably
stored
waste
containers
for
totals
analysis,
setting
the
upper
confidence
limit,
and
control
charting
for
newly
generated
waste
stream
sampling.

B2­
1
Approach
for
Statistically
Selecting
Waste
Containers
for
Visual
Examination
(
to
confirm
RTR)

As
a
QC
check
on
the
radiographic
examination
of
waste
containers,
a
statistically
selected
portion
of
the
certified
waste
containers
is
opened
and
visually
examined.
The
data
from
VE
are
used
to
verify
the
waste
matrix
code,
waste
material
parameter
weights,
and
absence
of
prohibited
items
as
determined
by
radiography.

The
data
obtained
from
the
visual
examination
are
also
used
to
determine,
with
acceptable
confidence,
the
percentage
of
miscertified
waste
containers
from
the
radiographic
examination.
Miscertified
containers
are
those
that
radiography
indicates
meet
the
WAC
for
the
WIPP
and
the
TRUPACT­
Il
Authorized
Methods
for
Payload
Control
but
that
VE
indicates
do
not
meet
these
criteria.

Initially,
the
AMWTP
will
use
an
eleven­
percent
(
11%)
miscertification
rate
to
calculate
the
number
of
waste
containers
to
undergo
VE
until
an
AMWTP­
specific
miscertification
rate
is
established.
The
AMWTP
will
establish
a
site­
specific
miscertification
rate
is
by
characterizing
at
least
fifty
containers
in
a
single
summary
category
group
at
the
initial
11%
miscertification
rate.
The
results
of
this
initial
characterization
then
serve
as
the
site­
specific
miscertification
rate
until
reassessed
as
described
below.

The
site­
specific
miscertification
rate
is
applied
initially
to
each
summary
category
group
to
determine
the
number
of
containers
in
that
summary
category
group
requiring
visual
examination,
as
specified
in
Table
B2­
1.
However,
a
summary
category
group
specific
miscertification
rate
is
determined
when
either
six
months
have
passed
since
radiographic
characterization
commenced
on
a
given
summary
category
group,
or
at
least
50%
of
a
given
summary
category
group
has
undergone
radiographic
characterization,
whichever
occurs
first.
The
summary
category
group
is
then
subject
to
the
VE
requirements
of
this
reevaluated
summary
category
group
miscertification
rate
to
ensure
that
the
entire
summary
category
group
is
appropriately
characterized.

Table
B2­
1
provides
the
number
of
waste
containers
per
summary
category
group
that
undergo
VE
for
various
miscertification
rates
and
waste
container
population
sizes
using
a
hypergeometric
sampling
approach.
A
miscertification
rate
of
1%
is
used
for
any
waste
stream­
specific
miscertification
rate
calculated
to
be
less
than
1%.

The
site­
specific
miscertification
rate
is
reassessed
annually
by
calculating
a
drum­
weighted
average
of
all
historic
summary
category
group
miscertification
rates.
Each
summary
category
group
miscertification
rate
is
rounded
off
to
the
nearest
integer
value
before
being
used
to
calculate
the
new
site­
specific
miscertification
rate.
A
miscertification
rate
of
1%
is
used
for
any
site­
specific
miscertification
rate
calculated
to
be
less
than
1%.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

104
The
number
of
waste
containers
requiring
VE
(
as
identified
in
Table
B2­
1)
utilizes
a
hypergeometric
approach
and
is
based
on
a
90
percent
confidence
that
the
actual
miscertification
rate
(
for
the
population)
is
less
than
the
90
percent
upper
confidence
level
(
UCL),
and
also
an
80
percent
confidence
that
the
UCL
will
be
less
than
14
percent
if
the
actual
miscertification
rate
is
the
same
as
the
targeted
percent
of
miscertified
waste
containers
(
column
heading
of
Table
B2­
1).
Thus,
there
is
only
a
10
percent
probability
that
the
UCL
will
be
below
14
percent
in
the
case
where
the
actual
miscertification
rate
is
14
percent
or
greater.
Also,
there
is
only
a
20
percent
probability
that
the
UCL
will
be
above
14
percent
in
the
case
where
the
actual
miscertification
rate
is
the
same
as
the
targeted
percent.

The
hypergeometric
approach
to
determining
the
number
of
containers
to
undergo
VE
is
dependant
upon
the
defined
estimate
of
the
allowable
proportion
of
containers
that
were
miscertified
and
information
on
previous
percentages
of
containers
that
were
miscertified.
The
rationale
and
details
of
this
methodology
are
discussed
further
in
Attachment
B2
of
the
WIPP­
WAP,
and
compliance
with
the
requirements
for
statistically
selection
waste
containers
for
VE
is
achieved
through
the
execution
of
site­
specific
procedure
MP­
TRUW­
8.19,
RTR/
VE
Drum
Selection.

B2­
2
Approach
for
Statistically
Selecting
Retrievably
Stored
Waste
Containers
for
Total
(
or
TCLP)
Analysis
B2­
2a
Statistical
Selection
of
Containers
for
Totals
Analysis
The
statistical
approach
for
characterizing
retrievably
stored
homogeneous
solids
and
soil/
gravel
waste
and
repackaged
or
treated
S3000
waste
that
the
AMWTP
demonstrates
is
not
suitable
for
control
charting
using
sampling
and
analysis
relies
on
using
AK
to
segregate
waste
containers
into
relatively
homogeneous
waste
streams.
Using
AK,
the
entire
waste
stream
is
classified
as
hazardous
or
nonhazardous
rather
than
individual
waste
containers.
Individual
waste
containers
serve
as
convenient
units
for
characterizing
the
combined
mass
of
waste
from
the
waste
stream
of
interest.
Once
segregated
by
waste
stream,
random
selection
and
sampling
of
the
waste
containers
followed
by
analysis
of
the
waste
samples
is
performed
to
ensure
that
the
resulting
mean
contaminant
concentration
provides
an
unbiased
representation
of
the
true
mean
contaminant
concentration
for
each
waste
stream.
The
SPM
verifies
that
the
samples
collected
from
within
a
waste
stream
were
selected
randomly
in
accordance
with
MP­
TRUW­
8.25,
Homogeneous
Solids
and
Soils/
Gravel
Sampling
Plan.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

105
An
end
use
of
analytical
results
for
retrievably
stored
homogeneous
solids
and
soil/
gravel
is
for
assigning
the
EPA
hazardous
waste
D­
codes
that
apply
to
each
mixed
waste
stream
and
to
confirm
AK.
The
D­
codes
are
indicators
that
the
waste
exhibits
the
toxicity
characteristic
for
specific
contaminants
under
RCRA.
The
RCRA­
toxicity
determination
is
made
on
the
basis
of
sampling
and
analysis
of
waste
streams
and
on
whether
or
not
the
waste
stream
includes
F­
code
wastes.
If
a
waste
stream
includes
one
or
more
RCRA
Fcodes
identified
via
AK,
toxicity
characteristic
contaminants
associated
with
the
F­
code
waste(
s)
are
not
included
in
the
RCRA­
toxicity
characteristic
determination.
That
is,
the
F­
codes
take
precedence
over
RCRA­
toxicity
D­
code,
and
the
waste
stream
is
assumed
hazardous
regardless
of
the
concentration.
Therefore,
toxicity
characteristics
contaminants
associated
with
F­
codes(
s)
for
a
waste
stream
are
omitted
from
all
calculations
for
determining
the
number
of
containers
to
sample
because
these
wastes
streams
are
assumed
to
be
hazardous.
In
addition,
each
toxicity
characteristic
contaminant
associated
with
the
Fcode
s)
is
excluded
from
evaluation
of
analytical
results
to
determine
D­
codes.
Contaminants
of
interest
for
the
sampling,
analysis,
and
RCRA­
toxicity
determination
of
a
waste
stream,
then,
excludes
contaminants
associated
with
F­
codes
that
have
been
assigned
to
the
waste
stream.

The
sampling
and
analysis
strategy
is
illustrated
in
Figure
B2­
1.
Preliminary
estimates
of
the
mean
concentration
and
variance
of
each
RCRA
regulated
contaminant
in
the
waste
is
used
to
determine
the
number
of
waste
containers
to
select
for
sampling
and
analysis.
The
preliminary
estimates
are
made
by
obtaining
a
preliminary
number
of
samples
from
the
waste
stream
or
from
previous
sampling
from
the
waste
stream.
Preliminary
estimates
are
based
on
samples
from
a
minimum
of
5
waste
containers.
Samples
collected
to
establish
preliminary
estimates
that
are
selected,
sampled,
and
analyzed
in
accordance
with
applicable
provisions
of
the
WIPP­
WAP
may
be
used
as
part
of
the
required
number
of
samples
to
be
collected.
The
applicability
of
the
preliminary
estimates
to
the
waste
stream
to
be
sampled
is
justified
and
documented.
The
preliminary
estimates
for
the
mean,
variance
and
the
appropriate
number
of
samples
(
n)
to
be
collected
for
each
contaminant
is
calculated
in
accordance
with
the
equations
presented
in
Section
B2­
2a
of
the
WIPP­
WAP.

The
number
of
samples
collected
is
based
upon
the
largest
n
calculated
for
each
of
the
contaminants
of
concern.
The
actual
number
of
samples
collected
is
adjusted
as
necessary
to
ensure
that
an
adequate
number
of
samples
are
collected
to
allow
for
acceptable
levels
of
completeness.

All
calculations
are
rounded
up
to
the
nearest
integer.
A
minimum
of
five
containers
are
sampled
and
analyzed
in
each
waste
stream.
If
there
are
fewer
than
the
minimum
of
the
required
number
of
containers
in
a
waste
stream,
one
or
more
containers
is
sampled
more
than
once
to
obtain
the
samples
of
the
waste.
Otherwise
any
one
container
may
be
selected
for
sampling
only
once.

The
calculated
total
number
of
required
waste
containers
will
then
be
randomly
sampled
and
analyzed.
Waste
containers
from
the
preliminary
mean
and
variance
estimates
may
be
counted
as
part
of
the
total
number
of
calculated
required
samples
if
and
only
if:

 
There
is
documented
evidence
that
the
waste
containers
for
the
preliminary
estimate
samples
were
selected
in
the
same
random
manner
as
is
chosen
for
the
required
samples.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

106
 
There
is
documented
evidence
that
the
method
of
sample
collection
in
the
preliminary
estimate
samples
were
identical
to
the
methodology
to
be
employed
for
the
required
samples.

 
There
is
documented
evidence
that
the
method
of
sample
analysis
in
the
preliminary
estimate
samples
were
identical
to
the
analytical
methodology
employed
for
the
required
samples.

 
There
is
documented
evidence
that
the
validation
of
the
sample
analyses
in
the
preliminary
estimate
samples
were
comparable
to
the
validation
employed
for
the
required
samples.
In
addition,
the
validated
samples
results
shall
indicate
that
all
sample
results
were
valid
according
to
the
analytical
methodology.

Upon
collection
and
analysis
of
the
preliminary
samples,
or
at
any
time
after
the
preliminary
samples
have
been
analyzed,
the
AMWTP
may
assign
hazardous
waste
codes
to
a
waste
stream.
For
waste
streams
with
calculated
upper
confidence
limits
below
the
regulatory
threshold,
the
AMWTP
shall
collect
the
required
number
of
samples
if
the
AMWTP
intends
to
establish
that
the
constituent
is
below
the
regulatory
threshold.

B2­
2b
Statistical
Selection
of
Containers
for
Headspace
Gas
Analysis
When
a
waste
stream
meets
the
conditions
for
representative
headspace
gas
sampling
as
discussed
in
Section
B­
3a(
1),
headspace
gas
sampling
of
that
waste
stream
may
be
done
on
a
randomly
selected
portion
of
containers
in
the
waste
stream.
The
minimum
number
of
containers,
n,
that
must
be
sampled
is
determined
by
taking
an
initial
VOC
sample
from
10
randomly
selected
containers.
These
samples
are
analyzed
for
all
the
target
analytes.
The
standard
deviation,
s,
is
calculated
for
each
of
the
nine
VOCs
in
Module
IV,
Table
IV.
D.
1
of
the
WIPP
Hazardous
Waste
Permit.
The
value
of
n
is
determined
as
the
largest
number
of
samples
(
not
to
exceed
the
number
of
containers
in
the
waste
stream
or
waste
stream
lot)
calculated
using
equations
B2­
8
in
the
WIPP­
WAP
Waste
container
samples
from
the
preliminary
mean
and
variance
estimates
may
be
counted
as
part
of
the
total
number
of
calculated
required
samples
if
and
only
if:

 
There
is
documented
evidence
that
the
waste
containers
for
the
preliminary
estimate
samples
were
selected
in
the
same
random
manner
as
is
chosen
for
the
required
samples.

 
There
is
documented
evidence
that
the
method
of
sample
collection
in
the
preliminary
estimate
samples
were
identical
to
the
methodology
to
be
employed
for
the
required
samples.

 
There
is
documented
evidence
that
the
method
of
sample
analysis
in
the
preliminary
estimate
samples
were
identical
to
the
analytical
methodology
employed
for
the
required
samples.

 
There
is
documented
evidence
that
the
validation
of
the
sample
analyses
in
the
preliminary
estimate
samples
were
comparable
to
the
validation
employed
for
the
required
samples.
In
addition,
the
validated
samples
results
shall
indicate
that
all
sample
results
were
valid
according
to
the
analytical
methodology.

The
mean
and
standard
deviation
calculated
after
sampling
n
containers
can
be
used
to
calculate
a
UCL90
for
each
of
the
headspace
gas
VOCs
using
the
methodology
presented
in
Section
B2­
3b.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

107
B2­
3
Upper
Confidence
Limit
for
Statistical
Sampling
B2­
3a
Upper
Confidence
Limit
for
Statistical
Solid
Sampling
Upon
completion
of
the
required
sampling,
final
mean
and
variance
estimates
and
the
UCL90
for
the
mean
concentration
for
each
contaminant
is
determined.
The
observed
sample
n*
is
checked
against
the
preliminary
estimate
for
the
number
of
samples
(
n)
to
be
collected
before
proceeding
using
the
equation
presented
in
Section
B2­
3a
of
the
WIPP­
WAP.

If
the
observed
sample
n*
estimate
results
in
greater
than
20
percent
more
required
samples
than
were
originally
calculated,
then
the
additional
samples
required
to
fulfill
the
revised
sample
estimate
are
collected
and
analyzed.
The
determination
of
n*
is
an
iterative
process
that
continues
until
the
difference
between
n*
and
the
previous
sample
determination
is
less
than
20
percent.

Once
sufficient
sampling
and
analysis
has
occurred,
the
waste
characterization
will
proceed.
The
assessment
is
made
with
90
percent
confidence.
The
UCL90
for
the
mean
concentration
of
each
contaminant
will
be
calculated
in
accordance
with
the
equation
presented
in
Section
B2­
3a
of
the
WIPPWAP

If
the
UCL90
for
the
mean
concentration
is
less
than
the
regulatory
threshold
limit,
the
waste
stream
is
not
assigned
the
hazardous
waste
code
for
this
contaminant.
If
the
UCL90
is
greater
than
or
equal
to
the
regulatory
threshold
limit,
the
waste
stream
is
assigned
the
hazardous
waste
code
for
this
contaminant.

Compliance
with
the
requirements
for
calculation
and
comparison
of
the
UCL90
to
regulatory
thresholds
is
achieved
through
the
execution
of
procedure
MP­
TRUW­
8.11,
Data
Reconciliation.

B2­
3b
Upper
Confidence
Limit
for
Statistical
Headspace
Gas
Sampling
If
a
waste
stream
meets
the
conditions
for
representative
headspace
gas
sampling
in
Section
B­
3a(
1),
a
UCL90
concentration
for
each
of
the
headspace
gas
VOCs
is
calculated
from
the
sample
data
collected.
The
observed
sample
n*
is
checked
against
the
estimate
for
the
number
of
samples
(
n)
to
be
collected
before
proceeding
using
the
equation
presented
in
Section
B2­
3b
of
the
WIPP­
WAP.

If
the
observed
sample
n*
estimate
results
in
greater
than
20
percent
more
required
samples
than
were
originally
calculated,
then
the
additional
samples
required
to
fulfill
the
revised
sample
estimate
are
collected
and
analyzed.
The
determination
of
n*
is
an
iterative
process
that
continues
until
the
difference
between
n*
and
the
previous
sample
determination
is
less
than
20
percent.

Then,
the
UCL90
is
calculated
using
the
UCL90
equation
presented
in
Section
B2­
3a
of
the
WIPP­
WAP.
In
this
case,
the
UCL90
is
the
90
percent
upper
confidence
VOC
concentration,
x
is
the
calculated
mean
VOC
concentration
and
s
is
the
standard
deviation.
The
value
of
t( ,
n­
1)
is
taken
from
Table
9­
2
of
Chapter
9
of
SW­
846.
When
composite
sample
headspace
gas
sample
results
are
used,
the
mean,
standard
deviation,
and
t­
statistic
are
based
on
the
number
of
composite
samples
analyzed,
rather
than
the
number
of
containers
sampled.
_
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

108
The
calculated
UCL90
concentration
for
each
headspace
gas
VOC
is
then
assigned
to
those
containers
in
the
waste
stream
not
selected
for
headspace
gas
sampling.
If
the
calculated
UCL90
concentration
is
less
than
the
applicable
MDL,
the
MDL
for
the
VOC
is
assigned
to
each
unsampled
container
instead
of
the
UCL90
concentration.
Compliance
with
the
requirements
for
calculations
and
comparisons
for
the
UCL90
to
regulatory
threshold
is
achieved
through
MP­
TRUW­
8.11,
Data
Reconciliation.

B2­
4
Control
Charting
for
Newly
Generated
Waste
Stream
Sampling
For
newly
generated
waste
streams
that
AMWTP
characterizes
using
control
charts,
significant
process
changes
and
process
fluctuations
associated
with
newly
generated
waste
is
determined
using
statistical
process
control
(
SPC)
charting
techniques;
these
techniques
require
historical
data
for
determining
limits
for
indicator
species,
and
subsequent
periodic
sampling
to
assess
process
behavior
relative
to
historical
limits.
SPC
is
performed
on
waste
prior
to
solidification
or
packaging
for
ease
of
sampling.
If
the
limits
are
exceeded
for
any
toxicity
characteristic
parameter,
the
waste
stream
is
recharacterized,
and
the
characterization
is
performed
according
to
procedures
required
in
the
WIPP­
WAP.

A
Shewhart
control
chart
(
Gilbert
1987)
is
a
control
chart
for
means
that
can
be
used
for
checking
whether
current
data
are
consistent
with
past
data
and
whether
shifts
or
trends
in
means
have
occurred.
The
control
chart
for
means
is
constructed
of
a
center
line
and
upper
and
lower
control
limits
that
are
based
on
the
mean
and
standard
deviation
of
historical
data
for
the
process.
If
a
current
sample
mean
from
the
process
lies
within
the
limits,
the
process
is
said
to
be
"
in
control",
or
consistent
with
historical
data.
If
the
current
mean
exceeds
the
limits,
the
process
has
likely
changed
from
historical
periods.

Logical
sets
of
historical
data
are
used
for
the
construction
of
limits
in
this
application.
The
sets
originate
from
initial
characterization
of
the
waste
stream
(
if
available),
from
characterization
of
a
different
lot
of
the
same
waste
stream,
or
from
a
similar
retrievably
stored
waste
stream.
At
a
minimum,
a
logical
set
includes
ten
representative
sample
values
collected
and
analyzed
from
the
newly
generated
waste
stream.
The
data
used
for
construction
of
the
limits
is
justified.
The
underlying
assumptions
for
control
charts
are
that
the
data
are
independent
and
normally
distributed
with
constant
mean
µ
and
constant
variance
 2.
The
statistical
tests
for
normality
are
conducted
and
data
transformation
to
normality
performed,
if
necessary.
Transformations
take
place
prior
to
any
calculations
that
use
the
data.

Each
limit
is
constructed
such
that
there
is
a
90
percent
confidence
that
the
true
mean
does
not
exceed
a
limit.
One­
sided
control
limits
are
used
because
once
a
waste
stream
has
been
determined
to
be
RCRAhazardous
the
limit
exceedance
of
interest
is
on
the
lower
side;
that
is
when
the
process
may
become
nonhazardous.
Likewise,
once
a
waste
stream
has
been
determined
not
to
be
RCRA­
hazardous,
the
limit
exceedance
of
interest
is
on
the
upper
side;
that
is
when
the
process
may
become
RCRA­
hazardous.
Whether
or
not
exceeding
the
limit
would
result
in
a
change
in
the
RCRA­
hazardous
nature
of
the
waste
stream
depends
on
how
close
the
observed
control
limits
are
to
RCRA
limits.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

109
Current
process
data
is
collected
and
averaged
for
comparison
to
the
control
limit
for
the
mean.
The
collection
period
and
number
of
samples
included
in
the
average
are
dependent
on
the
waste
stream
characteristics.
A
small
number
of
samples
will
reflect
more
of
the
process
variability
and
there
will
potentially
be
more
limit
exceedance.
If
two
or
three
samples
are
collected
for
the
mean
in
the
required
annual
(
or
batch)
sampling
of
a
relatively
homogeneous
waste
stream,
limit
exceedances
may
not
occur.
If
the
waste
stream
is
less
homogeneous,
it
is
necessary
to
collect
more
samples
to
meet
the
required
confidence
limit.

Periodically
it
is
necessary
to
update
the
control
limit
for
a
process.
An
update
is
performed
that
includes
all
historical
data
if
there
is
no
evidence
of
a
trend
in
the
process
or
a
shift
in
the
mean
for
the
process.
If
there
has
been
a
shift
in
the
mean,
only
more
recent
data
that
reflects
the
shift
is
used.
Control
limits
are
based
on
at
least
ten
data
points
that
are
representative
of
the
process
and
do
not
exhibit
outliers
or
a
trend
with
time.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
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31/
03
Effective:
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31/
03
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Project
Plan
(
QAPjP)

110
Table
B2­
1,
Number
of
Waste
Containers
Requiring
Visual
Examination
ANNUAL
NUMBER
OF
WASTE
CONTAINERS
PER
SUMMARY
CATEGORY
GROUP
UNDERGOING
CHARACTERIZATION
NUMBER
OF
WASTE
CONTAINERS
REQUIRING
VISUAL
EXAMINATION
BASED
ON
PERCENT
OF
WASTE
CONTAINERS
MISCERTIFIED
TO
WIPP­
WAC
BY
RADIOGRAPHY
IN
PREVIOUS
YEAR(
S)

1%
or
less
2%
3%
4%
5%
6%
7%
8%
9%
10%
11%
12%
13%
14%
or
greater
50
or
less
22a
22
22a
22
29a
29
41a
41
46a
46
50a
50
50a
50
100
15
24
24
33
33
41
48
62
69
81
87
96
100
100
200
15
26
26
35
44
52
68
83
105
126
152
176
196
200
300
15
26
26
35
44
53
70
94
116
153
202
247
287
300
400
15
26
26
36
45
62
79
103
134
178
235
316
377
400
500
16
26
26
36
45
63
80
104
143
196
268
364
465
500
1000
16
27
27
36
46
64
81
114
162
239
359
568
848
1000
1500
16
27
27
37
46
64
81
123
171
257
416
701
1176
1500
2000
16
27
27
37
46
64
90
123
172
266
441
795
1453
2000
a
Number
of
containers
for
the
higher
even­
number
percent
of
miscertified
containers
is
used
because
an
odd
percent
implies
a
noninteger
number
of
containers
are
likely
to
be
miscertified.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

111
Figure
B2­
1,
Statistical
Approach
to
Sampling
and
Analysis
of
Waste
Streams
of
Retrievably
Stored
Homogeneous
Solids
and
Soil/
Gravel
Segregate
waste
containers
into
waste
streams.

Using
acceptable
knowledge
and
headspace
gas
analytical
results,
determine
EPA
hazardous
waste
F
codes
and
contaminants
of
interest
for
determining
RCRA
toxicity
characteristic.

Obtain
preliminary
estimates
of
mean
and
variance
for
each
contaminant
of
interest
and
determine
contaminant
of
interest
with
highest
coefficient
of
variation.

Calculate
number
of
samples
and
analyses
required
for
contaminant
of
interest
with
highest
coefficient
of
variation.

Randomly
sample
and
analyze
the
required
number
of
waste
containers.

Calculate
UCL90
for
mean
concentration
of
each
contaminant
of
interest.

UCL90
for
the
mean
<
RTL?

Calculate
UCL90
for
mean
of
each
contaminant.
Classify
waste
stream
as
nonhazardous
for
this
contaminant.

RTL
=
Regulatory
Threshold
Limit
UCL90
=
Upper
90­
percent
One­
sided
Confidence
Limit
AMWTP
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responsible
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ensure
correct
revision
is
used
MP­
TRUW­
8.2,
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2
Issued:
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31/
03
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31/
03
Quality
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Project
Plan
(
QAPjP)

112
B3.
QUALITY
ASSSURANCE
OBJECTIVES
AND
DATA
VALIDATION
TECHNIQUES
FOR
WASTE
CHARACTERIZATION
SAMPLING
AND
ANALYTICAL
METHODS
B3­
1
Validation
Methods
Validation
of
all
data
(
qualitative
as
well
as
quantitative)
is
performed
so
that
data
used
for
WIPP
compliance
activities
are
of
known
and
acceptable
quality.
Validation
includes
a
quantitative
determination
of
precision,
accuracy,
completeness,
and
method
detection
limit
(
as
appropriate)
for
analytical
data
(
headspace
gas
VOCs,
total
VOCs,
SVOC,
and
metals
analysis).
Results
of
these
determinations
are
compared
with
the
QAOs
specified
in
Sections
B3­
2
through
B3­
9.
Qualitative
determination
of
comparability
and
representativeness
is
also
performed.

Information
generated
by
radiography
and
VE
is
qualitative
data
and
is
not
amenable
to
statistical
data
quality
analysis.
However,
radiography
and
VE
are
complementary
techniques
yielding
similar
data
to
determine
the
waste
matrix
code
and
waste
material
parameter
weights
of
waste
present
in
a
container.
VE
results
are
used
to
verify
the
waste
material
parameter
weights
of
waste
present
in
the
container.
VE
results
are
used
to
verify
the
waste
matrix
code
and
waste
material
parameter
weights
determined
by
radiography.
The
waste
matrix
code
is
determined
and
the
waste
material
parameter
weights
are
estimated
to
verify
the
container
is
properly
included
in
the
appropriate
waste
stream.

Data
validation
will
be
used
to
assess
the
quality
of
waste
characterization
data
collected
based
upon
project
precision,
accuracy,
completeness,
comparability,
and
representativeness
objectives
described
below:

Precision
Precision
is
a
measure
of
the
mutual
agreement
among
multiple
measurements
of
a
single
analyte,
either
by
the
same
method
or
by
different
methods.
Precision
is
either
expressed
as
the
relative
percent
difference
(
RPD)
for
duplicate
measurements
or
as
the
percent
relative
standard
deviation
(%
RSD)
for
three
or
more
replicate
measurements.
For
duplicate
measurements,
the
precision
expressed
as
the
RPD
is
calculated
as
follows:

RPD
=
×
100
(
C1
­
C2)
(
C1
+
C2)
2
where
C1
and
C2
are
the
two
values
obtained
by
analyzing
the
duplicate
samples.
C1
is
the
larger
of
the
two
observed
values.
AMWTP
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MP­
TRUW­
8.2,
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2
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03
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03
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113
For
three
or
more
replicate
measurements,
the
precision
expressed
as
the
%
RSD
is
calculated
as
follows:

%
RSD
s
y
=
×
100
where
s
is
the
standard
deviation
and
y
is
the
mean
of
the
replicate
sample
analyses.

The
standard
deviation,
s,
is
calculated
as
follows:

(
)
s
y
y
n
i
i
n
=
 

 
=
 
2
1
1
where
yi
is
the
measured
value
of
the
ith
replicate
sample
analysis
measurement,
and
n
equals
the
number
of
replicate
analyses.

Precision,
associated
with
analytical
equipment
calibration,
is
also
measured
as
the
percent
difference
(%
D)
between
multiple
measurements
of
an
equipment
calibration
standard
is
calculated
as
follows:

%
D
C
C
C
=
 
×
1
2
1
100
where
C1
is
the
initial
measurement
and
C2
is
the
second
or
other
additional
measurement.

Accuracy
Accuracy
is
the
degree
of
agreement
between
a
measured
analyte
concentration
(
or
the
average
of
replicate
measurements
of
a
single
analyte
concentration)
and
the
true
or
known
concentration.
Accuracy
is
determined
as
the
percent
recovery
(%
R).

For
situations
where
a
standard
reference
material
is
used,
the
%
R
is
calculated
as
follows:

%
R
C
C
m
t
=
×
100
where
Cm
is
the
measured
concentration
value
obtained
by
analyzing
the
sample
and
Ct
is
the
"
true"
or
certified
concentration
of
the
analyte
in
the
sample.
AMWTP
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PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
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03/
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03
Effective:
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31/
03
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(
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114
For
measurements
where
matrix
spikes
are
used,
the
%
R
is
calculated
as
follows:

%
R
S
U
C
sa
=
 
×
100
where
S
is
the
measured
concentration
in
the
spiked
aliquot,
U
is
the
measured
concentration
in
the
unspiked
aliquot,
and
Csa
is
the
actual
concentration
of
the
spike
added.

Method
Detection
Limit
(
MDL)

The
MDL
is
the
minimum
concentration
of
an
analyte
that
can
be
measured
and
reported
with
99%
confidence
that
the
analyte
concentration
is
greater
than
zero.
The
MDL
for
all
quantitative
measurements
is
defined
as
follows:

(
)
MDL
t
s
n
=
×
 
 
=
1
1
0
99
,
.
 
where
t(
n­
1,
1­
a
=
.99)
is
the
t­
distribution
value
appropriate
to
a
99%
confidence
level
and
a
standard
deviation
estimate
with
n­
1
degrees
of
freedom,
n
is
the
number
of
observations,
and
s
is
the
standard
deviation
of
replicate
measurements.

Currently,
the
AMWTP
has
no
plans
to
use
FTIR,
however,
should
FTIR
be
used
for
headspace­
gas
analysis
the
MDL
is
defined
as
follows:

MDL
=
3s
where
s
is
the
standard
deviation.
Initially,
a
minimum
of
seven
samples
spiked
at
a
level
of
three
to
five
times
the
estimated
MDL
and
analyzed
on
non­
consecutive
days
must
be
used
to
establish
the
MDLs.
MDLs
should
be
updated
using
the
results
of
the
laboratory
control
sample
or
on­
line
control
samples.

Completeness
Completeness
is
a
measure
of
the
amount
of
valid
data
obtained
from
the
overall
measurement
system
compared
to
the
amount
of
data
collected
and
submitted
for
analysis.
Completeness
must
be
expressed
as
the
number
of
samples
analyzed
with
valid
results
as
a
percent
of
the
total
number
of
samples
submitted
for
analysis.
Completeness,
expressed
as
the
percent
complete
(%
C),
is
calculated
as
follows:

%
C
V
n
=
×
100
where
V
is
the
number
of
valid
sampling
or
analytical
results
obtained
and
n
is
the
number
of
samples
submitted
for
analysis.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

115
Valid
sampling
and
analysis
results
are
those
meeting
one
of
the
following
criteria:

 
No
NCRs
are
associated
with
the
result
 
Any
NCRs
associated
with
the
result
do
not
result
in
rejection
of
the
sampling
or
analytical
work.

Comparability
Comparability
is
the
degree
to
which
one
data
set
can
be
compared
to
another.
Comparability
of
data
generated
at
different
sites
is
assured
through
the
use
of
standardized,
approved
testing,
sampling,
preservation,
and
analytical
techniques
and
by
meeting
the
QAOs
specified
in
Sections
B3­
2
through
B3­
9.

The
comparability
of
waste
characterization
data
shall
be
ensured
through
the
use
of
data
usability
criteria
(
based
on
guidance
provided
by
CBFO),
which
address,
as
appropriate,
the
following:

 
Definition
or
reference
of
criteria
used
to
define
and
assign
data
qualifier
flags
based
on
QAO
results
 
Criteria
for
assessing
the
usability
of
data
impacted
by
matrix
interferences
 
Criteria
for
assessing
the
usability
of
data
based
upon
positive
and
negative
bias
as
indicated
by
quality
control
data,
of
data
qualifiers,
and
qualifier
flags
 
Criteria
for
assessing
the
usability
of
data
due
to:

1.
Severe
matrix
effects
2.
Misidentification
of
compounds
3.
Gross
exceedance
of
holding
times
4.
Failure
to
meet
calibration
or
tune
criteria.

 
Criteria
for
assessing
the
usability
of
data
that
does
not
meet
minimum
detection
limit
requirements.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

116
Representativeness
Representativeness
is
the
degree
to
which
sample
data
represent
a
characteristic
of
a
population,
parameter
variations
at
a
sampling
point,
or
an
environmental
condition.
Representativeness
is
a
qualitative
parameter
that
concerns
the
proper
design
of
the
sampling
program.
The
representativeness
of
waste
containers
from
waste
streams
subjected
to
visual
examination
and
homogeneous
solids
and
soil/
gravel
sampling
and
analysis
is
validated
through
documentation,
and
this
confirms
a
true
random
sample
with
an
adequate
population
was
collected.
Since
representativeness
is
a
quality
characteristic
that
expresses
the
degree
to
which
a
sample
or
group
of
samples
represents
the
population
being
studied,
the
random
selection
of
waste
containers
ensures
representativeness
at
a
Program
level.
The
SPM
documents
that
the
selected
waste
containers
from
within
a
waste
stream
or
summary
category,
as
applicable,
are
randomly
selected.
Sampling
personnel
verify
that
proper
procedures
are
followed
to
ensure
that
samples
are
representative
of
the
waste
contained
in
a
particular
waste
container
or
a
waste
stream.

Nonconformance
to
Data
Quality
Objectives
(
DQOs)

WIPP
will
be
notified
within
five
(
5)
calendar
days
of
identification
that
a
non­
administrative
nonconformance
has
been
identified
at
the
SPM
signature
release
level
[
i.
e.,
failure
to
meet
data
quality
objective
(
DQO)].
and
will
receive
a
nonconformance
report
within
thirty
(
30)
calendar
days
of
identification
of
the
incident.

Procedures
contain
specific
QC
requirements
to
ensure
the
data
generated
meet
the
DQOs.
Reported
data
that
do
not
meet
DQOs
are
treated
as
a
nonconformance
and
reported
to
CBFO
as
described
in
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions,
and
MP­
Q&
SI­
5.3,
Corrective
Action
and
MP­
TRUW­
8.28,
Project
Level
Administrative
Controls
for
Analytical
Laboratory
Department.
The
AMWTP
will
implement
corrective
actions
that
remedy
the
nonconformance
prior
to
shipment
to
WIPP.

Identification
of
Tentatively
Identified
Compounds
(
TICs)

In
accordance
with
EPA
SW­
846
convention,
identification
of
compounds
detected
by
GC/
MS
methodologies
that
are
not
on
the
list
of
target
analytes
shall
be
reported
as
TICs.
Both
composited
and
individual
container
headspace
gas,
volatile
analysis
(
TLCP/
Totals),
and
semi­
volatile
(
TLCP/
Totals)
analysis
are
subject
to
TIC
reporting.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

117
AMWTP
and
ALD
procedures
for
identifying
and
reporting
TICs
when
using
GC/
MS
methods
are
based
on
guidance
provided
in
EPA
SW­
846
Method
8260B
and
SW­
846
Method
8270C.
TIC
evaluation
for
headspace
gas
is
addressed
in
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations.
TIC
evaluation
for
total
VOC
and
SVOC
analysis
is
addressed
in
ACMM­
9260,
Volatile
Organic
Compounds
by
Gas
Chromatography
Mass
Spectrometry
(
GC/
MS)
and
ACMM­
9270,
Semivolatile
Organic
Compounds
by
Gas
Chromatography/
Mass
Spectrometry.
These
procedures
assign
tentative
identifications
in
accordance
with
the
following
SW­
846
criteria:

 
Relative
intensities
of
major
ions
in
the
reference
spectrum
(
ions
greater
than
10%
of
the
most
abundant
ion)
should
be
present
in
the
sample
spectrum.

 
The
relative
intensities
of
the
major
ions
should
agree
within
+
20%.

 
Molecular
ions
present
in
the
reference
spectrum
should
be
present
in
the
sample
spectrum.

 
Ions
present
in
the
sample
spectrum
but
not
in
the
reference
spectrum
should
be
reviewed
for
possible
background
contamination
or
presence
of
coeluting
compounds.

 
Ions
present
in
the
reference
spectrum
but
not
in
the
sample
spectrum
should
be
reviewed
for
possible
subtraction
from
the
sample
spectrum
because
of
background
contamination
or
coeluting
peaks.

 
The
reference
spectra
used
for
identifying
TICs
shall
include,
at
minimum,
all
of
the
available
spectra
for
compounds
that
appear
in
the
20.4.1.200
NMAC
(
incorporating
40
CFR
Part
261)
Appendix
VIII
list.
The
reference
spectra
may
be
limited
to
VOCs
when
analyzing
headspace
gas
samples.

TICs
shall
be
reported
as
part
of
the
analytical
batch
data
reports
for
GC/
MS
Methods
in
accordance
with
the
following
minimum
criteria:

 
A
TIC
in
an
individual
container
headspace
gas
or
solids
sample
shall
be
reported
in
the
analytical
batch
data
report
if
the
TIC
meets
the
SW­
846
identification
criteria
above
and
is
present
with
a
minimum
of
10%
of
the
area
of
the
nearest
internal
standard.

 
A
TIC
in
a
composited
headspace
gas
sample
that
contain
2
to
5
individual
container
samples
shall
be
reported
in
the
analytical
batch
data
report
if
the
TIC
meets
the
SW­
846
identification
criteria
listed
above
and
is
present
with
a
minimum
of
2%
of
the
area
of
the
nearest
internal
standard.

 
A
TIC
in
a
composited
headspace
gas
sample
that
contains
6
to10
individual
container
samples
shall
be
reported
in
the
analytical
batch
data
report
if
the
TIC
meets
the
SW­
846
identification
criteria
listed
above
and
is
present
with
a
minimum
of
1%
of
the
area
of
the
nearest
internal
standard.

 
A
TIC
in
a
composited
headspace
gas
sample
that
contains
11
to
20
individual
container
samples
shall
be
reported
in
the
analytical
batch
data
report
if
the
TIC
meets
the
SW­
846
identification
criteria
listed
above
and
is
present
with
a
minimum
of
0.5%
of
the
area
of
the
nearest
internal
standard.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

118
TICs
that
meet
the
SW­
846
identification
criteria,
are
reported
in
25%
of
all
waste
containers
sampled
from
a
given
waste
stream
and
that
appear
in
the
20.4.1.200
NMAC
(
incorporating
40
CFR
Part
261)
Appendix
VIII
list
will
be
compared
to
AK
to
determine
if
the
TIC
is
a
listed
waste
in
the
waste
stream.
TICs
identified
through
headspace
gas
analyses
that
meet
the
Appendix
VIII
list
criteria
and
the
25%
reporting
criteria
for
a
waste
stream
will
be
added
to
the
headspace
gas
waste
stream
target
list
regardless
of
the
hazardous
waste
listing
associated
with
the
waste
stream.
TICs
reported
from
the
Totals
VOC
or
SVOC
analyses
may
be
excluded
from
the
target
analyte
list
for
a
waste
stream
if
the
TIC
is
a
constituent
in
an
F­
listed
waste
whose
presence
is
attributable
to
waste
packaging
materials,
or
radiolytic
degradation
from
AK
documentation.
If
a
listed
waste
constituent
TIC
cannot
be
attributed
to
waste
packaging
materials,
radiolysis,
or
other
origins,
the
constituent
will
be
added
to
the
target
analyte
list
and
new
hazardous
waste
codes
will
be
assigned,
if
appropriate.
TICs
subject
to
inclusion
on
the
target
analyte
list
that
are
toxicity
characteristic
parameters
shall
be
added
to
the
target
analyte
list
regardless
of
origin
because
the
hazardous
waste
designation
for
these
codes
is
not
based
on
source.
However,
for
toxicity
characteristic
and
nontoxic
F003
constituents,
the
site
may
take
concentration
into
account
when
assessing
whether
to
add
a
hazardous
waste
code.
If
a
target
analyte
list
for
a
waste
stream
is
expanded
due
to
the
presence
of
TICs,
all
samples
collected
from
that
waste
stream
will
be
analyzed
for
constituents
on
the
expanded
list.
The
comparison
to
AK
and
the
determination
of
whether
or
not
to
add
the
TIC
to
the
target
analyte
list
will
be
done
in
accordance
with
MP­
TRUW­
8.11,
Data
Reconciliation
and
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.

B3­
2
Headspace
Gas
Sampling
(
HSGS)

Quality
Assurance
Objectives
HSGS
occurs
from
the
headspace
within
each
drum
of
TRU
mixed
waste
or
randomly
selected
containers
from
waste
streams
that
meet
the
conditions
for
reduced
gas
sampling
(
as
defined
in
Section
B­
3a(
1))
destined
for
WIPP.
Headspace
gas
samples
are
collected
in
accordance
with
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operations.

Precision
and
accuracy
of
drum
HSGS
operations
are
assessed
by
analyzing
QC
samples
that
consist
of
field
and
equipment
blanks,
field
duplicates,
and
field
reference
standards.
If
the
QAOs
in
this
section
are
not
met,
then
an
NCR
must
be
prepared,
submitted,
and
resolved
(
see
Section
B3­
13).
Table
B1­
2
summarizes
the
field
QC
sample
collection
requirements
and
Table
B1­
3
summarizes
the
QC
sample
acceptance
criteria.

Precision
The
precision
of
HSGS
and
analysis
are
assessed
by
collection
of
sequential
on­
line
duplicates
for
an
on­
line
integrated
sampling
analysis
system
or
simultaneous
collection,
should
AMWTF
choose
to
use
direct
canister
sampling.
The
RPD
is
calculated
for
each
on­
line
sample/
duplicate
pair
and
compared
with
the
criterion
of
less
than
or
equal
to
25%.
If
the
RPD
exceeds
the
criterion
and
the
analyte
concentration
exceeds
its
PRQL,
an
NCR
must
be
prepared,
submitted,
and
resolved
(
see
Section
B3­
13).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

119
Accuracy
A
field
reference
standard
is
collected
using
headspace­
gas
sampling
equipment
to
assess
the
accuracy
of
the
headspace­
gas
sampling
operation
at
a
frequency
of
one
field
reference
for
every
20
drums
sampled
or
per
sampling
batch.
The
%
R
for
each
analyte
is
calculated
and
compared
with
the
acceptance
criteria
of
70­
130%,
inclusive.
If
a
%
R
is
outside
the
criteria,
an
NCR
must
be
prepared,
submitted,
and
resolved
(
see
Section
B3­
13).

Field
blanks
are
collected
using
the
HSGS
equipment
at
a
frequency
of
1
field
blank
every
20
drums
sampled
or
sampling
batch
sampled
to
assess
the
accuracy
of
the
HSGS
methods.
Equipment
blanks
must
also
be
collected
at
a
frequency
of
one
equipment
blank
for
each
equipment
cleaning
batch
to
assess
possible
contamination
in
the
equipment
cleaning
method.
For
field
blanks
and
on­
line
blanks,
the
concentration
of
each
target
analyte
must
be
less
than
or
equal
to
three
times
the
program­
required
MDL.
If
the
concentration
of
any
target
compound
listed
in
Table
B3­
2
is
outside
the
criteria,
an
NCR
must
be
prepared,
submitted,
and
resolved
(
see
Section
B3­
13).

Completeness
Sampling
completeness
is
expressed
as
the
number
of
valid
samples
collected
as
a
percent
of
the
total
number
of
samples
collected
for
each
waste
stream.
The
completeness
can
also
be
expressed
as
the
number
of
valid
samples
collected
as
a
percent
of
the
total
number
of
drums
for
each
waste
stream.
A
valid
sample
is
defined
as
a
sample
collected
per
approved
sampling
methods
from
a
drum
that
was
properly
prepared
for
sampling
(
the
poly
liner
was
vented
to
the
drum
headspace).
The
SQAO
verifies
a
minimum
90%
completeness
is
achieved
on
each
data
package.
The
amount
and
type
of
data
that
may
be
lost
during
the
HSGS
operation
cannot
be
predicted
in
advance.
The
AMWTP
SQAO
or
designee
evaluates
the
importance
of
any
lost
or
contaminated
headspace
gas
samples
and
takes
corrective
action,
as
appropriate.

Comparability
Consistent
use
and
application
of
uniform
procedures
and
equipment,
as
specified
in
Section
B1
and
application
of
data
usability
criteria,
ensure
HSGS
operations
are
comparable
when
sampling
headspace
at
the
different
sampling
facilities.
The
AMWTP
takes
corrective
actions
if
uniform
procedures,
equipment,
or
operations
are
not
followed
without
approved
and
justified
deviations.
In
addition,
the
AMWTP
on­
line
integrated
sampling
system
and
laboratories
analyzing
samples
successfully
participate
in
the
PDP.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
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Assurance
Project
Plan
(
QAPjP)

120
Representativeness
Specific
HSGS
steps
to
ensure
samples
are
representative
include:

 
Selection
of
the
correct
DAC
Scenario
and
waste
packaging
configuration
and
meeting
DAC
 
equilibrium
times.
Sample
canister
cleaning
and
leak­
check
after
assembly
 
Sampling
equipment
cleaning
or
disposal
after
use
 
Sampling
equipment
leak­
check
after
sample
collection
 
Use
of
sample
canisters
with
passivated
internal
surfaces
 
Use
of
low­
internal­
volume
sampling
equipment
 
Collection
of
samples
with
a
low­
sample
volume
to
available
headspace
volume
ratio
(
less
than
10%
of
the
headspace
when
the
headspace
can
be
determined)

 
Careful
and
documented
pressure
regulation
of
sampling
activities
specified
in
Section
B1­
1
 
Performance
audits
 
Collection
of
equipment
blanks,
field
reference
standard,
field
blanks,
and
field
duplicates
at
the
specified
frequencies
 
Manifold
pressure
sensors
and
temperature
sensors
calibrated
before
initial
use
and
annually
using
NIST,
or
equivalent
standards.

 
OVA
calibrated
daily,
prior
to
use,
or
as
necessary
according
manufactures
specifications.

Failure
to
perform
the
checks
at
the
prescribed
frequencies
results
in
corrective
actions.

B3­
3
Sampling
of
Homogeneous
Solids
and
Soils/
Gravel
Quality
Assurance
Objectives
(
QAOs)

This
section
presents
QAOs
to
ensure
sampling
is
conducted
in
a
representative
manner
on
a
waste
stream
basis
for
containers
containing
homogeneous
solids
or
soil/
gravel.
Samples
are
randomly
collected
in
both
the
horizontal
and
vertical
planes
of
each
container's
waste
as
described
in
INST­
OI­
16,
Drum
Coring
Operations.
For
waste
containers
that
contain
homogeneous
solids
or
soils/
gravel
in
smaller
containers
(
for
example,
1­
gal
poly
bottles)
within
a
waste
container,
one
randomly
chosen
smaller
container
must
be
sampled
from
each
drum.
AMWTP
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PROCEDURE
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responsible
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03
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03
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121
Precision
Sampling
precision
is
determined
by
collecting
and
sampling
field
duplicates
(
e.
g.,
co­
located
cores
or
colocated
samples
as
described
in
Section
B1­
2b(
1)),
once
per
sampling
batch
or
once
per
week
during
the
sampling
operations,
whichever
is
more
frequent.
A
sampling
batch
is
a
suite
of
homogeneous
solids
and
soil/
gravel
samples
collected
consecutively
using
the
same
sampling
equipment
within
a
specific
time
period.
A
sampling
batch
can
be
up
to
20
samples
(
excluding
field
QA
samples),
collected
within
14
calendar
days
of
the
first
sample
in
the
batch.
The
RPD
between
collocated
core
samples
is
calculated
and
reported
by
the
SQAO
or
designee
per
MP­
TRUW­
8.17,
Co­
located
Core
Sampling
Control
Charts.

The
recommended
method
for
establishing
acceptance
criteria
for
co­
located
cores
and
co­
located
samples
is
the
F­
Test
method
because
the
F­
Test:
1)
does
not
require
potentially
arbitrary
groupings
into
batches,
2)
is
based
on
exact
distributions,
and
3)
is
more
likely
to
detect
a
change
in
the
process.
When
a
sufficient
number
of
samples
are
collected
(
25
to
30
pairs
of
collocated
cores
or
samples),
control
charts
of
the
RPD
will
be
developed
for
each
constituent
and
for
each
waste
matrix
or
waste
type
(
e.
g.
pyrochemical
salts
or
organic
sludges).
The
limits
for
the
control
chart
will
be
three
standard
deviations
above
or
below
the
average
RPD.
Once
constructed,
RPDs
for
additional
co­
located
pairs
will
be
compared
with
the
control
chart
to
determine
whether
or
not
the
co­
located
cores
are
acceptable.
Periodically,
the
control
charts
will
be
updated
using
all
available
data.

The
statistical
test
will
involve
calculating
the
variance
for
collocated
cores
and
samples
by
pooling
the
variances
computed
for
each
pair
of
duplicate
results.
The
variance
for
the
waste
stream
will
be
computed
excluding
any
data
from
drums
with
co­
located
cores,
because
the
test
requires
the
variance
estimate
to
be
independent.
All
data
must
be
transformed
to
normality
prior
to
computing
variances
and
performing
the
test.
The
test
hypothesis
is
evaluated
using
the
F
distribution
and
the
method
for
testing
the
difference
in
variances.

Accuracy
Sampling
accuracy
through
the
use
of
standard
reference
materials
is
not
measured.
Because
waste
containers
containing
homogeneous
solids
and
soil/
gravel
with
known
quantities
of
analytes
are
not
available,
sampling
accuracy
cannot
be
determined.
However,
sampling
methods
and
requirements
described
are
designed
to
minimize
sample
degradation
and
hence
maximize
sampling
accuracy.
AMWTP
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PROCEDURE
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responsible
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correct
revision
is
used
MP­
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8.2,
Rev
2
Issued:
03/
31/
03
Effective:
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31/
03
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(
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122
Sampling
accuracy
as
a
function
of
sampling
cross­
contamination
will
be
measured.
Equipment
blanks
will
be
collected
at
a
frequency
of
once
per
equipment
cleaning
batch.
Corrective
actions
must
be
must
be
taken
if
the
blank
exceeds
three
times
the
MDLs
(
PRDLs
for
metals)
listed
for
any
of
the
compounds
or
analytes
listed
in
Tables
B3­
4,
B3­
6,
and
B3­
8.
Equipment
blanks
will
be
collected
from
the
following
equipment
types:

 
Fully
assembled
coring
tools
 
Liners
cleaned
separately
from
coring
tools
 
Miscellaneous
sampling
equipment
that
is
reused
(
bowls,
spoons,
chisels)

Completeness
Sampling
completeness
is
expressed
as
the
number
of
valid
samples
collected
as
a
percent
of
the
total
samples
collected
for
each
waste
stream.
A
valid
sample
is
any
sample
collected
from
a
randomly
selected
drum
using
randomly
selected
horizontal
and
vertical
planes
per
INST­
OI­
16,
Drum
Coring
Operations.
The
AMWTP
must
achieve
a
minimum
90%
completeness.

Comparability
Consistent
use
and
application
of
uniform
procedures,
sampling
equipment,
and
measurement
units
must
ensure
that
sampling
operations
are
comparable.
Consistent
application
of
data
usability
criteria
will
also
ensure
comparability.
In
addition,
laboratories
analyzing
samples
successfully
participate
in
the
PDP.

Representativeness
Specific
steps
to
ensure
representativeness
of
samples
include
the
following
for
both
waste
containers
and
smaller
containers:

 
Coring
tools
and
sampling
equipment
used
are
clean
before
sampling
 
The
entire
depth
of
waste
minus
a
defined
approved
safety
factor
is
cored,
and
the
core
collected
must
have
a
length
greater
than
or
equal
to
50%
of
the
waste
depth.
This
is
called
core
recovery
and
is
calculated
as
follows:

(
)
Core
y
x
recovery
%
=
×
100
where
x
=
waste
depth
in
the
container
y
=
the
length
of
the
core
collected
from
the
waste
AMWTP
MANAGEMENT
PROCEDURE
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03
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123
 
Coring
operations
and
tool
selection
should
be
designed
to
minimize
alteration
of
the
in­
place
waste
characteristics.
Minimal
waste
disturbance
must
be
verified
by
visually
examining
the
corre
and
describing
the
observation
(
e.
g.,
undisturbed,
cracked,
or
pulverized)
in
the
field
logbook.

If
core
recovery
is
less
than
50%
of
the
depth
of
the
waste,
a
second
coring
location
is
randomly
selected
and
a
core
collected.
The
core
with
the
best
core
recovery
is
used
for
sample
collection.

One
randomly
selected
container
within
a
drum
will
be
chosen
if
the
drum
contains
individual
containers.

B3­
4
Radiography
Quality
Assurance
Objectives
The
QAOs
for
radiography
are
detailed
in
this
section.
It
should
be
noted
that
radiography
does
not
have
a
specific
MDL
because
it
is
primarily
a
qualitative
determination.
The
objective
of
radiography
is
to
verify
the
Waste
Matrix
Code,
identify
prohibited
items
for
each
waste
container,
and
estimate
each
waste
material
parameter
weight
(
Table
B3­
1).
All
activities
required
to
achieve
these
objectives
are
described
or
incorporated
by
reference
in
this
QAPjP
and
INST­
OI­
12,
Real
Time
Radiography
System
Operations.

Data
to
meet
these
objectives
are
obtained
from
an
audio/
videotaped
(
or
equivalent
media)
scan
provided
by
trained
and
qualified
radiography
operators.
Results
are
also
recorded
on
an
radiography
data
form.
The
precision,
accuracy,
completeness,
and
comparability
objectives
for
radiography
data
are
described
in
the
following
sections.

In
the
event
QAOs
are
not
met,
an
NCR
is
issued
per
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions,
and
corrective
action
is
taken
per
MP­
Q&
SI­
5.3,
Corrective
Action.

Precision
The
qualitative
determinations
made
during
radiography
do
not
lend
themselves
to
the
statistical
evaluation
of
precision
because
of
the
nature
of
the
inspection.
As
a
measure
of
precision,
the
SQAO
or
designee
calculates
and
reports
the
RPD
between
the
estimated
waste
material
parameter
weights
(
Table
B3­
1)
as
determined
by
radiography
and
these
same
parameters
as
determined
by
VE.

Additionally,
the
precision
of
radiography
is
verified
prior
to
use
by
tuning
precisely
enough
to
demonstrate
compliance
with
QAOs
through
viewing
an
image
test
pattern.
AMWTP
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revision
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used
MP­
TRUW­
8.2,
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03
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03
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124
Accuracy
The
programmatic
accuracy
at
which
the
waste
matrix
code
and
waste
material
parameter
weights
can
be
determined,
is
documented
through
the
VE
of
a
randomly­
selected
statistical
portion
of
waste
containers
(
See
Section
B2­
1).
The
SQAO
or
designee
calculates
and
reports
the
miscertification
rate
of
waste
containers
that
require
assignment
to
a
different
waste
matrix
code
or
are
found
to
contain
prohibited
items
after
VE
as
a
measure
of
radiography
accuracy.
The
miscertification
rate
is
used
to
determine
the
number
of
drums
subject
to
confirmatory
VE.

Completeness
An
audio/
videotape
(
or
equivalent
media)
of
the
radiography
examination
and
a
validated
radiography
data
form
is
obtained
for
100%
of
the
retrievably
stored
waste
containers
subject
to
radiography.
All
audio/
videotape
(
or
equivalent
media)
and
radiography
data
forms
are
subject
to
validation
as
indicated
in
Sections
B3­
10.

Comparability
Using
standardized
radiography
procedures
and
operator
qualification
enhances
the
comparability
of
radiography
data.
Operator
training
requirements
are
outlined
in
Section
B1­
3b.
radiography
operators
comply
with
the
training
and
qualification
requirements
specified
in
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.

B3­
5
Gas
Volatile
Organic
Compounds
Analysis
Quality
Assurance
Objectives
The
specified
QAOs
in
Table
B3­
2
represent
the
required
quality
of
data
necessary
to
draw
valid
conclusions
regarding
program
objectives.
WIPP­
WAP­
related
limits,
such
as
the
program
required
quantitation
limits
(
PRQL)
associated
with
VOC
analysis,
are
specified
to
ensure
that
the
analytical
data
collected
satisfy
the
requirements
of
the
data
users.
A
summary
of
required
QC
samples
and
the
associated
acceptance
criteria
are
included
in
Table
B3­
3.
Key
data
quality
indicators
for
laboratory
measurements
are
defined
below.

Precision
Precision
is
assessed
by
analyzing
laboratory
duplicates
and
replicate
analyses
of
laboratory
control
samples,
and
PDP
blind­
audit
samples.
The
results
of
these
QC
samples
are
compared
with
the
acceptance
criteria
in
Tables
B3­
2.
These
QC
measurements
are
used
to
demonstrate
acceptable
method
performance
and
to
trigger
corrective
action
when
control
limits
are
exceeded.
AMWTP
MANAGEMENT
PROCEDURE
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responsible
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ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
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03/
31/
03
Effective:
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31/
03
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Project
Plan
(
QAPjP)

125
Precision
is
initially
assessed
using
analytical
methods
described
in
INST­
TRUW­
8.2.1,
HSG
Calibration,
by
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
%
RSD
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
3.
The
%
RSD
must
comply
with
these
criteria
before
the
procedure
can
be
used
to
analyze
WIPP
samples.
Continuing
method
precision
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
RSD
must
be
within
the
Table
B3­
3
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
performed.
Further
analyses
cannot
be
performed
until
acceptable
method
precision
is
demonstrated.

An
on­
line
duplicate
is
analyzed
with
every
on­
line
batch.
Calculating
the
RPD
between
the
sample
and
the
duplicate
results
assesses
the
precision
within
an
on­
line
batch.
For
target
compounds
with
concentrations
exceeding
their
PRQL,
the
RPD
must
comply
with
the
criteria
in
Table
B3­
3.
If
the
RPD
is
not
within
the
criteria,
an
NCR
is
prepared
and
corrective
action
taken.

The
AMWTP
also
analyzes
PDP
blind­
audit
samples.
If
notified
by
CBFO
that
the
precision
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken.

Accuracy
Accuracy
as
%
R
is
assessed
for
the
analytical
methods
by
analyzing
PDP
blind­
audit
samples
and
laboratory
control
samples.
The
results
from
these
measurements
are
compared
with
the
acceptance
criteria
in
Table
B3­
2.
These
QC
measurements
are
used
to
demonstrate
acceptable
method
performance
and
trigger
corrective
action
when
control
limits
are
exceeded.

Accuracy
is
initially
assessed
using
INST­
TRUW­
8.2.1,
HSG
Calibration,
by
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
average
percent
recovery
(%
R)
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
2.
The
%
R
must
comply
with
these
criteria
before
the
method
can
be
used
to
analyze
WIPP
samples.
Continuing
method
accuracy
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
R
must
meet
Table
B3­
3
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
initiated.
Further
analyses
cannot
be
performed
until
acceptable
accuracy
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.

At
least
one
on­
line
control
sample
(
OLCS)
per
analytical
batch
is
analyzed
to
assess
method
accuracy
within
the
batch.
The
%
R
of
the
OLCS
must
meet
the
acceptance
criteria
in
Table
B3­
3.
Whenever
possible,
samples
associated
with
a
failed
OLCS
are
reanalyzed
after
corrective
action
is
taken.
If
a
noncompliant
OLCS
is
associated
with
reported
sample
data,
an
NCR
is
prepared.

The
AMWTP
also
analyzes
PDP
blind­
audit
samples.
If
notified
by
CBFO
that
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken.

Calibration
GC/
MS
tunes,
initial
calibrations,
and
continuing
calibrations
are
performed
and
evaluated
using
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations,
and
criteria
specified
in
Table
B3­
3.
These
criteria
will
be
used
to
demonstrate
acceptable
calibration
and
trigger
corrective
action
when
control
limits
are
exceeded.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

126
Method
Detection
Limits
(
MDLs)

MDLs
are
expressed
in
units
of
nanograms
(
ng)
for
VOCs
and
must
be
less
than
or
equal
to
those
listed
in
Table
B3­
2.
MDLs
are
determined
as
described
in
INST­
TRUW­
8.2.1,
HSG
Calibration.

Program
Required
Quantitation
Limit
The
AMWTP
demonstrates
the
capability
to
quantitate
at
or
below
the
PRQL
by
setting
the
analyte
concentrations
of
at
least
one
calibration
standard
below
the
PRQLs
in
Table
B3­
2.
Standard
preparation
requirements
are
provided
in
INST­
TRUW­
8.2.1,
HSG
Calibration.
Analysis
is
performed
in
accordance
with
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operations.

Completeness
Laboratory
completeness
shall
be
expressed
as
the
number
of
samples
analyzed
with
valid
results
as
a
percent
of
the
total
number
of
samples
submitted
for
analysis.
A
composited
sample
is
treated
as
one
sample
for
the
purposes
of
completeness
because
only
one
sample
is
run
through
the
analytical
instrument.
Valid
results
are
defined
as
results
that
meet
the
data
usability
criteria
based
on
application
of
the
QC
Criteria
specified
in
Tables
B3­
2
and
B3­
3;
and
meet
the
detection
limit,
calibration,
representativeness,
and
comparability
criteria
within
this
section.

Comparability
Comparability
of
analytical
data
is
ensured
by
consistent
use
of
uniform
procedures
based
on
standardized
methods,
use
of
standards
and
QC
samples
with
documented
traceability
to
recognized
national
standards
(
for
example,
NIST),
and
successful
participation
in
the
Gas
PDP.

Representativeness
Representativeness
is
achieved
by
collection
of
sufficient
numbers
of
samples
using
clean
sampling
equipment
that
does
not
introduce
sample
bias.
Samples
must
be
collected
as
specified
in
B1.

B3­
6
Total
Volatile
Organic
Compound
Analysis
Total
VOC
analysis
is
performed
at
the
Analytical
Laboratories
Department
(
ALD).

Quality
Assurance
Objectives
The
specified
QAOs
in
Table
B3­
4
represent
the
required
quality
of
data
necessary
to
draw
valid
conclusions.
A
summary
of
required
QC
samples
and
the
associated
acceptance
criteria
is
included
in
Table
B3­
5.
Acceptable
method
performance
is
demonstrated
using
the
matrix­
independent
QC
samples
in
Table
B3­
5.
Corrective
actions
are
triggered
when
these
control
limits
are
exceeded.
Method
performance
in
specific
sample
matrices
is
evaluated
using
the
matrix­
dependent
QC
samples
in
Table
B3­
5;
data
are
qualified
if
control
limits
are
exceeded
but
nonconformance
reporting
is
not
required.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

127
Precision
Precision
is
assessed
through
the
analysis
of
laboratory
duplicates
or
matrix
spike
duplicates,
replicate
analyses
of
laboratory
control
samples,
and
PDP
blind­
audit
samples.
The
results
of
these
QC
samples
are
compared
with
the
acceptance
criteria
in
Table
B3­
4.
These
QC
measurements
will
be
used
to
demonstrate
acceptable
method
performance
and
to
trigger
corrective
action
when
control
limits
are
exceeded.

Precision
is
initially
assessed
using
analytical
methods
ACMM­
9260,
Volatile
Organic
Compounds
by
Gas
Chromatography
Mass
Spectrometry
(
GC/
MS),
and
ACMM­
9441,
Determination
of
Nonhalogenated
Volatile
Organics
by
Gas
Chromatography,
by
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
%
RSD
is
calculated
for
the
replicate
analyses
and
compared
to
the
acceptance
criteria
in
Table
B3­
5.
The
%
RSD
must
comply
with
these
criteria
before
the
procedure
can
be
used
to
analyze
WIPP
samples.
Continuing
method
precision
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
demonstration
samples.
The
%
RSD
must
be
within
the
Table
B3­
5
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
taken.
Further
analyses
cannot
be
performed
until
acceptable
precision
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.

A
matrix
spike
and
matrix
spike
duplicate
(
MSD)
pair
is
analyzed
with
every
analytical
batch.
As
allowed
by
Table
B3­
5,
the
MSD
is
used
in
lieu
of
a
laboratory
duplicate.
The
precision
within
an
analytical
batch
is
assessed
by
calculating
the
RPD
between
the
matrix
spike
and
MSD
results.
The
RPD
must
comply
with
the
acceptance
criteria
in
Table
B3­
5.
If
the
RPD
is
not
within
the
criteria,
corrective
action
is
taken.
If
the
poor
precision
is
traced
to
the
sample
matrix,
sample
data
are
flagged
with
a
"
Z",
per
Section
B3­
12.
An
NCR
is
not
required
when
the
problem
is
traced
to
the
matrix.

The
ALD
also
analyzes
PDP
blind­
audit
samples.
If
notified
that
the
precision
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken
per
the
PDP
Plan
for
the
RCRA
Constituent
Analysis
of
Solidified
Wastes
(
Solid
PDP
Plan)
(
DOE/
CAO­
95­
1077).

Accuracy
Accuracy
as
%
R
is
assessed
for
the
analytical
methods
by
analyzing
laboratory
control
samples,
matrix
spikes,
surrogate
compounds,
and
PDP
blind­
audit
samples.
The
results
from
these
measurements
for
laboratory
control
samples
and
matrix
spike
samples
are
compared
with
the
%
R
criteria
in
Table
B3­
4.
Surrogates
and
internal
standards
are
evaluated
as
specified
in
SW846
or
Table
B3­
5.
The
QC
measurements
independent
of
matrix
will
be
used
to
demonstrate
acceptable
method
performance.
Corrective
actions
are
triggered
when
control
limits
are
exceeded.

Accuracy
is
initially
assessed
using
analytical
methods
ACMMs­
9260
and
­
9441
by
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
average
%
R
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
5.
The
%
R
must
comply
with
the
criteria
before
the
procedure
can
be
used
to
analyze
WIPP
samples.
Continuing
method
accuracy
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
R
must
be
within
the
Table
B3­
5
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
taken.
Further
analyses
cannot
be
performed
until
acceptable
accuracy
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

128
At
least
one
LCS
is
analyzed
with
each
analytical
batch.
Method
accuracy
within
the
analytical
batch
is
assessed
by
calculating
the
%
R
for
the
LCS
compounds.
The
%
Rs
must
comply
with
the
acceptance
criteria
in
Table
B3­
5.
If
the
%
R
is
not
within
the
acceptance
criteria
and
the
14­
day
preparation­
to­
extraction
holding
time
has
not
been
exceeded,
the
associated
samples
may
be
reprepared
and
reanalyzed.
If
a
noncompliant
LCS
is
associated
with
reported
sample
data,
an
NCR
is
initiated.

Accuracy
for
a
specific
sample
matrix
is
assessed
by
analysis
of
a
matrix
spike/
MSD
sample
pair
in
every
analytical
batch
and
calculation
of
the
%
R
for
the
MS
and
the
MSD.
The
%
Rs
must
comply
with
the
acceptance
criteria
in
Table
B3­
5.
If
MS/
MSD
matrix,
sample
data
are
flagged
with
a
"
Z"
qualifier
per
Table
B3­
5.
An
NCR
is
not
required
when
the
problem
is
traced
to
the
matrix.

A
minimum
of
one
laboratory
blank
is
analyzed
per
analytical
batch
to
demonstrate
acceptable
levels
of
laboratory
contamination.
Laboratory
blanks
are
carried
through
the
entire
sample
preparation
and
analysis
process.
If
analytes
are
detected
in
a
laboratory
blank
(
see
Table
B3­
14)
the
associated
sample
data
are
flagged
with
a
B
qualifier.
Laboratory
blank
results
are
compared
with
the
acceptance
criteria
in
Table
B3­
5,
and
an
NCR
is
initiated
if
acceptance
criteria
are
exceeded.

Surrogate
compounds
(
system
monitoring
compounds)
are
added
to
each
sample
to
monitor
system
performance
in
specific
sample
matrices.
Surrogate
compound
percent
recoveries
are
calculated
and
compared
with
the
acceptance
criteria
in
Table
B3­
5.
Corrective
measures
defined
in
EPA
SW­
846
Methods
8260
and
8000
are
followed
in
case
of
surrogate
failure.
Surrogate
compound
data
that
do
not
meet
the
acceptance
criteria
are
flagged
with
a
"
Z"
flag.
Because
surrogate
compound
recovery
is
influenced
by
sample
matrix,
NCRs
are
not
initiated
for
surrogate
failures.

The
laboratory
also
analyzes
PDP
blind­
audit
samples.
If
notified
that
the
accuracy
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken
per
the
Solid
PDP
Plan.

Calibration
Tunes,
initial
calibrations,
and
continuing
calibrations
are
performed
per
Table
B3­
5
and
applicable
EPA
SW­
846
methods
for
GC/
MS
and
GC.
These
criteria
will
be
used
to
demonstrate
acceptable
calibration
and
to
trigger
corrective
action
when
control
limits
are
exceeded.

Method
Detection
Limit
MDLs
are
determined
for
each
analytical
method
initially,
then
semiannually.
MDLs
are
expressed
in
milligrams
per
killogram
(
mg/
kg)
for
VOCs.
Procedures
for
determining
MDLs
are
included
in
ACMMs­
9260
and
­
9441,
and
are
based
on
the
requirements
in
Section
B3­
1.
The
measured
MDLs
are
compared
with
the
required
MDLs
in
Table
B3­
4.
If
the
MDLs
are
not
met,
corrective
action
is
taken
and
the
MDLs
redetermined.
Analyses
do
not
proceed
until
the
MDL
criteria
are
met.

Program
Required
Quantitation
Limit
The
ALD
demonstrates
capability
to
quantitate
analytes
in
samples
at
or
below
the
Table
B3­
4
PRQLs
by
setting
the
analyte
concentrations
of
at
least
one
calibration
standard
below
their
respective
PRQLs.
Procedures
for
preparing
calibration
standards
are
included
in
ACMMs­
9260
and
 
9441.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

129
Completeness
Laboratory
completeness
is
expressed
as
the
number
of
samples
analyzed
with
valid
results
as
a
percent
of
the
total
number
of
samples
submitted
for
analysis.
Valid
results
are
defined
as
results
that
meet
the
data
usability
criteria
based
an
application
of
the
QC
criteria
specified
in
Tables
B3­
4
and
B3­
5
and
meet
the
calibration,
detection
limit,
representativeness
and
comparability
criteria
within
this
section.
Completeness
is
calculated
at
the
project
level
during
SQAO
review
per
MP­
TRUW­
8.9,
Level
II
Data
Validation.

Comparability
Comparability
of
analytical
data
is
ensured
by
consistent
use
of
uniform
procedures
based
on
standardized
EPA
SW­
846
sample
preparation
and
methods
that
meet
the
QAOs
specified
in
Tables
B3­
4
and
B3­
5,
use
of
standards
and
QC
samples
with
documented
traceability
to
recognized
national
standards
(
for
example,
NIST)
and
successful
participation
in
the
Solid
PDP.
AMWTP
may
use
the
most
recent
version
of
SW­
846.
Any
changes
to
SW­
846
methodology
that
results
in
the
elimination
of
sample
preparation
or
analytical
methods
must
be
addressed
as
a
corrective
action
to
address
the
comparability
of
data
before
and
after
the
modification.

Representativeness
Representativeness
for
VOC
analysis
is
achieved
by
collecting
unbiased
samples
as
addressed
in
Section
B1­
2.

B3­
7
Total
Semivolatile
Organic
Compound
Analysis
Total
SVOC
analysis
is
performed
at
the
Analytical
Laboratories
Department
(
ALD).

Quality
Assurance
Objectives
The
QAOs
in
Table
B3­
6
represent
the
required
quality
of
data
necessary
to
draw
valid
conclusions
regarding
program
objectives.
WIPP­
WAP
required
limits,
such
as
PRQLs,
are
specified
to
ensure
that
the
analytical
data
collected
satisfy
the
requirements
of
all
data
users.
A
summary
of
required
QC
samples
and
the
associated
acceptance
criteria
for
this
analysis
is
included
in
Table
B3­
7.
Corrective
actions
are
triggered
when
these
control
limits
are
exceeded.
Method
performance
in
specific
sample
matrices
is
evaluated
using
the
matrix­
dependent
QC
samples
in
Table
B3­
7;
data
are
qualified
if
control
limits
are
exceeded
but
nonconformance
reporting
is
not
required.
Key
data­
quality
indicators
for
laboratory
measurements
are
defined
below.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

130
Precision
Precision
is
assessed
through
the
analysis
of
laboratory
duplicates
or
matrix
spike
duplicates,
replicate
analyses
of
laboratory
control
samples,
and
PDP
blind­
audit
samples.
The
results
of
these
QC
samples
are
compared
with
the
acceptance
criteria
in
Table
B3­
6.
The
QC
measurements
independent
of
matrix
will
be
used
to
demonstrate
acceptable
method
performance.
Corrective
actions
are
triggered
when
control
limits
are
exceeded.

Precision
is
initially
assessed
using
analytical
methods
ACMM­
9270,
Semivolatile
Organic
Compounds
by
Gas
Chromatography/
Mass
Spectrometry
and
ACMM­
9080,
Determination
of
Polychlorinated
Biphenyls
(
PCBs)
by
Gas
Chromatography,
by
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
%
RSD
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
7.
The
%
RSD
must
comply
with
these
criteria
before
the
procedure
can
be
used
to
analyze
WIPP
samples.
Continuing
method
precision
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
RSD
must
be
within
the
Table
B3­
7
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
taken.
Further
analyses
cannot
be
performed
until
acceptable
precision
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.

A
matrix
spike
and
MSD
pair
is
analyzed
with
every
analytical
batch.
As
allowed
by
Table
B3­
7,
the
matrix
spike
duplicate
is
used
in
lieu
of
a
laboratory
duplicate.
The
precision
within
an
analytical
batch
is
assessed
by
calculating
the
RPD
between
the
matrix
spike
and
MSD
results.
The
RPD
must
comply
with
the
acceptance
criteria
in
Table
B3­
7.
If
the
RPD
is
not
within
the
criteria,
corrective
action
is
taken.
If
the
poor
precision
is
traced
to
the
sample
matrix,
sample
data
are
flagged
with
a
"
Z"
per
Section
B3­
12.
An
NCR
is
not
required
when
the
problem
is
traced
to
the
matrix.

The
ALD
also
analyzes
PDP
blind­
audit
samples.
If
notified
that
the
precision
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken
per
the
Solid
PDP
Plan.

Accuracy
Accuracy
as
%
R
is
assessed
for
the
analytical
methods
by
analyzing
laboratory
control
samples,
matrix
spikes,
surrogate
compounds,
and
PDP
blind­
audit
samples.
The
results
from
these
measurements
for
laboratory
control
samples
and
matrix
spikes
samples
are
compared
to
the
%
R
criteria
listed
in
Table
B3­
6.
Results
of
surrogates
and
internal
standards
are
evaluated
as
specified
in
the
SW­
846
method
(
EPA
1996)
or
Table
B3­
7.
These
QC
measurements
will
be
used
to
demonstrate
acceptable
method
performance
and
to
trigger
corrective
action
when
control
limits
are
exceeded.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

131
Accuracy
is
initially
assessed
using
analytical
methods
ACMMs­
9270
and
­
9080
by
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
average
%
R
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
7.
The
%
R
must
comply
with
these
criteria
before
the
procedure
can
be
used
to
analyze
WIPP
samples.
Continuing
method
accuracy
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
R
must
be
within
the
Table
B3­
7
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
taken.
Further
analyses
cannot
be
performed
until
acceptable
accuracy
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.

At
least
one
LCS
is
analyzed
with
each
analytical
batch.
Method
accuracy
within
the
analytical
batch
is
assessed
by
calculating
the
%
R
for
the
LCS
compounds.
The
%
Rs
must
comply
with
the
acceptance
criteria
in
Table
B3­
7.
If
the
%
R
is
not
within
the
acceptance
criteria
and
the
14­
day
preparation
 
to­
extraction
holding
time
has
not
been
exceeded,
the
associated
samples
may
be
reprepared
and
reanalyzed.
If
a
noncompliant
LCS
is
associated
with
reported
sample
data,
an
NCR
is
prepared.

Accuracy
for
a
specific
sample
matrix
is
assessed
by
analysis
of
a
matrix
spike/
MSD
sample
pair
in
every
analytical
batch
and
calculation
of
the
%
R
for
the
matrix
spike
and
the
MSD.
The
%
Rs
must
comply
with
the
acceptance
criteria
in
Table
B3­
7.
If
MS/
MSD
%
Rs
do
not
meet
the
criteria,
and
the
poor
accuracy
is
traced
to
the
sample
matrix,
sample
data
are
flagged
with
a
"
Z"
qualifier
per
Table
B3­
7.
An
NCR
is
not
required
when
the
problem
is
traced
to
the
matrix..

A
minimum
of
one
laboratory
blank
is
analyzed
per
analytical
batch
to
demonstrate
acceptable
levels
of
laboratory
contamination.
Laboratory
blanks
are
carried
through
the
entire
sample
preparation
and
analysis
process.
If
analytes
are
detected
in
a
laboratory
blank
(
see
Table
B3­
14),
the
associated
sample
data
are
flagged
with
a
B
qualifier.
Laboratory
blank
results
are
compared
with
the
acceptance
criteria
in
Table
B3­
7,
and
an
NCR
is
initiated
if
acceptance
criteria
are
exceeded.

Surrogate
compounds
(
system
monitoring
compounds)
are
added
to
each
sample
to
monitor
system
performance
in
specific
sample
matrices.
Surrogate
compound
percent
recoveries
are
calculated
and
compared
with
the
acceptance
criteria
in
Table
B3­
7.
Corrective
measures
defined
in
EPA
SW­
846
Methods
8270
and
8000
are
followed
in
case
of
surrogate
failure.
Surrogate
compound
data
that
do
not
meet
the
acceptance
criteria
are
flagged
with
a
"
Z"
flag.
Because
surrogate
compound
recovery
is
influenced
by
sample
matrix,
NCRs
are
not
prepared
for
surrogate
failures.

The
ALD
also
analyzes
PDP
blind­
audit
samples.
If
notified
that
the
accuracy
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken
per
the
Solid
PDP
Plan.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

132
Calibration
Tunes,
initial
calibrations,
and
continuing
calibrations
are
performed
and
evaluated
per
Table
B3­
7
for
GC/
MS
and
GC.
These
criteria
will
be
used
to
demonstrate
acceptable
calibration
and
trigger
corrective
action
when
control
limits
are
exceeded.

Method
Detection
Limit
MDLs
are
determined
for
each
analytical
method
initially,
then
semiannually.
MDLs
are
expressed
in
mg/
kg
for
SVOCs.
Procedures
for
determining
MDLs
are
included
in
ACMMs­
9270
and
­
9080
and
are
based
on
the
requirements
in
Section
B3­
1.
The
measured
MDLs
are
compared
with
the
required
MDLs
in
Table
B3­
6.
If
the
MDLs
are
not
met,
corrective
action
is
taken
and
the
MDLs
redetermined.
Analyses
do
not
proceed
until
the
MDL
criteria
are
met.

Program
Required
Quantitation
Limit
The
ALD
demonstrates
capability
to
quantitate
analytes
in
samples
at
or
below
the
Table
B3­
6
PRQLs
by
setting
the
analyte
concentrations
of
at
least
one
calibration
standard
below
their
respective
PRQLs.
Procedures
for
preparing
calibration
standards
are
included
in
ACMMs­
9270
and
­
9080.

Completeness
Laboratory
completeness
is
expressed
as
the
number
of
samples
analyzed
with
valid
results
as
a
percent
of
the
total
number
of
samples
submitted
for
analysis.
Valid
results
are
defined
as
results
that
specify
data
usability
criteria
based
on
application
of
the
QC
criteria
specified
in
Tables
B3­
6
and
B3­
7
and
that
meet
the
calibration,
detection
limit,
representativeness
and
comparability
criteria
specified
within
this
section.
Completeness
is
calculated
at
the
project
level
during
SQAO
review
per
MP­
TRUW­
8.9,
Level
II
Data
Validation.

Comparability
Comparability
of
analytical
data
is
ensured
by
consistent
use
of
uniform
procedures
based
on
standardized
methods
that
meet
the
QAOs
specified
in
Tables
B3­
6
and
B3­
7,
use
of
standards
and
QC
samples
with
documented
traceability
to
recognized
national
standards
(
for
example,
NIST),
and
successful
participation
in
the
Solid
PDP.
The
most
current
version
of
SW­
846
methods
are
consistent
with
QAO
requirements.
Any
changes
to
SW­
846
methodology
that
results
in
the
elimination
of
sample
preparation
or
analytical
methods
must
be
addressed
as
a
corrective
action
to
address
the
comparability
of
data
before
and
after
the
SW­
846
modification.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

133
ACMM­
9270
uses
GC/
MS
for
the
analysis
of
all
SVOC
target
analytes
except
PCBs.
This
method
is
based
on
EPA
SW­
846
Method
8270C.
Samples
are
prepared
for
SVOC
analysis
using
an
ultrasonic
extraction
method
based
on
EPA
SW­
846
Method
3550A.
This
extraction
procedure
is
documented
in
ACMM­
9500,
Sample
Preparation
for
Semivolatile
Organic
Compounds
and
Polychlorinated
Biphenyls.
ACMM­
9080
is
a
Gas
Chromatography/
Electron
Capture
Detection
(
GC/
ECD)
method
based
on
EPA
SW­
846
Method
8082
and
is
used
for
analysis
of
PCBs.
Samples
are
prepared
for
analysis
using
an
ultrasonic
extraction
method
based
on
EPA
SW­
846
Method
3550A,
followed
by
solvent
exchange
to
hexane
and
florisil
cleanup
based
on
EPA
SW­
846
Method
3620B.

Representativeness
Representativeness
for
SVOC
analysis
is
achieved
by
collecting
unbiased
samples,
addressed
in
Section
B1­
2.

B3­
8
Total
Metal
Analysis
Total
metals
analysis
Total
SVOC
analysis
is
performed
at
the
Analytical
Laboratories
Department
(
ALD).

Quality
Assurance
Objectives
The
specified
QAOs
in
Table
B3­
8
represent
the
required
quality
of
data
necessary
to
draw
valid
conclusions
regarding
AMWTP
objectives.
A
summary
of
required
QC
samples
and
the
associated
acceptance
criteria
are
included
in
Table
B3­
9.
Corrective
actions
are
triggered
when
these
control
limits
are
exceeded.
Method
performance
in
specific
sample
matrices
is
evaluated
using
the
matrix­
dependent
QC
samples
in
Table
B3­
9;
data
are
qualified
if
control
limits
are
exceeded
but
nonconformance
reporting
is
not
required.

Precision
Precision
is
assessed
through
the
analysis
of
laboratory
sample
duplicates
or
matrix
spike
duplicates,
replicate
analyses
of
laboratory
control
samples,
and
PDP
blind­
audit
samples.
The
results
of
QC
samples
are
compared
with
the
acceptance
criteria
in
Table
B3­
8.

Precision
is
initially
assessed
using
analytical
methods
ACMM­
2901,
Determination
of
Metals
by
ICP­
AES
for
TRU
Waste
Characterization,
and
ACMM­
2810,
Determination
of
Mercury
by
CVAA
for
TRU
Waste
Characterization,
by
preparing
and
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
%
RSD
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
9.
The
%
RSD
must
comply
with
the
criteria
before
the
procedures
can
be
used
to
analyze
WIPP
samples.
Continuing
method
precision
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
RSD
must
be
within
the
Table
B3­
9
acceptance
criteria.
If
these
criteria
are
not
met,
corrective
action
is
taken.
Further
analyses
cannot
be
performed
until
acceptable
precision
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

134
A
matrix
spike
and
MSD
pair
is
analyzed
with
every
analytical
batch.
As
allowed
by
Table
B3­
9,
the
MSD
is
used
in
lieu
of
a
laboratory
duplicate.
The
precision
within
an
analytical
batch
is
assessed
by
calculating
the
RPD
between
the
matrix
spike
and
MSD
results.
The
RPD
must
comply
with
the
acceptance
criteria
in
Table
B3­
9.
If
the
RPD
is
not
within
the
criteria,
corrective
action
is
taken.
If
the
poor
precision
is
traced
to
the
sample
matrix,
sample
data
are
flagged
with
a
"
Z"
per
Section
B3­
12.
An
NCR
is
not
required
when
the
problem
is
traced
to
the
matrix.

The
ALD
also
analyzes
PDP
blind­
audit
samples.
If
notified
that
the
precision
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken
per
the
Solid
PDP
Plan.

Accuracy
Accuracy
as
%
R
is
assessed
for
the
analytical
methods
by
analyzing
laboratory
control
samples,
matrix
spikes,
serial
dilutions,
interference
check
samples,
and
PDP
blind­
audit
samples.
The
results
from
these
measurements
are
compared
with
the
acceptance
criteria
in
Table
B3­
8
and
Table
B3­
9.
These
QC
measurements
will
be
used
to
demonstrate
acceptable
method
performance
and
to
trigger
corrective
action
when
control
limits
are
exceeded.

Laboratory
blanks
and
calibration
blanks
shall
be
assessed
to
determine
possible
laboratory
contamination
and
are
evaluated
as
specified
in
Table
B3­
9.
These
QC
measurements
will
be
used
to
demonstrate
acceptable
levels
of
laboratory
contamination
and
to
trigger
corrective
action
when
control
limits
are
exceeded.

Accuracy
is
initially
assessed
using
analytical
methods
ACMMs­
2901
and
­
2810
by
preparing
and
analyzing
a
minimum
of
seven
replicate
method
performance
samples.
The
average
%
R
is
calculated
for
the
replicate
analyses
and
compared
with
the
acceptance
criteria
in
Table
B3­
9.
The
%
R
must
comply
with
these
criteria
before
the
procedure
can
be
used
to
analyze
WIPP
samples.
Continuing
method
accuracy
performance
is
demonstrated
semiannually
through
analysis
of
at
least
four
method
performance
samples.
The
%
RSD
must
be
within
the
acceptance
criteria
in
Table
B3­
9.
If
these
criteria
are
not
met,
corrective
action
is
taken.
Further
analyses
cannot
be
performed
until
acceptable
precision
is
demonstrated
through
additional
replicate
analyses
of
method
performance
samples.

At
least
one
LCS
is
analyzed
with
each
analytical
batch.
Method
accuracy
within
the
analytical
batch
is
assessed
by
calculating
the
%
R
for
the
LCS
compounds.
The
%
Rs
must
comply
with
the
acceptance
criteria
in
Table
B3­
9.
If
a
solid
LCS
material
having
established
statistical
control
limits
is
used,
those
statistical
control
limits
are
used
to
evaluate
the
LCS
method
accuracy
requirement.
If
the
%
R
is
not
within
the
acceptance
criteria
and
the
holding
time
has
not
been
exceeded,
the
associated
samples
may
be
reprepared
and
reanalyzed.
If
a
noncompliant
LCS
is
associated
with
reported
sample
data,
an
NCR
is
prepared.

Accuracy
for
a
specific
sample
matrix
is
assessed
by
analysis
of
a
matrix
spike/
MSD
pair
in
every
analytical
batch
and
calculation
of
the
%
R
for
the
matrix
spike
and
MSD
results.
The
%
R
must
comply
with
the
acceptance
criteria
in
Table
B3­
9.
If
%
R
is
not
within
the
acceptance
criteria,
corrective
action
is
taken.
If
the
poor
accuracy
is
traced
to
the
sample
matrix,
sample
data
are
flagged
with
a
"
Z"
per
Section
B3­
12.
An
NCR
is
not
required
when
the
problem
is
traced
to
the
matrix.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

135
A
minimum
of
one
laboratory
blank
is
analyzed
per
analytical
batch
to
monitor
potential
bias
in
sample
results
due
to
laboratory
contamination.
Laboratory
blanks
are
carried
through
the
entire
sample
preparation
and
analysis
process.
Laboratory
blanks
results
are
compared
to
the
acceptance
criteria
in
Table
B3­
9.
If
laboratory
blank
concentrations
exceed
the
acceptance
criteria,
any
associated
sample
having
analyte
concentrations
less
than
or
equal
to
the
ten
times
the
blank
concentration
and
greater
than
or
equal
to
half
the
PRQL
must
be
redigested
and
reanalyzed.
An
NCR
is
initiated
if
redigestion
and
analysis
are
not
performed.

For
Inductively
Coupled
Plasma­
Atomic
Emission
Spectroscopy
(
ICP­
AES)
analyses
(
ACMM­
2901),
serial
dilution
and
interference
check
samples
are
analyzed
and
the
accuracy
of
the
results
is
assessed.
The
%
D
between
the
results
from
a
sample
and
serial
dilution
is
calculated
to
provide
an
indication
of
matrix
effects
on
instrument
accuracy.
If
the
%
D
values
do
not
meet
the
criteria
in
Table
B3­
9,
a
matrix
effect
is
inferred
and
the
data
are
flagged
with
a
"
Z".
An
NCR
is
not
required
because
the
problem
is
due
to
the
matrix.
The
%
R
for
target
compounds
in
the
interference
check
sample
is
calculated
and
compared
with
the
criteria
in
Table
B3­
9.
If
the
%
R
values
do
not
meet
acceptance
criteria,
the
problem
must
be
corrected
and
the
affected
samples
reanalyzed.
If
data
are
reported
from
an
analytical
run
with
unacceptable
%
R
values,
an
NCR
must
be
prepared.

The
ALD
also
analyzes
PDP
blind­
audit
samples.
If
notified
that
the
accuracy
of
the
PDP
analyses
is
not
acceptable,
corrective
action
is
taken
per
the
Solid
PDP
Plan.

Calibration
Initial
calibration/
verifications
and
continuing
calibration
verifications
(
CCVs)
are
performed
and
evaluated
using
methods
and
criteria
in
Table
B3­
9
and
the
EPA
SW­
846
method.
These
criteria
will
be
used
to
demonstrate
acceptable
calibration
and
trigger
corrective
action
when
control
limits
are
exceeded.

Program
Required
Detection
Limits
PRDLs
are
the
maximum
values
for
instrument
detection
limit
(
IDL)
permissible
for
program
support
under
the
WIPP­
WAP.
The
Instrument
Detection
Limits
(
IDLs)
for
each
target
metal
is
determined
initially,
then
semiannually
by
procedures
included
in
ACMMs­
2901
and
­
2810.
IDLs
are
expressed
in
units
of
micrograms
per
liter
(
µ
g/
L).
IDLs
must
be
less
than
or
equal
to
the
PRDLs
in
Table
B3­
8
for
the
method
used
to
quantitate
a
specific
analyte.
For
high
concentration
samples,
an
exception
to
the
requirements
may
be
made
in
cases
where
the
sample
concentration
exceeds
five
times
the
IDL
of
the
instrument
being
used.
In
this
case
the
analyte
concentration
may
be
reported
even
though
the
IDL
may
exceed
the
PRDL.
Analyses
do
not
proceed
until
the
IDL
criteria
are
met.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

136
Program
Required
Quantitation
Limits
The
ALD
shall
demonstrate
the
capability
of
analyte
quantitation
at
or
below
the
(
Table
B3­
8)
PRQLs
in
units
of
mg/
kg
wet
weight.
The
ALD
meets
the
PRQL
requirement
by
setting
the
analyte
concentrations
of
at
least
one
QC
or
calibration
standard
at
or
below
the
solution
concentration
equivalent
of
the
PRQL.
Procedures
for
preparing
calibration
standards
are
included
in
ACMMs­
2901
and
­
2810.

Completeness
Laboratory
completeness
is
expressed
as
the
number
of
samples
analyzed
with
valid
results
as
a
percent
of
the
total
number
of
samples
submitted
for
analysis.
Valid
results
are
defined
as
results
that
meet
the
data
usability
criteria
specified
in
Tables
B3­
8
and
B3­
9
and
meet
the
calibration,
detection
limit,
representativeness,
and
comparability
criteria
specified
within
this
section.
Completeness
is
calculated
at
the
project
level
during
SQAO
review
per
MP­
TRUW­
8.9,
Level
II
Data
Validation.

Comparability
Comparability
of
analytical
data
is
ensured
by
consistent
use
of
uniform
procedures
based
on
standardized
methods
that
meet
the
QAOs
specified
in
Tables
B3­
8
and
B3­
9,
use
of
standards
and
QC
samples
with
documented
traceability
to
recognized
national
standards
(
for
example,
NIST),
and
successful
participation
in
the
Solid
PDP.
The
most
current
version
of
SW­
846
methods
may
be
used
if
they
are
consistent
with
QAO
requirements.
Any
changes
to
SW­
846
methodology
that
results
in
the
elimination
of
sample
preparation
or
analytical
methods
must
be
addressed
as
a
corrective
action
to
address
the
comparability
of
data
before
and
after
the
SW­
846
modification.

ACMM­
8909,
Microwave
Assisted
Digestion
of
Homogeneous
Solids
and
Soil/
Gravel,
uses
microwave
digestion
for
sample
preparation
for
ICP­
AES
analysis.
This
method
is
based
on
EPA
SW­
846
Method
3051.
ACMM­
2901,
which
uses
ICP­
AES
to
determine
metals
concentrations
in
digested
samples,
is
based
on
EPA
SW­
846
Method
6010B.
ACMM­
2810
is
used
for
mercury
sample
preparation
and
analysis,
and
is
based
on
EPA
SW­
846
Method
7471A.

Representativeness
Representativeness
for
metals
analysis
is
achieved
by
collecting
unbiased
samples
and
preparation
of
samples
in
the
laboratory
using
representative
and
unbiased
methods
as
addressed
in
Section
B1­
2.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

137
B3­
9
Acceptable
Knowledge
AK
documentation
provides
primarily
qualitative
information
that
cannot
be
assessed
according
to
specific
data
quality
goals
used
for
analytical
techniques.
QAOs
for
analytical
results
are
described
in
terms
of
precision,
accuracy,
completeness,
comparability,
and
representativeness.
Appropriate
analytical
and
testing
results
are
used
to
confirm
the
characterization
of
wastes
based
on
AK
(
refer
to
Section
B4­
4).
To
ensure
the
AK
process
is
consistently
applied,
the
AMWTP
complies
with
the
following
data
quality
requirements
for
AK
documentation:

 
Precision
­
Precision
is
the
agreement
among
a
set
of
replicate
measurements
without
assumption
of
the
knowledge
of
a
true
value.
The
qualitative
determinations,
such
as
compiling
and
assessing
AK
documentation,
do
not
lend
themselves
to
statistical
evaluations
of
precision.
However,
the
AK
information
is
addressed
by
the
independent
review
of
AK
information
during
internal
and
external
audits.

 
Accuracy
­
Accuracy
is
the
degree
of
agreement
between
an
observed
sample
result
and
the
true
value.
The
percentage
of
waste
containers
that
require
reassignment
to
a
new
Waste
Matrix
Code
and/
or
designation
of
different
hazardous
waste
codes
based
on
the
reevaluation
of
AK
and
sampling
and
analysis
data
are
reported
as
a
measure
of
AK
accuracy.

 
Completeness
­
Completeness
is
an
assessment
of
the
number
of
waste
streams
or
number
of
samples
collected
to
the
number
of
samples
determined
to
be
usable
through
the
data
validation
process.
The
AK
record
must
contain
100%
of
the
required
information
(
B4­
3).
The
usability
of
AK
information
is
assessed
for
completeness
during
audits.

 
Comparability
­
Data
are
considered
comparable
when
one
set
of
data
can
be
compared
with
another
set
of
data.
Comparability
is
ensured
through
sites
meeting
the
training
requirements
and
complying
with
the
minimum
standards
outlined
in
procedures
that
are
used
to
implement
the
AK
process.
Assignment
of
hazardous
waste
codes
will
be
made
per
Section
B4­
4.
This
information
will
be
provided
to
other
sites
that
store
or
generate
a
similar
waste
stream.

 
Representativeness
­
Representativeness
expresses
the
degree
to
which
sample
data
accurately
and
precisely
represent
characteristics
of
a
population.
Representativeness
is
a
qualitative
parameter
that
will
be
satisfied
by
ensuring
the
process
of
obtaining,
evaluating,
and
documenting
AK
information
is
performed
per
Section
B­
4.
The
AMWTP
also
assesses
and
documents
the
limitations
of
the
AK
information
used
to
assign
hazardous
waste
codes
(
for
example,
purpose
and
scope
of
information,
date
of
publication,
type
and
extent
to
which
waste
parameters
are
addressed).

The
AMWTP
complies
with
the
nonconformance
notification
and
reporting
requirements
of
Section
B3­
1
if
the
results
of
confirmatory
analytical
techniques
in
Section
B
are
inconsistent
with
AK
documentation.

The
AMWTP
addresses
QC
by
tracking
its
performance
with
regard
to
the
use
of
AK
by:
1)
assessing
the
frequency
of
inconsistencies
among
information,
and
2)
documenting
the
results
of
AK
confirmation
through
radiography,
VE,
headspace
gas
analyses,
and
solidified
waste
analyses.
In
addition,
the
AK
process
and
waste
stream
documentation
are
evaluated
through
internal
assessments
by
QA
organizations
and
assessments
by
auditors
external
to
the
organization.
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation,
contains
the
site­
specific
procedure
for
AK.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

138
B3­
10
Data
Review,
Validation,
and
Verification
Requirements
Procedures
have
been
developed
for
the
review,
validation,
and
verification
of
data
at
the
data
generation
level
and
the
validation
and
verification
of
data
at
the
project
level.
Data
review
determines
if
raw
data
is
properly
collected
and
ensures
raw
data
are
properly
reduced.
Data
validation
confirms
that
the
data
reported
satisfies
the
requirements
of
the
WIPP­
WAP
and
is
accompanied
by
signature
release.
Data
verification
authenticates
that
data
as
presented
represent
the
sampling
and
analysis
activities
as
performed
and
have
been
subject
to
the
appropriate
levels
of
data
review.
These
requirements
ensure
that
WIPP­
WAP
records
furnish
documentary
evidence
of
quality.

The
AMWTP
has
implemented
an
electronic
data
processing
system
called
the
Waste
Tracking
System
(
WTS).
Data
are
collected
by
the
operator,
entered
into
the
WTS
(
automated
or
key
entry),
signed
electronically,
and
promoted
for
data
generation
level
review
and
validation.
The
data
are
progressively
reviewed
(
on
a
batch
basis)
at
the
data
generation
level
by
the
independent
reviewer,
technical
supervisor
and
QA
Representative
using
paper/
electronic
data
validation
checklists.
The
reviews
are
performed
in
the
sequence
specified.
If
data
are
approved,
the
data
are
automatically
promoted
to
the
next
reviewer.
If
the
data
are
rejected,
the
data
are
manually/
automatically
demoted
to
the
data
generator
for
problem
resolution.

Data
batches
approved
by
data
generation
level
QA
are
promoted
to
the
project
level
and
the
progressive
review
process
is
repeated
by
the
SQAO
or
designee
and
the
SPM
or
designee.
The
SQAO
and
the
SPM
completes
manual/
electronic
data
validation/
verification
checklists.
The
SPM
or
designee
assembles
a
WSPF
that
is
transmitted
to
WIPP
with
the
appropriate
characterization
data
in
WWIS.

Once
an
approved
WSPF
is
in
place
for
a
waste
stream,
the
data
are
promoted
through
Certification
and
Transportation
levels
of
review
and
approval
and
transferred
to
WWIS
via
WTS.

Four
types
of
Batch
Data
Reports
are
validated
at
the
project
level
as
follows:

 
A
Testing
Batch
Data
Report
or
equivalent
includes
all
data
pertaining
to
radiography
or
VE
for
up
to
20
waste
containers
without
regard
to
waste
matrix.
Table
B3­
11
lists
all
of
the
information
required
in
Testing
Batch
Data
Reports
(
identified
with
an
"
X")
and
other
information
that
is
necessary
for
data
validation,
but
is
optional
in
Testing
Batch
Data
Reports
(
identified
with
an
"
O").

 
A
Sampling
Batch
Data
Report
or
equivalent
includes
all
sample
collection
data
pertaining
to
a
group
of
no
more
than
20
samples
headspace
or
homogeneous
waste
samples
that
were
collected
for
chemical
analysis.
Table
B3­
12
lists
all
of
the
information
required
in
Sampling
Batch
Data
Reports
(
identified
with
an
"
X")
and
other
information
that
is
necessary
for
data
validation,
but
is
optional
in
Sampling
Batch
Data
Reports
(
identified
with
an
"
O").
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

139
 
An
Analytical
Batch
Data
Report
or
equivalent
analytical
data
from
the
analysis
of
TRU­
mixed
waste
for
up
to
20
samples
headspace
or
homogeneous
waste
samples.
Analytical
Batch
Data
Reports
or
equivalent
that
contain
results
for
composited
headspace
gas
samples
must
contain
sufficient
information
to
identify
the
containers
that
were
composited
for
each
composite
sample
and
the
sample
volume
that
was
taken
from
each
waste
container.
Because
Analytical
Batch
Data
Reports
are
generated
based
on
the
number
of
samples
analyzed,
an
Analytical
Batch
Data
Report
may
contain
results
that
are
applicable
to
more
than
20
containers
depending
on
how
many
composite
samples
are
part
of
the
report,
but
may
not
exceed
a
total
of
20
samples
analyzed.
Table
B3­
13
lists
all
of
the
information
required
in
Analytical
Batch
Data
Reports
(
identified
with
an
"
X")
and
other
information
that
is
necessary
for
data
validation,
but
is
optional
in
Analytical
Batch
Data
Reports
(
identified
with
an
"
O").

 
Raw
analytical
data
need
not
be
included
in
Analytical
Batch
Data
Reports,
but
must
be
maintained
in
the
site
project
files
and
be
readily
available
for
review
upon
request.
Raw
data
may
include
all
analytical
bench
sheet
and
instrumentation
readouts
for
all
calibration
standard
results,
sample
data,
QC
samples,
sample
preparation
conditions
and
logs,
sample
run
logs,
and
all
re­
extraction,
reanalysis
or
dilution
information
pertaining
to
the
individual
samples.
Raw
data
may
also
include
calculation
records
and
any
qualitative
or
semi­
quantitative
data
collected
for
a
sample
and
that
has
been
recorded
on
a
bench
sheet
or
in
a
logbook.

 
An
On­
line
Batch
Data
Report
or
equivalent
contains
the
combined
information
from
the
Sampling
Batch
Data
Report
and
Analytical
Batch
Data
Report
that
is
relevant
to
the
on­
line
method
used.
For
on­
line
integrated
headspace­
gas
sampling/
analytical
systems,
samples
will
be
collected
within
a
12­
hour
period
using
the
same
on­
line
integrated
sampling/
analysis
system.

The
AMWTP
batch
numbers
are
assigned
using
a
the
following
standard
numbering
convention.
The
conventions
shall
be
formatted
as
follows:

XXXyy­
nnnnnm
Where
XXX
=
batch
type
indicator
as
follows
RTR
=
radiography
testing
batch
ASY
=
Assay
testing
batch
VVE
=
Visual
Examination
testing
batch
HSA
=
Headspace
Analytical
HSG
=
On­
line
HSG
sampling
batch
MHS
=
Manual
HSG
sampling
batch
SSC
=
Solid
Sampling
(
coring)
batch
SSA
=
Solid
Sampling
analytical
batch
yy
=
Calendar
year
(
01
for
2001)
nnnnn
=
a
number
that
starts
with
00001
at
the
beginning
of
each
calendar
year,
and
increases
sequentially
for
each
batch.
m
=
method
indicator
(
if
needed)
Typical
examples:­
ASY01­
00071
HSG02­
11111
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

140
B3­
10a
Data
Generation
Level
The
following
are
the
minimum
requirements
for
raw
data
collection
and
management:

 
All
raw
data
are
signed
and
dated
in
reproducible
ink
by
the
person
generating
it.
Alternately,
unalterable
electronic
signatures
are
used.

 
All
data
are
recorded
clearly,
legibly,
and
accurately
in
field
and
laboratory
records
(
bench
sheets
and
logbooks),
and
include
applicable
sample
identification
numbers
(
for
sampling
and
analytical
labs).

 
Any
changes
to
original
data
are
lined
out,
initialed,
and
dated
by
the
individual
making
the
change.
A
justification
for
changing
the
original
data
is
also
included
(
if
not
readily
apparent).
The
original
data
are
not
obliterated
or
otherwise
disfigured
so
as
not
to
be
readable.
Data
changes
are
made
by
the
individual
who
originally
collected
the
data
or
an
individual
authorized
to
change
the
data.

 
All
data
are
transferred
and
reduced
from
field
and
laboratory
records
completely
and
accurately.

 
All
field
and
laboratory
records
are
maintained
as
specified
in
Table
B­
7.

 
Data
are
organized
into
a
standard
format
for
reporting
purposes
(
Batch
Data
Report),
as
outlined
in
specific
sampling
and
analytical
procedures.

Data
review,
validation,
and
verification
at
this
level
involve
scrutiny
and
signature
release
from
qualified
independent
technical
reviewer(
s),
technical
supervisor(
s)
or
designee,
and
a
QA
Representative
or
designee
as
specified
below.
Individuals
conducting
this
data
review,
validation,
and
verification
must
use
checklists
that
address
all
items
included
in
this
section.
Checklists
contain
or
reference
tables
showing
the
results
of
sampling,
analytical,
or
on­
line
batch
QC
samples,
as
applicable.
Checklists
reflect
review
of
all
QC
samples
and
QAO
categories
per
criteria
in
Tables
B3­
2
through
B3­
9
(
as
applicable
to
the
methods
validated).
Completed
checklists
are
forwarded
with
Batch
Data
Reports
to
the
project
level.
Analytical
raw
data
must
be
available
and
reviewed
by
the
data
generation
level
reviewer;
however,
it
need
not
be
included
in
the
Batch
Data
Report.
Nonconformances
identified
during
data
generation
level
validation
and
verification
are
documented
per
MP­
Q&
SI­
5.4.
All
activities
required
to
achieve
these
objectives
are
addressed
in
MP­
TRUW­
8.8,
Level
I
Data
Validation
and
MCP­
2008,
Analytical
Data
Recording,
Review,
and
Reporting.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

141
B3­
10a(
1)
Independent
Technical
Review
(
ITR)

The
independent
technical
review
ensures
by
review
of
raw
data
that
data
generation
and
reduction
are
technically
correct;
calculations
are
verified
correct;
deviations
are
documented;
and
QA/
QC
results
are
complete,
documented
correctly,
and
compared
against
WIPP­
WAP
criteria.
This
review
validates
and
verifies
all
of
the
work
done
by
the
originator.

All
(
100%)
of
the
Batch
Data
Reports
receive
a
documented
ITR.
This
review
is
performed
by
an
individual
other
than
the
data
generator
who
is
qualified
to
have
performed
the
initial
work.
This
review
is
performed
as
soon
as
practicably
possible
to
determine
and
correct
negative
quality
trends
in
the
sampling
or
analytical
process.
However,
at
a
minimum,
the
ITR
is
performed
before
any
waste
associated
with
data
is
shipped
to
WIPP.
The
ITR
review
and
signature
release
ensure
the
following:

 
Data
generation
and
reduction
were
conducted
in
a
technically
correct
manner
per
the
method
used
(
procedure
with
revision).
Data
were
reported
in
the
proper
units
correct
number
of
significant
figures.

 
Calculations
have
been
verified
by
a
valid
calculation
program,
a
spot
check
of
verified
calculation
programs,
and/
or
100%
check
of
all
hand
calculations.
Values
not
verified
to
within
rounding
or
significant
difference
discrepancies
are
rectified
before
ITR
completion.

 
The
data
were
reviewed
for
transcription
errors.

 
The
testing,
sampling,
or
analytical
data
QA
documentation
for
Batch
Data
Reports
is
complete
and
includes,
as
applicable,
raw
data,
DAC
and
equilibrium
calculations
and
times,
calculation
records,
COC
forms,
calibration
records
(
or
references
to
an
available
calibration
package),
QC
sample
results,
and
copies
or
originals
of
the
gas
sample
canister
tags.
Corrective
action
is
taken
to
ensure
all
Batch
Data
Reports
are
complete
and
include
all
necessary
raw
data
before
ITR
completion.

 
QC
sample
results
were
within
established
control
limits
and,
if
not,
the
data
were
appropriately
qualified
per
the
data
usability
criteria.
Data
outside
established
control
limits
are
qualified,
as
appropriate,
assigned
an
appropriate
qualifier
flag,
discussed
in
the
case
narrative,
and
included,
as
appropriate,
in
calculations
for
completeness.

 
Reporting
flags
(
Table
B3­
14)
were
assigned
correctly.

 
Sample
holding
time
and
preservation
requirements
were
met,
or
exceptions
documented.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

142
 
Radiography
audio/
video
recordings
were
reviewed
(
independent
observation)
on
a
waste
container
basis
once
per
testing
batch,
or
once
per
day
of
operation,
whichever
is
less
frequent
(
Section
B1­
3b(
2)).
The
radiography
audio/
videotape
(
or
equivalent
media)
recordings
are
reviewed
against
the
reported
data
on
the
radiography
form
to
ensure
the
data
are
correct
and
complete.

 
Field
sampling
records
are
complete.
Incomplete
or
incorrect
field
sampling
records
are
subject
to
resubmittal
before
ITR
completion.

B3­
10a(
2)
Technical
Supervisory
Signature
Release
The
technical
supervisor
review
ensures
that
the
independent
technical
review
was
performed
completely,
that
the
Batch
Data
Report
is
complete,
and
verifies
that
the
results
are
technically
reasonable.
This
review
validates
and
verifies
that
the
characterization
performed
in
this
area
is
ready
for
QA
Representative
review.

All
(
100%)
of
the
Batch
Data
Reports
receive
technical
supervisory
(
or
designee)
signature
release
for
each
testing
batch,
sampling
batch,
analytical
and
on­
line
batches.
The
technical
supervisory
signature
release
occurs
as
soon
as
practicably
possible
after
the
ITR
to
determine
and
correct
negative
quality
trends
in
the
sampling
or
analytical
process.
However,
at
a
minimum,
the
technical
supervisory
signature
release
is
performed
before
any
waste
associated
with
the
data
is
shipped
to
WIPP.
This
release
ensures
the
following:

 
The
data
are
technically
reasonable
based
on
the
technique
used
 
All
data
received
ITR
with
the
exception
of
radiography
audio/
videotape
(
or
equivalent
media)
recordings,
which
receive
periodic
technical
reviews
as
specified
in
Section
B1­
3b(
2).

 
The
testing,
sampling,
or
analytical
data
QA
documentation
for
Batch
Data
Reports
is
complete
and
includes,
as
appropriate,
raw
data,
DAC
and
equilibrium
times,
calculation
records,
COC
forms,
calibration
records,
QC
sample
results,
and
original
or
copies
of
the
gas
sample
canister
tags
 
Sample
holding
time
requirements
were
met,
or
exceptions
documented.

 
Field
sampling
records
are
complete.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

143
B3­
10a(
3)
QA
Representative
Signature
Release
The
data
generation
level
QA
review
ensures
that
Batch
Data
Report
is
complete,
that
QC
checks
meet
the
acceptance
criteria,
and
that
the
appropriate
QAOs
have
been
met.
This
review
verifies
and
validates
that
the
characterization
results
meet
the
program
QA/
QC,
that
instrument
performance
criteria
have
been
met,
and
that
QAOs
for
the
subject
characterization
area
have
been
met.
The
QA
review
may
be
conducted
by
the
Technical
Supervisor,
using
a
separate
checklist.

All
(
100%)
of
the
batch
data
reports
receive
Data
Generation
Level
QA
Representative
or
designee
signature
release.
The
QA
Representative
signature
release
occurs
as
soon
as
practicably
possible
after
the
technical
supervisory
signature
release
to
determine
and
correct
negative
quality
trends
in
the
sampling
or
analytical
process.
However,
at
a
minimum,
the
QA
Representative
signature
release
is
performed
before
any
waste
associated
with
data
reviewed
is
shipped
to
the
WIPP
facility.
This
release
ensures
the
following:

 
Independent
technical
and
technical
supervisory
reviews
were
performed
as
evidenced
by
the
appropriate
signature
releases
 
QA
documentation
for
the
Batch
Data
Report
is
completed
as
appropriate
for
the
point
of
data
generation
 
Sampling
and
laboratory
QC
checks
were
properly
performed,
and
QC
criteria
that
were
not
met
are
documented
 
QAOs
have
been
met
according
to
methods
out­
lined
in
Section
B3­
11.

B3­
10b
Project
Level
Data
review,
validation,
and
verification
at
this
level
involves
scrutiny
and
signature
release
from
the
SPM
or
designee
and
the
SQAO
or
designee.
MP­
TRUW­
8.9,
Level
II
Data
Validation,
defines
the
project
level
validation
and
verification
process.
Any
nonconformance
identified
during
this
process
shall
be
documented
on
an
NCR.

The
SPM
and
the
SQAO
shall
ensure
that
a
repeat
of
the
data
generation
level
review,
validation,
and
verification
is
performed
on
the
data
for
a
minimum
of
one
randomly
chosen
waste
container
quarterly
(
every
three
months).
This
exercise
will
document
that
the
data
generation
level
review,
validation,
and
verification
is
being
performed
according
to
procedures.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

144
B3­
10b(
1)
SQAO
Signature
Review
and
Release
of
Batch
Data
Reports
The
SQAO
review
ensures
that
the
Batch
Data
Reports
received
from
the
data
generation
are
complete,
validates
and
verifies
that
the
QC
checks
were
done
properly
and
meet
program
criteria,
and
ensures
that
the
QAOs
have
been
met.

All
(
100%)
of
the
Batch
Data
Reports
receive
SQAO
or
designee
signature
release.
The
SQAO
signature
release
occurs
as
soon
as
practicably
possible
to
determine
and
correct
negative
quality
trends
in
the
sampling
or
analytical
process.

However,
at
a
minimum,
the
SQAO
signature
release
is
performed
before
any
waste
associated
with
data
reviewed
is
shipped
to
WIPP.
This
signature
release
ensures
the
following:

 
Batch
Data
Reports
are
complete
and
data
are
properly
reported
(
i.
e.,
data
are
reported
in
correct
units,
and
with
correct
qualifying
flags)

 
Sampling
batch
QC
checks
(
e.
g.,
equipment
blanks,
field
duplicates,
field
reference
standards)
were
properly
performed,
meet
the
established
QAOs,
and
are
within
established
data
usability
criteria
 
Testing
batch
QC
checks
(
e.
g.,
replicate
scans,
measurement
system
checks)
were
properly
performed.
Radiography
data
are
complete
and
acceptable
based
on
evidence
of
videotape
review
of
one
waste
container
per
day
or
once
per
testing
batch,
whichever
is
less
frequent,
as
specified
in
B1­
3b(
2).

 
Analytical
QC
checks
(
e.
g.,
laboratory
duplicates,
laboratory
blanks,
matrix
spikes,
matrix
spike
duplicates,
laboratory
control
samples)
were
properly
performed,
meet
the
established
QAOs,
and
are
within
established
data
usability
criteria
 
On­
line
QC
checks
(
e.
g.,
field
blanks,
on­
line
blanks,
on­
line
duplicates,
on­
line
control
samples)
were
properly
performed,
meet
the
established
QAOs,
and
are
within
established
data
usability
criteria.

 
Proper
procedures
were
followed
to
ensure
representative
samples
for
headspace
gas
and
homogeneous
solids
and
soil/
gravel
were
taken
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

145
B3­
10b(
2)
SPM
Signature
Release
of
Batch
Data
Reports
The
Site
Project
Manager
review
is
the
final
validation
that
all
of
the
data
contained
in
Batch
Data
Reports
have
been
properly
reviewed
as
evidenced
by
signature
release
and
completed
checklists.

All
(
100%)
of
the
Batch
Data
Reports
have
an
SPM
or
designee
signature
release.
The
SPM
signature
release
occurs
as
soon
as
practicably
possible
after
the
SQAO
signature
release
to
determine
and
correct
negative
quality
trends
in
the
sampling
or
analytical
process.
However,
at
a
minimum,
the
SPM
signature
release
is
performed
before
any
waste
associated
with
data
reviewed
is
shipped
to
WIPP.
This
signature
release
ensures
the
following:

 
Data
generation
level
independent
technical,
technical
supervisory,
and
QA
representative
(
or
designee)
review,
validation,
and
verification
have
been
performed
as
evidenced
by
completed
review
checklists
and
by
the
appropriate
signature
releases.

 
Batch
data
review
checklists
are
complete.

 
Batch
Data
Reports
are
complete
and
data
are
properly
reported
(
e.
g.,
data
are
reported
in
the
correct
units,
with
the
correct
number
of
significant
figures,
and
with
qualifying
flags).

 
Verification
that
data
are
within
established
data
assessment
criteria
and
meet
the
applicable
QAOs
(
Section
B3­
11).

 
The
Site
Project
Manager
or
designee
shall
determine
the
validity
of
the
drum
age
criteria
(
DAC)
assignment
made
at
the
data
generation
level
based
upon
an
assessment
of
the
data
collection
and
evaluation
necessary
to
make
the
assignment.

B3­
10b(
3)
Prepare
SQAO
Summary
and
Data
Validation
Summary
To
document
the
project
level
validation
and
verification
described
above,
the
SQAO
(
or
designee)
prepares
the
Site
Project
QA
Officer
Summary,
and
the
SPM
(
or
designee)
prepares
a
Data
Validation
Summary.
These
reports
may
be
combined
to
eliminate
redundancy,
or
incorporated
into
the
SQAO
and
SPM
checklists.
The
SQAO
Summary
includes
a
validation
checklist
for
each
Batch
Data
Report.
Checklists
for
the
SQAO
Summary
are
sufficiently
detailed
to
validate
all
aspects
of
a
Batch
Data
Report
that
affect
data
quality.

The
Data
Validation
Summary
provides
confirmation
that,
on
a
per
waste
container
basis
as
evidenced
by
Batch
Data
Report
reviews,
all
data
have
been
validated
per
this
QAPjP.
The
Data
Validation
Summary
must
identify
each
Batch
Data
Report
reviewed
(
including
all
waste
container
numbers),
describe
how
the
validation
was
performed
and
whether
or
not
problems
were
detected
(
e.
g.,
nonconformances),
and
include
a
statement
indicating
all
data
are
acceptable.
Summaries
include
release
signatures.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

146
Once
the
data
are
approved
through
project
level
validation
and
verification,
or
when
the
SPM
decides
the
sample
no
longer
needs
to
be
retained,
the
SPM
or
designee
notifies
the
laboratories;
samples
must
be
retained
until
this
notification
is
received.
Gas
sample
canisters
may
then
be
released
from
storage
for
cleaning,
recertification,
and
subsequent
reuse.
Sample
tags
are
removed
and
retained
in
the
files
before
recycling
the
canisters.
If
the
SPM
requests
that
samples
or
canisters
be
retained
for
future
use
(
e.
g.,
an
experimental
holding
time
study),
the
same
sample
identification
and
COC
forms
are
used
and
crossreferenced
to
documentation
specifying
the
purpose
for
sample
or
canister
retention.

B3­
10b(
4)
Prepare
Waste
Stream
Characterization
Package
In
the
event
the
CBFO
request
detailed
information
on
a
waste
stream,
AMWTP
will
provide
a
Waste
Stream
Characterization
Package.
The
SPM
can
require
each
characterization
area,
data
generation
level
technical
supervisor/
QA
officer
to
assist
in
preparation
and
review
of
the
Waste
Stream
Characterization
Package
(
Section
B3­
12b(
2))
as
necessary
to
ensure
the
package
will
support
the
SPM's
waste
characterization
determinations.

B3­
10c
CBFO
Level
Not
applicable
to
the
AMWTP,
this
section
refers
to
WIPP.

B3­
11
Reconciliation
with
Data
Quality
Objectives
Reconciling
the
results
of
waste
testing
and
analysis
with
the
DQOs
provides
a
way
to
ensure
data
are
of
adequate
quality
to
support
the
regulatory
compliance
programs.
Reconciliation
with
the
DQOs
takes
place
at
both
the
project
and
the
CBFO
levels.
At
the
project
level,
reconciliation
is
performed
by
the
SPM
or
designee,
and
submitted
to
CBFO
for
review
and
approval.
Reconciliation
is
performed
as
described
in
MPTRUW
8.11,
Data
Reconciliation.

B3­
11a
Reconciliation
at
the
Project
Level
The
SPM
ensures
all
data
generated
and
used
in
decision
making
meet
the
DQOs
provided
in
Section
B­
4a(
1).
The
SPM
assesses
whether
data
of
sufficient
type,
quality,
and
quantity
have
been
collected
for
each
waste
stream.
The
SPM
determines
if
the
variability
of
the
data
set
is
small
enough
to
provide
the
required
confidence
in
the
results.

The
SPM
also
determines
if,
based
on
the
desired
error
rates
and
confidence
levels,
a
sufficient
number
of
valid
data
points
have
been
determined
(
as
established
by
the
associated
completeness
rate
for
each
sampling
and
analytical
process).
In
addition,
the
SPM
documents
that
random
sampling
of
containers
was
performed
for
the
purposes
of
waste
stream
characterization.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

147
For
each
waste
stream,
the
SPM
determines
if
sufficient
data
have
been
collected
to
determine
the
following
WIPP­
WAP­
required
waste
parameters:

 
Waste
Matrix
Code
 
Waste
material
parameter
weights
 
If
each
container
of
waste
contains
TRU
radioactive
waste
 
Mean
concentrations,
UCL90
for
the
mean
concentrations,
standard
deviations,
and
the
number
of
samples
collected
for
each
VOC
in
the
headspace
gas
of
waste
containers
in
the
waste
stream
(
if
applicable)

 
Potential
flammability
of
TRU
waste
headspace
gases
 
Mean
concentrations,
UCL90
for
the
mean
concentrations,
standard
deviations,
and
the
number
of
samples
collected
for
VOCs,
SVOCs,
and
metals
in
the
waste
stream
 
Whether
the
waste
stream
exhibits
a
TC
under
40
CFR
Part
261,
Subpart
C
 
Whether
the
waste
stream
is
classified
as
hazardous
or
nonhazardous
at
the
90%
confidence
level
 
Whether
a
sufficient
number
of
waste
containers
were
visually
examined
(
as
a
QC
check
on
radiography)
to
determine
with
a
reasonable
level
of
certainty
that
the
UCL90
for
the
miscertification
rate
is
less
than
14%

 
Whether
an
appropriate
packaging
configuration
and
Drum
Age
Criteria
(
DAC)
were
applied
and
documented
in
the
headspace
gas
sampling
documentation,
and
whether
the
drum
age
was
met
prior
to
sampling.

 
Whether
all
TICs
were
appropriately
identified
and
reported
per
the
requirements
of
Section
B3­
1
before
submittal
of
a
WSPF
for
a
waste
stream
or
waste
stream
lot
 
Whether
the
overall
completeness,
comparability,
and
representativeness
QAOs
were
met
for
each
analytical
and
testing
procedure
per
Sections
B3­
2
through
B3­
9
before
submittal
of
a
WSPF
for
a
waste
stream
or
waste
stream
lot
 
Whether
the
PRQLs
for
all
analyses
were
met
before
submittal
of
a
WSPF
for
a
waste
stream
or
waste
stream
lot.

If
the
SPM
determines
insufficient
data
have
been
collected
to
make
the
determinations
listed
above,
additional
data
collection
efforts
must
be
undertaken.
The
reconciliation
of
a
waste
stream
is
performed
before
submittal
of
the
WSPF.
For
subsequent
shipments,
data
reconciliation
is
done
on
all
containers
or
samples
prior
to
shipment
to
the
WIPP.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

148
The
SPM
(
or
designee)
uses
MP­
TRUW­
8.11,
Data
Reconciliation,
as
the
statistical
procedure
(
Section
B2)
to
evaluate
and
report
waste
characterization
data
from
the
analysis
of
homogeneous
solids
and
soils/
gravel.
This
procedure
assesses
compliance
with
the
DQOs
in
Section
B­
4a(
1)
as
well
as
the
RCRA
regulations.
It
applies
to
all
laboratory
analytical
data
for
total
VOCs,
total
SVOCs,
and
total
metals.
For
RCRA
regulatory
compliance
(
40
CFR
261.24),
data
from
the
analysis
if
the
appropriate
metals
and
organic
compounds
is
expressed
as
toxicity
characteristic
leaching
procedure
(
TLCP)
values
or
results
are
compared
to
the
TC
levels
expressed
as
total
values.
These
total
values
will
be
considered
regulatory
threshold
limit
(
RTL)
values.
RTL
values
are
obtained
by
calculating
the
weight/
weight
concentration
(
in
the
solid)
of
a
TC
analyte
that
would
give
the
regulatory
weight/
volume
concentration
(
in
the
TLCP
extract),
assuming
100­
percent
dissolution.

B3­
11b
Reconciliation
at
the
CBFO'
Level
Not
applicable
to
the
AMWTP;
this
section
refers
to
CBFO.

B3­
12
Data
Reporting
Requirements
Data
reporting
requirements
define
the
type
of
information
and
the
method
of
transmittal
for
data
transfer
from
the
data
generation
level
to
the
project
level
and
from
the
project
level
to
WIPP.

The
AMWTP
utilizes
WTS
for
data
validation,
reporting
and
WWIS
transfer.
Validation
performed
on
any
solid
sampling
and
analysis
at
the
ALD
utilizes
both
paper
and
electronic
data
reporting
and
validation.
All
batches
can
be
transmitted
at
any
level
in
paper
form
upon
request.

B3­
12a
Data
Generation
Level
to
the
Project
Level
At
the
AMWTP,
data
reporting
is
accomplished
electronically
with
WTS
to
the
extent
possible.
Data
are
transmitted
by
hard
copy
or
electronically
(
hard
copy
is
available
on
demand)
from
the
data
generation
level
to
the
project
level
(
SPO).
The
Batch
Data
Reports
and
checklists
used
contain
the
information
required
by
the
testing,
sampling,
and
analytical
techniques
described
in
Sections
B1
through
B6,
as
well
as
the
signature
releases
to
document
the
review,
validation,
and
verification
described
in
B3­
10.
All
batch
data
reports
and
checklists
will
be
approved
formats,
as
provided
in
approved
procedures.

Hard
copy
reports
are
transmitted
to
the
AMWTP
Document
Control.
Electronic
reports
through
WTS
are
transmitted
after
generation
level
electronic
signature
release
to
the
SQAO.
After
review
by
the
SQAO,
all
Batch
Data
Reports
are
forwarded
to
the
SPM
or
designee.
All
hard
copy
reports
are
assigned
serial
numbers
and
each
page
is
numbered.
Transmitted
data
include
all
testing,
sampling,
and
analytical
Batch
Data
Reports,
and
data
review
checklists.

Data
generating
organizations
are
responsible
for
ensuring
that
correct
and
current
characterization
information
is
forwarded
to
the
SPO
if
changes
to
reported
data
are
identified.
This
responsibility
includes
modifying
all
data
packages
or
database
records
impacted
by
the
changed
characterization
information.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

149
QA
documentation
and
records,
including
raw
data,
are
maintained
in
either
testing,
sampling,
and
analytical
facility
files,
or
site
project
files
per
the
document
storage
requirements
presented
in
Section
B.
In
addition
to
Batch
Reports,
ALD
forwards
sampling
and
analytical
QA
documentation
to
the
SPO.
Contract
waste
characterization
facilities
shall
forward
testing,
sampling,
and
analytical
QA
documentation
along
with
Batch
Data
Reports
to
the
SPO
for
inclusion
in
the
paper
files.

B3­
12b
Project
Level
to
CBFO
Level
The
Characterization
Information
Summary
and
Waste
Stream
Characterization
Package
(
when
requested
by
the
CBFO)
are
prepared
as
appropriate
and
transmitted
to
WIPP
electronically
or
by
hard
copy.
In
addition,
the
site
project
office
prepares
a
WSPF
in
accordance
with
MP­
TRUW­
8.14,
Preparation
of
Waste
Stream
Profile
Forms,
for
each
waste
stream
certified
for
shipment
to
WIPP.
The
SQAO
verifies
these
reports
are
consistent
with
information
found
in
analytical
batch
reports.
Summarized
testing,
sampling,
and
analytical
data
are
included
with
the
Characterization
Information
Summary.
The
contents
of
the
WSPF,
the
Characterization
Information
Summary,
and
the
Waste
Stream
Characterization
Package
are
discussed
in
the
following
sections.

After
approval
of
a
WSPF
and
the
associated
Characterization
Information
Summary,
the
AMWTP
maintains
a
cross­
reference
of
container
identification
numbers
to
each
Batch
Report.

A
Waste
Stream
Characterization
package
must
be
submitted
when
requested
by
the
CBFO.

B3­
12b(
1)
Waste
Stream
Profile
Form
(
MP­
TRUW­
8.14,
Preparation
of
Waste
Stream
Profile
Forms)

The
WSPF
(
Figure
B­
1)
includes
the
following
information:

 
Generator/
storage
site
name
 
Generator/
storage
site
EPA
ID
 
Date
of
audit
report
approval
by
NMED
(
if
obtained)

 
Original
generator
of
waste
stream
 
The
waste
stream
WIPP
identification
number
 
Summary
Category
Group
 
Waste
Matrix
Code
Group
 
Waste
stream
name
 
Description
of
the
waste
stream
 
Applicable
EPA
hazardous
waste
codes
 
Applicable
TRUCON
codes
 
A
listing
of
AK
documentation
used
to
identify
the
waste
stream
 
The
waste
characterization
procedures
used
and
the
reference
and
date
of
the
procedure
 
Certification
signature
of
SPM,
name,
title,
and
date
signed.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

150
B3­
12b(
2)
Characterization
Information
Summary
(
MP­
TRUW­
8.14,
Preparation
of
the
Waste
Stream
Profile
Forms)

The
Characterization
Information
Summary
includes
the
following
elements:

 
Data
reconciliation
with
DQOs
 
Headspace
gas
summary
data
listing
the
identification
numbers
of
samples
used
in
the
statistical
reduction,
the
maximum,
mean,
standard
deviation,
UCL90,
RTL,
and
associated
EPA
hazardous
waste
codes
that
must
be
applied
to
the
waste
stream.

 
Total
metal,
VOC,
and
SVOC
analytical
results
for
homogeneous
solids
and
soil/
gravel
(
if
applicable),
and
demonstration
that
control
charting
cannot
be
applied
effectively,
if
this
option
is
implemented.

 
TIC
listing
and
evaluation,
and
verification
that
AK
was
confirmed
 
Radiography
and
VE
summary
to
document
prohibited
items
are
not
present
and
to
confirm
AK,
and
documentation
and
justification
for
the
use
of
radiography
in
lieu
of
or
in
combination
with
visual
examination/
visual
examination
technique
for
newly
generated
waste.

 
A
complete
listing
of
container
identification
numbers
used
to
generate
the
WSPF,
cross
referenced
to
each
Batch
Data
Report
 
Complete
(
current
and
projected)
AK
summary
including
waste
stream
name
and
number,
point
of
generation,
waste
stream
volume,
generation
dates,
TRUCON
codes,
Summary
Category
Group,
Waste
Matrix
Code(
s),
and
Waste
Matrix
Code
Group,
other
TRU
Waste
Baseline
Inventory
Report
(
TWBIR)
information,
waste
stream
description,
areas
of
operation,
generating
processes,
RCRA
determinations
(
including
determination
for
ignitability,
corrosivity,
and
reactivity),
and
radionuclide
information,
all
references
used
to
generate
the
AK
summary,
and
any
other
information
required
by
Section
B4­
2b.

 
Certification
through
acceptable
knowledge
or
testing
and/
or
analysis
that
any
waste
assigned
the
hazardous
waste
number
of
U134
(
hydrofluoric
acid)
no
longer
exhibits
the
characteristic
of
corrosivity.
This
is
confirmed
by
assuring
that
no
liquid
is
present
in
U134
waste.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

151
B3­
12b(
3)
Waste
Stream
Characterization
Package
(
MP­
TRUW­
8.14,
Preparation
of
the
Waste
Stream
Profile
Forms)

The
Waste
Stream
Characterization
Package
consists
of
the
following:

 
Waste
Stream
Profile
Form
(
Section
B3­
12b(
1))

 
Accompanying
Characterization
Information
Summary
(
Section
B3­
12b(
2)

 
Complete
AK
summary
(
B3­
12b(
2))

 
Batch
Data
Reports
supporting
the
confirmation
of
AK
as
well
as
others
requested
by
the
CBFO.

 
Raw
analytical
data
requested
by
the
permit.

B3­
12b(
4)
WIPP
Waste
Information
System
(
WWIS)
Data
Reporting
The
WWIS
Data
Dictionary
contains
all
of
the
data
fields,
the
field
format,
and
the
limits
associated
with
the
data
as
established
by
the
WIPP­
WAP.
These
data
are
subject
to
edit
and
limit
checks
performed
automatically
by
the
database,
as
defined
in
the
WIPP
Waste
Information
System
User's
Manual
for
Use
by
Shippers/
Generators.
If
a
container
was
part
of
a
composite
headspace
gas
sample,
the
analytical
results
from
the
composite
sample
must
be
assigned
as
the
container
headspace
gas
data
results,
including
associated
TICs
for
every
waste
container
associated
with
the
composite
sample.
The
AMWTP
coordinates
the
data
transmission
with
WIPP
in
accordance
with
MP­
TRUW­
8.16,
WWIS
Data
Transfer.

B3­
13
Nonconformances
Work
activities
are
monitored
and
controlled
by
the
SPM
and
the
SQAO
which
includes
nonconformance
identification,
documentation,
and
reporting,
as
well
as
the
monitoring
of
NCRs
and
Corrective
Action
Reports
(
CARs).
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste,
discusses
specific
nonconformance
procedures
and
corrective
action
processes.

Nonconformances
are
uncontrolled
and
unapproved
deviations
from
an
approved
plan
or
procedure.
Nonconforming
items
and
activities
that
do
not
meet
the
WIPP­
WAP
requirements,
procurement
document
criteria,
or
approved
procedures
are
addressed
in
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions
and
are
discussed
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.
Nonconforming
items
are
marked,
tagged,
or
segregated
and
the
affected
personnel
notified.
Nonconforming
items
are
identified,
documented,
and
corrected
in
accordance
with
the
CBFO
QAPD.

Disposition
of
nonconforming
items
shall
be
identified
and
documented.
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions,
identifies
the
person(
s)
responsible
for
evaluating
and
dispositioning
nonconforming
items.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

152
Management
at
all
levels
will
foster
a
"
no­
fault"
attitude
to
encourage
the
identification
of
nonconforming
items
and
processes.
Nonconformances
may
be
detected
and
identified
by
anyone
performing
WIPP­
WAP
activities,
including
 
Project
staff
 
during
field
operations,
supervision
of
subcontractors,
data
validation
and
verification,
and
self­
assessment
 
Laboratory
staff
 
during
the
preparation
for
and
performance
of
laboratory
testing;
calibration
of
equipment;
QC
activities;
laboratory
data
review,
validation,
and
verification;
and
self­
assessment
 
QA
personnel
 
during
oversight
activities
or
audits
A
nonconformance
report
shall
be
prepared
for
each
nonconformance
identified.
Each
nonconformance
report
shall
be
initiated
by
the
individual(
s)
identifying
the
nonconformance.
The
nonconformance
report
shall
then
be
processed
by
knowledgeable
and
appropriate
personnel.
For
this
purpose,
a
nonconformance
report
including,
or
referencing
as
appropriate,
results
of
laboratory
analysis,
QC
rests,
audit
reports,
internal
memoranda,
or
letters
shall
be
prepared.
The
nonconformance
report
must
provide
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
the
data,
if
applicable
 
An
approval
signatures
specified
in
the
site
nonconformance
procedures
The
SQAO
oversees
the
nonconformance
reporting
process
and
is
responsible
for
identifying
and
tracking
all
nonconformances
and
report
this
information
to
CBFO.
Documentation
of
nonconformances
is
made
available
to
the
SPM,
who
is
responsible
for
notifying
project
personnel.
Completion
of
the
corrective
action
for
nonconformances
is
verified
by
the
SQAO.

The
CBFO
will
be
notified
within
five
(
5)
calendar
days
of
identification
that
a
non­
administrative
nonconformance
has
been
identified
at
the
SPM
signature
release
level
[(
i.
e.,
failure
to
meet
data
quality
objective
(
DQO)]
and
will
receive
a
nonconformance
report
within
thirty
(
30)
calendar
days
of
identification
of
the
incident.
A
corrective
action
process
will
be
implemented
and
the
NCR
will
be
resolved
prior
to
shipment.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
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Assurance
Project
Plan
(
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153
B3­
14
Special
Training
Requirements
and
Certifications
Before
performing
activities
that
affect
WIPP­
WAP
quality,
all
personnel
receive
indoctrination
into
the
applicable
scope,
purpose,
and
objectives
of
the
WIPP­
WAP
and
the
specific
QAOs
of
the
assigned
task.
Personnel
assigned
to
perform
activities
for
the
WIPP­
WAP
have
the
education,
experience,
and
training
applicable
to
the
functions
associated
with
the
work.
Evidence
of
personnel
proficiency
and
demonstration
of
competence
in
the
task(
s)
assigned
is
demonstrated
and
documented.
All
personnel
designated
to
work
on
specific
aspects
of
the
WIPP­
WAP
maintain
qualification
(
that
is,
training
and
certification)
throughout
the
duration
of
the
work.
Qualification
requirements
for
personnel
are
documented
in
Individual
Training
Plans
or
qualification
packages,
prepared
in
accordance
with
MP­
TRQP­
14.1,
Preparation
and
Administration
of
Individual
Training
Plans,
and
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.
Job
performance
is
evaluated
and
documented
at
periodic
intervals
to
ensure
personnel
maintain
proficiency
and
record
additions
to
training,
as
necessary
per
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.

Personnel
involved
in
WIPP­
WAP
activities
receive
continuing
training
to
ensure
job
proficiency
is
maintained.
Training
includes
both
education
in
principles
and
enhancement
of
skills.
Training
records
that
specify
the
scope
of
the
training,
the
date
of
completion,
and
documentation
of
job
proficiency
are
maintained
as
QA
Records.
Continuing
training
for
WIPP­
WAP
activities
is
addressed
in
MP­
RTQP­
14.19,
Training
Records
Administration.

Analytical
laboratory
line
management
ensures
analytical
personnel
are
qualified
to
perform
the
analytical
method(
s)
for
which
they
are
responsible
in
accordance
with
MP­
TRUW­
8.28,
Project
Level
Administrative
Controls
for
Analytical
Laboratory
Department.
The
minimum
qualifications
for
certain
specified
positions
for
the
WIPP­
WAP
are
summarized
in
Table
B3­
10.
MP­
RTQP­
14.19,
Training
Records
Administration,
contains
the
requirements
for
maintaining
records
of
the
qualification,
training,
and
demonstration
of
proficiency.
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification,
also
identifies
the
responsible
person(
s)
for
ensuring
all
personnel
maintain
proficiency
in
the
work
performed
and
identify
any
additional
training
that
may
be
required.

An
evaluation
of
personnel
qualifications
includes
comparing
and
evaluating
the
requirements
specified
in
the
job/
position
description
and
the
skills,
training,
and
experience
included
in
the
person's
current
resume.
This
evaluation
done
in
accordance
with
MP­
RTQP­
14.6,
Job
and
Training
Needs
Analysis,
is
also
performed
for
personnel
who
change
positions
because
of
a
transfer
or
promotion
as
well
as
personnel
assigned
to
shortterm
or
temporary
work
assignments
that
may
affect
the
quality
of
the
WIPP­
WAP.

B3­
15
Changes
To
Plans
and
Procedures
Controlled
changes
to
WIPP­
WAP
related
plans
or
procedures
are
managed
through
MP­
DOCS­
18.4,
Document
Control
and
MP­
TRUW­
8.28,
Project
Level
Administrative
Controls
for
Analytical
Laboratory
Department.
The
SPM
and
the
SQAO
shall
review
all
non­
administrative
changes
and
evaluate
whether
those
changes
could
impact
DQOs
specified
in
the
permit.
After
AMWTP
certification,
any
changes
to
WIPP­
WAP
related
plans
or
procedures
that
could
positively
or
negatively
impact
DQOs
(
i.
e.,
those
changes
that
require
prior
approval
of
the
CBFO
as
defined
in
Section
B5­
2)
shall
be
reported
to
the
CBFO
within
five
(
5)
days
of
identification
by
the
project
level
review.
The
CBFO
shall
send
NMED
a
monthly
summary
briefly
describing
the
changes
to
plans
and
procedures
identified
pursuant
to
this
section
during
the
previous
month.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

154
TABLE
B3­
1
WASTE
MATERIAL
PARAMETERS
AND
DESCRIPTIONS
Waste
Material
Parameter
Description
Iron­
based
Metal/
Alloys
Iron
and
steel
alloys
in
the
waste
excluding
the
waste
container
materials.

Aluminum­
based
Metals/
Alloys
Aluminum
or
aluminum­
based
alloys
in
the
waste
materials.

Other
Metals
All
other
metals
found
in
the
waste
materials
(
for
example,
copper,
lead,
zirconium,
tantalum,
etc.).

Other
Inorganic
Materials
Nonmetallic
inorganic
waste,
including
concrete,
glass,
firebrick,
ceramics,
sand,
and
inorganic
sorbents.

Cellulosics
Materials
generally
derived
from
high
polymer
plant
carbohydrates,
for
example,
paper,
cardboard,
wood,
cloth,
etc.

Rubber
Natural
or
man­
made
elastic
latex
materials,
for
example,
surgeon
gloves,
leaded
rubber
gloves,
etc.

Plastics
(
Waste
Materials)
Generally
man­
made
materials,
often
derived
from
petroleum
feedstock,
for
example,
polyethylene,
polyvinylchloride,
etc.

Organic
Matrix
Cemented
organic
resins,
solidified
organic
liquids
and
sludges.

Inorganic
Matrix
Any
homogeneous
materials
consisting
of
sludge,
or
aqueous­
based
liquids
solidified
with
cement,
calcium
silicate,
or
other
solidification
agents;
for
example,
waste
water
treatment
sludge,
cemented
aqueous
liquids,
and
inorganic
particulates,
etc.

Soils/
gravel
Generally
consists
of
naturally
occurring
soils
which
have
been
contaminated
with
inorganic
waste
materials.

Steel
(
Packaging
Materials)
208­
L
(
55­
gal)
drums.

Plastics
(
Packaging
Materials)
90
mil
polyethylene
drum
liner
and
plastic
bags.
Source:
DOE/
CAO­
94­
1005,
Waste
Isolation
Pilot
Plant
Transuranic
Waste
Baseline
Inventory
Report
(
BIR)
(
DOE/
CAO,
1995b)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

155
TABLE
B3­
2
GAS
VOLATILE
ORGANIC
COMPOUNDS
TARGET
ANALYTE
LIST
AND
QUALITY
ASSURANCE
OBJECTIVES
Compound
CAS
Number
Precisiona
(%
RSD
or
RPD)
Accuracya
(%
R)
MDL
b
(
ng)
PRQL
(
ppmv)
Completeness
(%)
Benzene
71­
43­
2
<
25
70­
130
10
10
90
Bromoform
75­
25­
2
<
25
70­
130
10
10
90
Carbon
tetrachloride
56­
23­
5
<
25
70­
130
10
10
90
Chlorobenzene
108­
90­
7
<
25
70­
130
10
10
90
Chloroform
67­
66­
3
<
25
70­
130
10
10
90
1,1­
Dichloroethane
75­
34­
3
<
25
70­
130
10
10
90
1,2­
Dichloroethane
107­
06­
2
<
25
70­
130
10
10
90
1,1­
Dichloroethylene
75­
35­
4
<
25
70­
130
10
10
90
cis­
1,2­
Dichloroethylene
156­
59­
2
<
25
70­
130
10
10
90
trans­
1,2­
Dichloroethylene
156­
60­
5
<
25
70­
130
10
10
90
Ethyl
benzene
100­
41­
4
<
25
70­
130
10
10
90
Ethyl
ether
60­
29­
7
<
25
70­
130
10
10
90
Methylene
chloride
75­
09­
2
<
25
70­
130
10
10
90
1,1,2,2­
Tetrachloroethane
79­
34­
5
<
25
70­
130
10
10
90
Tetrachloroethylene
127­
18­
4
<
25
70­
130
10
10
90
Toluene
108­
88­
3
<
25
70­
130
10
10
90
1,1,1­
Trichloroethane
71­
55­
6
<
25
70­
130
10
10
90
Trichloroethylene
79­
01­
6
<
25
70­
130
10
10
90
1,1,2­
Trichloro­
1,2,2­
trifluoroethane
76­
13­
1
<
25
70­
130
10
10
90
m­
Xylenec
108­
38­
3
<
25
70­
130
10
10
90
o­
Xylene
95­
47­
6
<
25
70­
130
10
10
90
p­
Xylenec
106­
42­
3
<
25
70­
130
10
10
90
Acetone
67­
64­
1
<
25
70­
130
150
100
90
Butanol
71­
36­
3
<
25
70­
130
150
100
90
Methanol
67­
56­
1
<
25
70­
130
150
100
90
Methyl
ethyl
ketone
78­
93­
3
<
25
70­
130
150
100
90
Methyl
isobutyl
ketone
108­
10­
1
<
25
70­
130
150
100
90
aCriteria
apply
to
PRQL
concentrations.
bValues
based
on
delivering
10
mL
to
the
analytical
system.
eThese
xylene
isomers
cannot
be
resolved
by
GC/
MS
and
are
reported
as
the
m­
p
xylene
total.

CAS
=
Chemical
Abstract
Service
%
RSD
=
Percent
relative
standard
deviation
RPD
=
Relative
percent
difference
%
R
=
Percent
recovery
MDL
=
Method
detection
limit
(
maximum
permissible
value),
for
GC/
MS
and
GC/
FID
equals
total
number
of
nanograms
delivered
to
the
analytical
system
per
sample.
PRQL
=
Program
required
quantitation
limit
(
parts
per
million/
volume
basis)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
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Plan
(
QAPjP)

156
TABLE
B3­
3
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
GAS
VOLATILE
ORGANIC
COMPOUND
ANALYSIS
QC
Sample
Minimum
Frequency
Acceptance
Criteria
Corrective
Action
a
Method
Performance
Samples
Seven
samples
initially
and
four
semiannually
Meet
method
QAOs
Repeat
until
acceptable
Laboratory
duplicates
or
on­
line
duplicates
One
per
analytical
batch
or
on­
line
duplicates
RPD
<
25
b
Nonconformance
if
RPD
>
25
Laboratory
blanks
or
on­
line
duplicates
Daily
before
sample
analysis
for
GC/
MS
and
GC/
FID.
Otherwise,
daily
prior
to
sample
analysis
and
one
(
1)
per
analytical
or
on­
line
Analyte
amounts
 
3
x
MDLs
for
GC/
MS
and
GC/
FID
Flag
data
if
analyte
>
3
x
MDLs
for
GC/
MS
and
GC/
FID
Laboratory
control
samples
or
on­
line
control
sample
One
per
analytical
batch
or
on­
line
batch
70­
130
%
R
Nonconformance
if
%
R
<
70
or
>
130
Blind­
audit
Samples
Samples
and
frequency
controlled
by
the
Gas
PDP
Plan
Specified
in
the
Gas
PDP
Plan
Specified
in
the
Gas
PDP
Plan
a.
Corrective
action
per
Section
B3­
13
when
final
reported
QC
do
not
meet
the
acceptance
criteria.
b.
Applies
only
to
concentrations
greater
than
the
PRQLs
listed
in
Table
B3­
2.

BFB
=
4­
bromofluorobenzene
MDL
=
Method
Detection
Limit
QAO
=
Quality
Assurance
Objective
PDP
=
Performance
Demonstration
Program
PRQL
=
Program
Required
Quantitation
Limit
pt
=
point
%
R
=
Percent
Recovery
RPD
=
Relative
Percent
Difference
RT
=
Retention
Time
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
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Plan
(
QAPjP)

157
TABLE
B3­
4
VOLATILE
ORGANIC
COMPOUNDS
TARGET
ANALYTE
LIST
AND
QUALITY
ASSURANCE
OBJECTIVES
Compound
CAS
Number
Precision
a
(%
RSD
or
RPD)
Accuracy
a
(%
R)
MDLb
(
mg/
kg)
PRQLb
(
mg/
kg)
Completeness
(%)
Benzene
71­
43­
2
<
45
37­
151
1
10
90
Bromoform
75­
25­
2
<
47
45­
169
1
10
90
Carbon
disulfide
75­
15­
0
<
50
60­
150
1
10
90
Carbon
tetrachloride
56­
23­
5
<
30
70­
140
1
10
90
Chlorobenzene
108­
90­
7
<
38
37­
160
1
10
90
Chloroform
67­
66­
3
<
44
51­
138
1
10
90
1,4­
Dichlorobenzenec
106­
46­
7
<
60
18­
190
1
10
90
ortho­
Dichlorobenzenec
95­
50­
1
<
60
18­
190
1
10
90
1,2­
Dichloroethane
107­
06­
2
<
42
49­
155
1
10
90
1,1­
Dichloroethylene
75­
35­
4
<
250
D­
234
d
1
10
90
trans­
1,
2­
Dichloroethylene
156­
60­
5
<
50
60­
151
1
10
90
Ethyl
benzene
100­
41­
4
<
43
37­
162
1
10
90
Methylene
chloride
75­
09­
2
<
50
D­
221
d
1
10
90
1,1,2,2­
Tetrachloroethane
79­
34­
5
<
55
46­
157
1
10
90
Tetrachloroethylene
127­
18­
4
<
29
64­
148
1
10
90
Toluene
108­
88­
3
<
29
47­
150
1
10
90
1,1,1­
Trichloroethane
71­
55­
6
<
33
52­
162
1
10
90
1,1,2­
Trichloroethane
79­
00­
5
<
38
52­
150
1
10
90
Trichloroethylene
79­
01­
6
<
36
71­
157
1
10
90
Trichlorofluoromethane
75­
69­
4
<
110
17­
181
1
10
90
1,1,2­
Trichloro
1,2,2­
trifluoroethane
76­
13­
1
<
50
60­
150
1
10
90
Vinyl
chloride
75­
01­
4
<
200
D­
251
d
1
4
90
meta­
Xylene
f,
g
108­
38­
3
<
50
60­
150
1
10
90
ortho­
Xyleneg
95­
47­
6
<
50
60­
150
1
10
90
para­
Xylenef,
g
106­
42­
3
<
50
60­
150
1
10
90
Acetone
67­
64­
1
<
50
60­
150
10
e
100
90
Butanol
71­
36­
3
<
50
60­
150
10
e
100
90
Ethyl
ether
60­
29­
7
<
50
60­
150
10
e
100
90
Isobutanol
78­
83­
1
<
50
60­
150
10
e
100
90
Methanol
67­
56­
1
<
50
60­
150
10
e
100
90
Methyl
ethyl
ketone
78­
93­
3
<
50
60­
150
10
e
100
90
Pyridine
c
110­
86­
1
<
50
60­
150
10
e
100
90
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

158
TABLE
B3­
4
VOLATILE
ORGANIC
COMPOUNDS
TARGET
ANALYTE
LIST
AND
QUALITY
ASSURANCE
OBJECTIVES
(
continued)

Footnotes
for
Table
B3­
4:

a.)
Applies
to
laboratory
control
samples,
and
laboratory
matrix
spikes.
If
a
solid
laboratory
control
sample
material
which
has
established
statistical
control
limits
is
used,
then
the
established
control
limits
for
that
material
should
be
used
for
accuracy
requirements.

b.
TCLP
MDL
and
PRQL
values
are
reported
in
units
of
mg/
l
and
limits
are
reduced
by
a
factor
or
20
c.)
Can
also
be
analyzed
as
an
SVOC.
If
analyzed
as
an
SVOC,
the
QAOs
of
Table
B3­
6
apply.

d.)
Detected;
result
must
be
greater
than
zero.

e.)
Estimate,
to
be
determined.

f.)
These
xylene
isomers
cannot
be
resolved
by
GC/
MS
and
are
reported
as
the
m/
p
xylene
total.

%
RSD
=
Percent
relative
standard
deviation
RPD
=
Relative
percent
difference
%
R
=
Percent
recovery
MDL
=
Method
detection
limit
(
maximum
permissible
value)
PRQL
=
Program
required
quantitation
limit;
calculated
from
the
TC
level
for
benzene
assuming
a
25
g
sample,
0.5
L
of
extraction
fluid,
and
100%
analyte
extraction
CAS
=
Chemical
Abstract
Service
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
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Assurance
Project
Plan
(
QAPjP)

159
TABLE
B3­
5
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
VOLATILE
ORGANIC
COMPOUND
ANALYSIS
QC
Sample
Minimum
Frequency
Acceptance
Criteria
Corrective
Action
a
Method
performance
samples
Seven
samples
initially
and
four
semi­
annually
Meet
Table
B3­
4
QAOs
Repeat
until
acceptable
Laboratory
duplicate
One
per
analytical
batch
Meet
Table
B3­
4
Precision
QAOs
Nonconformance
if
RPDs
>
values
in
Table
B3­
4
Laboratory
blanks
One
per
analytical
batch
Analyte
concentrations
 
3
x
MDLs
Nonconformance
if
analyte
concentrations
>
3
x
MDLs.
Matrix
spikes
One
per
analytical
batch
Meet
Table
B3­
4
accuracy
QAOs
Flag
the
data
with
a
"
Z"
if
matrix­
related
exceedence;
otherwise
issue
a
nonconformance
if
%
R
is
outside
the
range
specified
in
Table
B3­
4.
Matrix
spike
duplicatesb
One
per
analytical
batch
Meet
Table
B3­
4
accuracy
and
precision
QAOs
Flag
the
data
with
a
"
Z"
if
matrix­
related
exceedence;
otherwise
issue
a
nonconformance
if
RPDs
>
values
and
%
Rs
outside
the
range
in
Table
B3­
4.
Laboratory
control
samples
One
per
analytical
batch
Meet
Table
B3­
4
accuracy
QAOs
Nonconformance
if
%
R
<
80
or
>
120
°
.
C
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

160
TABLE
B3­
5
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
VOLATILE
ORGANIC
COMPOUND
ANALYSIS
(
continued)

BFB
Tune
every
12
hours
5­
pt.
Initial
Calibration
initially,
and
as
needed
Abundance
criteria
met
per
method
Calibrate
per
SW­
846
Method
requirements:
%
RSD
for
calibration
check
compounds
(
CCCs)
 
30,
%
RSD
for
all
other
compounds
<
15%.
Average
relative
response
factor
(
RRF)
used
if
%
RSD
 
15;
linear
or
quadratic
regression
used
if
%
RSD
>
15;
r
 
0.990
if
using
alternative
curve
System
Performance
Check
Compound
(
SPCC)
minimum
RRF
per
SW­
846
Method;
RRF
for
all
other
compounds
 
0.01
Repeat
until
acceptable
GC/
MS
Calibration
Continuing
calibration
every
12
hours
%
D
 
20
for
CCC
SPCC
minimum
RRF
per
SW­
846
Method;
RRF
for
all
other
compounds
 
0.01
RT
for
internal
standard
must
be
±
30
seconds
from
last
daily
calibration,
internal
standard
area
count
must
be
>
50%
and
<
200%
of
last
daily
calibration
Repeat
until
acceptable
3­
pt.
Initial
Calibration
initially
and
as
needed
Correlation
coefficient
 
0.99
or
%
RSD
for
response
factors
 
20
for
all
analytes
Repeat
until
acceptable
GC/
FID
Calibration
Continuing
calibration
every
12
hours
%
D
or
%
Drift
for
all
analytes
 
15
of
expected
values
RT
±
3
standard
deviations
from
initial
RT
calibration
per
applicable
SW­
846
method
Repeat
until
acceptable
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

161
TABLE
B3­
5
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
VOLATILE
ORGANIC
COMPOUND
ANALYSIS
(
continued)
Surrogate
compounds
Each
analytical
sample
Average
%
R
from
minimum
of
30
samples
for
a
given
matrix
±
3
standard
deviations
Nonconformance
if
%
R
is
less
than
(
average
%
R­
3
standard
deviations)
or
greater
than
(
average
%
R+
3
standard
deviations).
Blind­
audit
samples
Samples
and
frequency
controlled
by
the
solid
PDP
Plan
Specified
in
the
Solid
PDP
Plan
Specified
in
the
Solid
PDP
Plan
a.
Corrective
Action
per
Section
B3­
13
when
final
reported
QC
samples
do
not
meet
the
acceptance
criteria.
Nonconformances
do
not
apply
to
matrix
related
exceedences.

b.
Duplicate
requirement
may
be
satisfied
using
matrix
spike
duplicate;
acceptance
criteria
applies
only
to
concentrations
greater
than
the
PRQLs
listed
in
Table
B3­
4.

c.
Nonconformance
needed
only
if
accuracy
requirements
in
Table
B3­
4
not
achieved.

See
Section
E­
1
for
acronyms.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

162
TABLE
B3­
6
SEMI­
VOLATILE
ORGANIC
COMPOUND
TARGET
ANALYTE
LIST
AND
QUALITY
ASSURANCE
OBJECTIVES
Compound
CAS
Number
Precisiona
(%
RSD
or
RPD)
Accuracya
(%
R)
MDLb
(
mg/
kg)
PRQLb
(
mg/
kg)
Completeness
%

Cresols
1319­
77­
3
<
50
25­
115
5
40
90
1,4­
Dichlorobenzenec
106­
46­
7
<
86
20
­
124
5
40
90
ortho­
Dichlorobenzenec
95­
50­
1
<
64
32
­
129
5
40
90
2,4­
Dinitrophenol
51­
28­
5
<
119
D­
172e
5
40
90
2,4­
Dinitrotoluene
121­
14­
2
<
46
39
­
139
0.3
2.6
90
Hexachlorobenzene
118­
74­
1
<
319
D­
152e
0.3
2.6
90
Hexachloroethane
67­
72­
1
<
44
40
­
113
5
40
90
Nitrobenzene
98­
95­
3
<
72
35
­
180
5
40
90
Polychlorinated
Biphenyls
(
PCBs)

Aroclor
1016d
12674­
11­
2
<
33
50
­
114
5
40
90
Aroclor
1221d
11104­
28­
2
<
110
15
­
178
5
40
90
Aroclor
1232d
11141­
16­
5
<
128
10
­
215
5
40
90
Aroclor
1242d
53469­
21­
9
<
49
39
­
150
5
40
90
Aroclor
1248d
12672­
29­
6
<
55
38
­
158
5
40
90
Aroclor
1254d
11097­
69­
1
<
62
29
­
131
5
40
90
Aroclor
1260d
11096­
82­
5
<
56
8
­
127
5
40
90
Pentachlorophenol
87­
86­
5
<
128
14
­
176
5
40
90
Pyridinec
110­
86­
1
<
50
25­
115
5
40
90
a.
Applies
to
laboratory
control
samples,
and
laboratory
matrix
spikes.
If
a
solid
laboratory
control
sample
material
which
has
established
statistical
control
limits
is
used,
then
the
established
control
limits
for
that
material
should
be
used
for
accuracy
requirements.
b.
TCLP
MDL
and
PRQL
values
are
reported
in
units
of
mg/
l
and
limits
are
reduced
by
a
factor
of
20
c.
Can
also
be
analyzed
as
a
VOC
d.
PCBs;
required
only
for
Waste
Matrix
Code
S3220
(
organic
sludges)
or
as
indicated
by
AK.
e.
Detected;
result
must
be
greater
than
zero
MDL
=
Method
detection
limit
(
maximum
permissible
value)
PRQL
=
Program
required
quantitation
limit;
calculated
from
the
TC
level
for
nitrobenzene
assuming
a
100
g
sample,
0.5
gal
(
2
L)
of
extraction
fluid,
and
100%
analyte
extraction
(
mg/
kg)
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

163
TABLE
B3­
7
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
SEMI­
VOLATILE
ORGANIC
COMPOUNDS
ANALYSIS
QC
Sample
Minimum
Frequency
Acceptance
Criteria
Corrective
Action
a
Method
Performance
Samples
Seven
samples
initially
and
four
semiannually
Meet
Table
B3­
6
QAOs
Repeat
until
acceptable
Laboratory
duplicate
One
per
analytical
batch
Meet
Table
B3­
6
Precision
QAOs
Nonconformance
if
RPDs
>
values
in
Table
B3­
6
Laboratory
blanks
One
per
analytical
batch
Analyte
concentrations
 
3
x
MDLs
Nonconformance
if
analyte
concentrations
>
3
x
MDLs
Matrix
spikes
One
per
analytical
batch
Meet
Table
B3­
6
accuracy
QAOs
Nonconformance
if
RPDs
>
values
and
%
Rs
outside
the
range
specified
in
Table
B3­
6.
Decafluorotriphenylphosphine
(
DFTPP)
Tune
every
12
hours
5­
pt.
Initial
Calibration
initially,
and
as
needed
Abundance
criteria
met
per
method
Calibrate
per
SW­
846
Method
requirements
%
RSD
for
CCC
 
30,
RRF
used
if
%
RSD
 
15,
use
linear
or
quadratic
regression
if
%
RSD
>
15;
r
 
0.990
if
using
alternative
curve
System
Performance
Check
Compound
(
SPCC)
minimum
RRF
per
SW­
846
Method;
RRF
for
all
other
compounds
 
0.01
Repeat
until
acceptable
GC/
MS
Calibration
Continuing
calibration
every
12
hours
%
D
 
20
for
CCC
SPCC
minimum
RRF
per
SW­
846
Method;
RRF
for
all
other
compounds
 
0.01
RT
for
internal
standard
must
be
±
30
seconds
from
last
daily
calibration,
internal
standard
area
count
must
be
>
50
%
and
<
200%
of
last
daily
calibration
Repeat
until
acceptable
3­
pt.
Initial
Calibration
initially
and
as
needed
Correlation
coefficient
 
0.990
or
%
RSD
<
20
for
all
analytes
Repeat
until
acceptable
GC/
ECD
Calibration
Continuing
calibration
every
12
hours
%
D
or
%
Drift
for
all
analytes
 
15
of
expected
values
RT
±
3
standard
deviations
from
initial
RT
calibration
per
applicable
SW­
846
method
Repeat
until
acceptable
Matrix
spikes
duplicates
b
One
per
analytical
batch
Meet
Table
B3­
6
accuracy
and
precision
QAOs
Nonconformance
if
RPDs
or
%
Rs
are
outside
the
ranges
specified
in
Table
B3­
6.
Laboratory
control
samples
One
per
analytical
batch
Meet
Table
B3­
6
accuracy
QAOs
Nonconformance
if
%
R
<
80
or
>
120C
Surrogate
compounds
Each
analytical
sample
Average
%
R
from
minimum
of
30
samples
for
a
given
matrix
±
3
standard
deviations
Nonconformance
if
%
R
is
less
than
(
average
%
R­
3
standard
deviations)
or
greater
than
(
average
%
R+
3
standard
deviations).
Blind­
audit
samples
Samples
and
frequency
controlled
by
the
Solid
PDP
Plan
Specified
in
the
Solid
PDP
Plan
Specified
in
the
Solid
PDP
Plan
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

164
TABLE
B3­
7
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
SEMI­
VOLATILE
ORGANIC
COMPOUNDS
ANALYSIS
(
continued)

a.
Corrective
Action
per
Section
B3­
13
when
final
reported
QC
samples
do
not
meet
the
acceptance
criteria.
Nonconformances
do
not
apply
to
matrix
related
exceedences.
b.
Duplicate
requirement
may
be
satisfied
using
matrix
spike
duplicate;
acceptance
criteria
apply
only
to
concentrations
greater
than
the
PRQLs
in
Table
B3­
6.
c.
Nonconformance
needed
only
if
accuracy
requirements
in
Table
B3­
6
not
achieved.
See
Section
E­
1
for
acronyms.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

165
TABLE
B3­
8
METALS
TARGET
ANALYTE
LIST
AND
QUALITY
ASSURANCE
OBJECTIVES
Analyte
CAS
Number
Precision
(%
RSD
OR
RPD)
a
Accuracy
(%
R)
b
PRDLc
(
µ
g/
L)
PRQLd
(
mg/
kg)
Completeness
(%)

Antimony
7440­
36­
0
 
30
80­
120
100
100
90
Arsenic
7440­
38­
2
 
30
80­
120
100
100
90
Barium
7440­
39­
3
 
30
80­
120
2000
2000
90
Beryllium
7440­
41­
7
 
30
80­
120
100
100
90
Cadmium
7440­
43­
9
 
30
80­
120
20
20
90
Chromium
7440­
47­
3
 
30
80­
120
100
100
90
Lead
7439­
92­
1
 
30
80­
120
100
100
90
Mercury
7439­
97­
6
 
30
80­
120
4.0
4.0
90
Nickel
7440­
02­
0
 
30
80­
120
100
100
90
Selenium
7782­
49­
2
 
30
80­
120
20
20
90
Silver
7440­
22­
4
 
30
80­
120
100
100
90
Thallium
7440­
28­
0
 
30
80­
120
100
100
90
Vanadium
7440­
62­
2
 
30
80­
120
100
100
90
Zinc
7440­
66­
6
 
30
80­
120
100
100
90
a.
 
30
%
control
limits
apply
when
sample
and
duplicate
concentrations
are
 
10
x
IDL
for
ICP­
AES
and
AA
techniques.
If
less
than
these
limits,
the
absolute
difference
between
the
two
values
shall
be
less
than
or
equal
to
the
PRQL.
b.
Applies
to
laboratory
control
samples
and
laboratory
matrix
spikes.
If
a
solid
laboratory
control
sample
material
that
has
established
statistical
control
limits
is
used,
then
the
established
control
limits
for
that
material
should
be
used
for
accuracy
requirements.
c.
Program
Required
Detection
Limit
(
PRDL)
set
such
that
it
is
a
factor
of
10
below
the
PRQL
for
100%
solid
samples,
assuming
a
100
x
dilution
during
digestion.
d.
TCLP
PRQL
values
are
responded
in
units
of
mg/
l
and
limits
are
reduced
by
a
factor
of
20.
See
Section
E­
1
for
acronyms.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

166
TABLE
B3­
9
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
METALS
ANALYSIS
QC
Samples
Minimum
Frequency
Acceptance
criteria
Corrective
Actions
a
Method
performance
samples
Seven
(
7)
samples
initially,
and
four
(
4)
semiannually
Meet
Table
B3­
8
QAOs
Repeat
until
acceptable
Laboratory
blanks
One
(
1)
per
analytical
batch
<
3
x
IDL
(<
5
x
IDL
for
ICP­
MS)
Redigest
and
reanalyze
any
samples
with
analyte
concentrations
which
are
 
10
×
blank
value
and
 
0.5
×
PRQL
Matrix
spikes
One
(
1)
per
analytical
batch
Meet
Table
B3­
8
accuracy
QAOs
Nonconformance
if
%
R
outside
the
range
specified
in
Table
B3­
8.
Matrix
spike
duplicates
One
(
1)
per
analytical
batch
Meet
Table
B3­
8
accuracy
and
precision
QAOs.
Nonconformance
if
RPDs
>
values
and
%
Rs
outside
range
specified
in
Table
B3­
8
Initial
Calibration
1
blank,
1
standard
(
ICP,
ICP­
MS),
3
standard,
1
blank
(
GFAA,
FLAA),
5
standard,
1
blank
(
CVAA,
HAA)
Daily
90­
110
%
R
(
80­
120%
for
CVAA,
GFAA,
HAA,
FLAA)
for
initial
calibration
verification
solution.
Regression
coefficient
 
0.995
for
FLAA,
CVA,
GFAA,
MAA
Correct
problem
and
recalibrate;
repeat
initial
calibration
Continuing
calibration
Every
10
samples
and
beginning
and
end
of
run
90­
110
%
for
continuing
calibration
verification
solution.
(
80­
120%
for
CVAA,
GFAA,
HAA,
FLAA)
Correct
problem
and
recalibrate;
rerun
last
10
samples
Serial
dilution
(
ICP)
One
per
analytical
batch
5
×
dilution
must
be
 
10
%
D
of
initial
value
for
sample
>
50
×
IDL
Flag
Data
with
a
"
Z"
if
>
10%
D
and
>
50
×
IDL
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

167
TABLE
B3­
9
SUMMARY
OF
LABORATORY
QUALITY
CONTROL
SAMPLES
AND
FREQUENCIES
FOR
METALS
ANALYSIS
(
continued)

QC
Samples
Minimum
Frequency
Acceptance
criteria
Corrective
Actions
a
Interference
Correction
Verification
(
ICP,
ICP­
MS)
Beginning
and
end
of
run
or
every
12
hours
(
8
for
ICP)
whichever
is
more
frequent
80­
120%
recovery
for
analytes
Note:
Acceptance
Criteria
and
Corrective
Action
apply
only
if
interferents
found
in
samples
at
levels
greater
than
ICS
A
Solution
Correct
problem
and
recalibrate,
nonconformance
if
not
corrected
Laboratory
Control
Samples
One
(
1)
per
analytical
batch
Table
B3­
8
accuracy
QAOs
Redigest
and
reanalyze
for
affected
analytes;
nonconformance
if
not
reanalyzed
Blind­
audit
samples
Samples
and
frequency
controlled
by
the
Solid
PDP
Plan
Specified
in
the
Solid
PDP
Plan
Specified
in
the
Solid
PDP
Plan
a.
Corrective
action
per
Section
B3­
13
when
final
reported
QC
samples
do
not
meet
acceptance
criteria.
Nonconformance
do
not
apply
to
matrix
related
exceedences.
b.
Applies
only
to
concentrations
greater
than
the
PRQLs
listed
in
Table
B3­
8
See
Section
E­
1
for
acronyms.

IDL
=
Instrument
Detection
Limit
PDP
=
Performance
Demonstration
Program
PRQL
=
Program
Required
Quantitation
Limit
%
R
=
Percent
Recovery
RPD
=
Relative
Percent
Difference
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

168
TABLE
B3­
10
MINIMUM
TRAINING
AND
QUALIFICATION
Personnel
Requirementsa
Radiography
Operatorsc
Site­
specific
training
based
on
Waste
Matrix
Codes
and
waste
material
parameters;
requalification
every
two
years.

GC
Technical
Supervisorsb
GC
Operatorsc
B.
S.
or
equivalent
experience
and
six
months
previous
applicable
experience.

GC/
MS
Operatorsc
B.
S.
or
equivalent
experience
and
one
year
independent
spectral
interpretation
or
demonstrated
expertise.
GC/
MS
Technical
Supervisors
B.
S.
or
equivalent
experience
and
one
year
applicable
experience.

Atomic
Absorption
Spectroscopy
Technical
Supervisorsb
Atomic
Absorption
Spectroscopy
Operatorsc
B.
S.
or
equivalent
experience
and
one
year
applicable
experience.

Atomic
Emission
Spectroscopy
Operatorsc
B.
S.
or
equivalent
experience
and
one
year
applicable
experience.

Atomic
Emission
Spectroscopy
Technical
Supervisorsb
B.
S.
and
specialized
training
in
Atomic
Emission
Spectroscopy
and
two
years
applicable
experience.

a.
Based
on
requirements
contained
in
US
EPA
Contract
Laboratory
Program
Statement
of
Work
for
Organics
Analysis
(
Document
Number
OLM
01.0)
and
Statement
of
Work
for
Inorganics
Analysis
(
Document
Number
ILM
03.0).

b.
Technical
Supervisors
are
those
persons
responsible
for
the
overall
technical
operation
and
development
of
a
specific
laboratory
technique.

c.
Operators
are
those
persons
responsible
for
the
actual
operation
of
analytical
equipment.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

169
TABLE
B3­
11
TESTING
BATCH
DATA
REPORT
CONTENTS
Required
Information
Radiography
Visual
Examination
as
QC
Check
on
Radiography
Visual
Verification
of
Acceptable
Knowledge
Comment
Batch
Data
Report
Date
X
X
X
Batch
number
X
X
X
Waste
container
number
X
X
X
Waste
stream
name
and/
or
number
O
O
O
Waste
Matrix
Code
X
X
X
Summary
Category
Group
included
in
waste
matrix
code
Implementing
procedure
(
specific
version
used)
X
X
X
If
procedure
cited
contains
more
than
one
method,
the
method
used
must
also
be
cited.
Can
use
revision
number,
date,
or
other
means
to
track
specific
version
used.

Container
type
O
O
O
Drums,
Standard
Waste
Box,
Ten
Drum
Overpack,
etc.

Videotape
reference
X
X
Reference
to
Videotape(
s)
applicable
to
each
container.

Imaging
check
O
Camera
check
O
Audio
check
O
O
QC
check
of
scales
O
O
Available
documented
evidence
calibrated
scale(
s)
were
used.
Only
applicable
if
items
are
weighed
during
the
visual
examination.

QC
documentation
X
X
X
Description
of
liners
and
layers
of
confinement
(
if
possible)
X
X
X
Indication
of
vented
rigid
liners
X
X
X
Only
required
for
containers
with
rigid
liners.
If
radiography
is
used
to
verify,
then
include
in
Testing
Batch
Data
Report.

Description
of
container
contents
X
X
X
Provide
enough
detail
for
verification
of
estimated
weights
for
the
12
waste
material
parameters.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

170
Required
Information
Radiography
Visual
Examination
as
QC
Check
on
Radiography
Visual
Verification
of
Acceptable
Knowledge
Comment
Verification
that
the
physical
form
matches
the
waste
stream
description
and
Waste
Matrix
Code.
X
X
X
Summary
Category
Group
included
in
Waste
Matrix
Code.

Indication
of
sealed
containers
>
4L
X
X
X
Amount
of
free
liquids
X
X
X
Estimated
weights
for
the
12
waste
material
parameters
X
X
X
Table
B3­
1
lists
waste
material
parameters.

Container
gross
weight
X
X
X
Container
empty
weight
O
O
O
Established,
documented
empty
container
weights
can
be
used.

Comments
X
X
X
Reference
to
or
copy
of
associated
NCRs,
if
any
X
X
X
Copies
of
associated
NCRs
must
be
available.

Visual
examination
expert
decisions
X
Only
applicable
if
visual
examination
expert
is
consulted
during
visual
examination.

Verify
absence
of
prohibited
items
X
X
X
Operator
signature
and
date
of
test
X
X
X
2
signatures
required
for
Visual
Verification
of
Acceptable
Knowledge
Signature
of
visual
examination
expert
and
date
X
When
visual
examination
expert
is
consulted.

Data
review
checklists
X
X
X
All
data
checklists
will
be
identified
LEGEND:
X
 
Required
in
Batch
Data
Report.
O
 
Information
must
be
documented
and
traceable;
inclusion
in
Batch
Data
Report
is
optional.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

171
TABLE
B3­
12
SAMPLING
BATCH
DATA
REPORT
CONTENTS
Required
Information
Headspace
Gas
Solid
Sampling
Comment
Batch
Data
Report
Date
X
X
Batch
number
X
X
Waste
stream
name
and/
or
number
O
O
Waste
Matrix
Code
X
Summary
Category
Group
included
in
Waste
Matrix
Code
Procedure
(
specific
version
used)
X
X
If
procedure
cited
contains
more
than
one
method,
the
method
used
must
also
be
cited.
Can
use
revision
number,
date,
or
other
means
to
track
specific
version
used.

Container
number
X
X
Container
type
O
O
Drums,
Standard
Waste
Box,
Ten
Drum
Overpack,
etc.

Sample
matrix
and
type
X
X
Analyses
requested
and
laboratory
X
X
Point
of
origin
for
sampling
X
X
Location
where
sample
was
taken
(
e.
g.,
building
number,
room)

Sample
number
X
X
Sample
Size
X
X
Sample
location
X
X
Location
within
container
where
sample
is
taken.
(
For
HSG,
specify
what
layer
of
confinement
was
sampled.
For
solids,
physical
location
within
container.)

Sample
preservation
X
X
Person
collecting
sample
X
X
Person
attaching
custody
seal
O
O
May
or
may
not
be
the
same
as
the
person
collecting
the
sample
Chain
of
Custody
record
X
X
Original
or
copy
is
allowed
Sampling
equipment
numbers
X
X
For
disposable
equipment,
a
reference
to
the
lot
Cross­
reference
of
sampling
equipment
numbers
with
associated
cleaning
batch
numbers
O
X
As
applicable
to
the
equipment
used
for
the
sampling.
For
disposable
equipment,
a
reference
to
the
lot
and
procurement
records
to
support
cleanliness
is
sufficient
Drum
age
X
Must
include
all
supporting
determinative
information,
including
but
not
limited
to
packaging
date,
equilibrium
start
time,
storage
temperature,
and
sampling
date/
time.
If
Scenario
3
is
used,
the
packaging
configuration,
filter
diffusivity,
liner
presence/
absence,
and
rigid
liner
vent
hole
diameter
used
in
determining
the
DAC
must
be
documented.
If
Scenario
1
and
2
are
used
together,
the
filter
diffusivity
and
rigid
liner
vent
hole
diameter
used
in
determining
the
DAC
must
be
documented.
If
default
values
are
used
for
retrievable
stored
waste,
these
values
must
clearly
be
identified
as
such.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

172
Equilibration
time
X
Verification
of
rigid
liner
venting
X
Only
applicable
to
containers
with
rigid
liners
Verification
that
sample
volume
taken
is
small
in
comparison
to
the
available
volume
X
Must
include
headspace
gas
volume
when
it
can
be
estimated
Scale
Calibration
O
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

173
TABLE
B3­
12
(
continued)
SAMPLING
BATCH
DATA
REPORT
CONTENTS
Required
Information
Headspace
Gas
Solid
Sampling
Comment
Depth
of
waste
X
For
newly
generated
waste,
if
a
sampling
method
other
than
coring
is
used,
this
is
replaced
by
documentation
that
a
representative
sample
has
been
taken.

Calculation
of
core
recovery
X
For
newly
generated
waste,
if
a
sampling
method
other
than
coring
is
used,
this
is
replaced
by
documentation
that
a
representative
sample
has
been
taken.

Collocated
core
description
X
For
newly
generated
waste,
if
a
sampling
method
other
than
coring
is
used,
this
is
replaced
by
documentation
that
a
QC
sample
has
been
taken.

Time
between
coring
and
subsampling
X
Only
applicable
to
coring.

OVA
calibration
and
reading
O
Only
applicable
to
manifold
systems.
Must
be
done
in
accordance
with
manufacturer's
specifications
Field
Records
X
X
Must
contain
the
following
as
applicable
to
the
sampling
method
used:
Collection
problems,
Sequence
of
sampling
collection,
Inspection
of
the
solids
sampling
area,
Inspection
of
the
solids
sampling
equipment,
Coring
tool
test,
random
location
of
sub­
sample,
canister
pressure,
and
ambient
temperature
and
pressure.

Reference
to
or
copy
of
associated
NCRs,
if
any
X
X
Copies
of
associated
NCRs
must
be
available.

Operator
Signature
and
date
and
time
of
sampling
X
X
Data
review
checklists
X
X
All
data
reviews
checklists
will
be
identified.

LEGEND:
X
 
Required
in
Batch
Data
Report.
O
 
Information
must
be
documented
and
traceable;
inclusion
in
Batch
Data
Report
is
optional.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

174
TABLE
B3­
13
ANALYTICAL
BATCH
DATA
REPORT
CONTENTS
Required
Information
Headspace
Gas
Solid
Sampling
Comment
Batch
Data
Report
Date
X
X
Batch
number
X
X
Sample
numbers
X
X
QC
designation
for
sample
X
X
Implementing
procedure
(
specific
version
used)
X
X
If
procedure
cited
contains
more
than
one
method,
the
method
used
must
also
be
cited.
Can
use
revision
number,
date,
or
other
means
to
track
specific
version
used.

QC
sample
results
X
X
Sample
data
forms
X
X
Form
should
contain
reduced
data
for
target
analytes
and
TICs
Chain
of
custody
X
X
Original
or
copy
Gas
canister
tags
X
Original
or
copy
Sample
preservation
X
X
Holding
time
X
Cross­
reference
of
field
numbers
to
laboratory
sample
numbers
X
X
Date
and
time
analyzed
X
X
Confirmation
of
spectra
used
for
results
O
O
Analyst
must
qualitatively
evaluate
the
validity
of
the
results
based
on
the
spectra,
can
be
implemented
as
a
check
box
for
each
sample
TIC
evaluation
X
X
Reporting
flags,
if
any
X
X
Table
B3­
14
lists
applicable
flags
Report
narrative
X
X
Reference
to
or
copy
of
associated
NCRs,
if
any
X
X
Copies
of
associated
NCRs
must
be
available.

Operator
signature
and
analysis
date
X
X
Data
review
checklists
X
X
All
data
review
checklists
will
be
identified
LEGEND:
X
 
Required
in
Batch
Data
Report.

O
 
Information
must
be
documented
and
traceable;
inclusion
in
Batch
Data
Report
is
optional.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

175
TABLE
B3­
14
DATA
REPORTING
FLAGS
Data
Flag
Indicator
B
Analyte
detected
in
blank
(
Organics/
Headspace
gases)

B
Analyte
blank
concentration
greater
than
or
equal
to
20
percent
of
sample
concentration
prior
to
dilution
corrections
(
Metals)

E
Analyte
exceeds
calibration
curve
(
Organics/
Headspace
gases)

J
Analyte
less
than
PRQL
but
greater
than
or
equal
to
MDL
(
Organics/
Headspace
gases)

J
Analyte
greater
than
or
equal
to
IDL
but
less
than
5
times
the
IDL
before
dilution
correction
(
Metals)

U
Analyte
was
not
detected
and
value
is
reported
as
the
MDL
(
IDL
for
Metals)

D
Analyte
was
quantitated
from
a
secondary
dilution,
or
reduced
sample
aliquot
(
Organics/
Headspace
gases)

Z
One
or
more
QC
samples
do
not
meet
acceptance
criteria
H
Holding
time
exceeded
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

176
B4
TRU
Waste
Characterization
Using
Acceptable
Knowledge
B4­
1
Introduction
The
RCRA
regulations
codified
in
40
CFR
Parts
260
through
265,
268,
and
270,
and
the
New
Mexico
Hazardous
Waste
Management
Regulations
in
Title
20
New
Mexico
Administrative
Code,
Chapter
4,
Part
1,
(
20
NMAC
4.1)
Subparts
I
through
VI,
Subpart
VIII,
and
Subpart
IX,
authorize
the
use
of
AK
in
appropriate
circumstances
by
waste
generators,
or
treatment,
storage,
or
disposal
facilities
to
characterize
hazardous
waste.
AK
is
described
in
Waste
Analysis:
EPA
Guidance
Manual
for
Facilities
That
Generate,
Treat,
Store
and
Dispose
of
Hazardous
Waste.
AK,
as
an
alternative
to
sampling
and
analysis,
can
be
used
to
meet
all
or
part
of
the
waste
characterization
requirements
under
the
RCRA.

AK
includes
a
number
of
techniques
used
to
characterize
transuranic
(
TRU)
waste,
such
as
process
knowledge,
records
of
analysis
acquired
prior
to
RCRA,
and
other
supplemental
sampling
and
analysis
data
(
EPA,
1994).
Radiography
and/
or
visual
examination,
headspace
gas
sampling
and
analysis,
and
homogeneous
waste
sampling
and
analysis
(
specified
in
Permit
Attachment
B
1)
are
used
to
acquire
supplemental
sampling
and
analysis
data
to
meet
the
requirements
of
the
WAP.
AK
is
used
in
TRU
waste
characterization
activities
in
three
ways:

 
To
delineate
TRU
waste
streams.

 
To
assess
if
TRU
heterogeneous
debris
wastes
exhibit
a
toxicity
characteristic
(
20
NMAC
4.1.200,
incorporating
40
CFR
§
261.24).

 
To
assess
if
TRU
wastes
are
listed
(
20
NMAC
4.1.200,
incorporating
40
CFR
§
261.31).

Sampling
and
analysis
is
performed
to
confirm
AK
and
to
update
and
modify
initial
AK
assessments.
Sampling
and
analysis
includes
radiography,
visual
examination,
headspace
gas,
and
homogeneous
waste
sampling
and
analysis.
TRU
waste
streams
undergo
applicable
provisions
of
the
AK
process
prior
to
management,
storage,
or
disposal
of
the
waste
at
WIPP.

B4­
2
Acceptable
Knowledge
Documentation
The
AMWTP
AK
information
progresses
from
general
facility
information
(
TRU
waste
management
program
information)
to
the
more
detailed
waste­
specific
information
(
TRU
waste
stream
information).
This
AK
information
applies
at
AMWTP
to
both
the
retrievably
stored
and
newly
generated
waste
streams.
The
process
used
to
control
and
develop
the
general
facility
and
waste
stream
information
is
described
in
MPTRUW
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

177
The
following
sections
include
the
information
required
for
characterization
of
TRU
waste
using
AK.
The
AMWTP
will
supplement
the
required
AK
records
with
additional
information
as
necessary.
If
the
required
information
is
not
available
for
a
particular
waste,
supplemental
information
is
obtained.
In
this
case,
the
waste
is
characterized
as
newly
generated
waste,
and
the
characterization
process
for
newly
generated
waste
is
presented
in
Section
B­
3d(
l)
of
this
document.

B4­
2a
Required
TRU
Waste
Management
Program
Information
TRU
mixed
waste
management
program
information
clearly
defines
waste
categorization
schemes
and
terminology,
provides
a
breakdown
of
the
types
and
quantities
of
TRU
mixed
waste
that
are
generated
and
stored
at
the
AMWTP,
and
describes
how
waste
is
tracked
and
managed
at
the
AMWTP,
including
historical
and
current
operations.
Information
related
to
TRU
mixed
waste
certification
procedures
and
the
types
of
documentation
(
e.
g.,
waste
profile
forms)
used
to
summarize
AK
is
also
provided.

The
AMWTP
will
be
involved
in
characterizing
stored
waste
generated
at
multiple
facilities
and
creating
newly
generated
waste
in
the
AMWTP
processing
facility.
For
each
generator
of
waste
the
following
general
facility
information
shall
be
maintained:

 
A
map
of
the
site
with
the
areas
and
facilities
involved
in
TRU
waste
generation,
treatment,
and
storage
identified.

 
Facility
mission
description
as
related
to
TRU
waste
generation
and
management.

 
Description
of
the
operations
that
generated
TRU
waste
at
the
site.

 
Description
of
waste
identification
and
category
schemes
used
at
the
site
(
IDC,
control
code).

 
Types
and
quantities
of
TRU
waste
generated,
including
historical
generation
through
future
projections.

 
Correlation
of
waste
streams
generated
for
the
same
building
and
process
as
appropriate
(
e.
g.,
sludge,
combustibles,
metals,
and
glass).

 
Waste
certification
procedures
for
retrievably
stored
and
newly
generated
wastes
to
be
sent
to
the
WIPP
facility.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

178
B4­
2b
Required
TRU
Waste
Stream
Information
AK
will
be
used
to
delineate
waste
streams.
For
each
TRU
mixed
waste
stream,
the
process
information
and
data
that
support
the
AK
used
to
characterize
that
waste
streams
will
be
compiled
and
documented.
The
type
and
quantity
of
supporting
documentation
varies
by
waste
stream
depending
on
the
process
generation
the
waste
and
the
site­
specific
requirements.
At
a
minimum,
the
waste
process
information
on
each
waste
stream
includes
the
following
written
information:

 
Area(
s)
and
building(
s)
from
which
the
waste
stream
was
or
is
generated.

 
The
waste
stream
volume
and
period
of
waste
generation.

 
Descriptions
of
the
waste
generating
process
for
each
building,
including
processes
associated
with
U134
waste
generation,
if
applicable.

 
Process
flow
diagrams
(
In
the
event
that
a
process
flow
diagram
cannot
be
created,
a
description
of
the
waste
generating
process,
rather
than
a
formal
process
flow
diagram,
will
be
used
to
satisfy
this
requirement.
The
use
of
the
waste
generating
process
description
will
be
justified,
and
the
justification
will
be
placed
in
the
auditable
record.).

 
Material
inputs
or
other
information
that
identifies
the
chemical
content
of
the
waste
stream
and
the
physical
waste
form
(
e.
g.,
glove
box
materials
and
chemicals
handled
during
glove
box
operations;
data
obtained
through
visual
examination
of
newly
generated
waste
that
later
undergoes
radiography;
information
demonstrating
neutralization
of
U134
[
hydrofluoric
acid]
and
waste
compatibility,
etc.).

The
AK
written
record
includes
a
summary
that
identifies
all
sources
of
waste
characterization
information
used
to
delineate
the
waste
stream.
The
basis
and
rationale
for
delineating
each
waste
stream,
based
on
the
parameters
of
interest,
is
clearly
summarized
and
traceable
to
referenced
documents.
Assumptions
made
in
delineating
each
waste
stream
also
are
identified
and
justified.

If
discrepancies
are
identified
between
required
information
in
the
source
documentation,
the
AMWTP
will
apply
all
hazardous
waste
codes
indicated
by
the
information
to
the
subject
waste
stream
unless
an
alternative
assignment
can
be
justified.
Inconsistencies
are
resolved
using
supplemental
information
from
interviews,
phone
contacts,
or
other
correspondence.
A
(
discrepancy
report)
documenting
resolution
to
the
discrepancy
is
maintained
as
a
quality
record
in
the
AK
files.
Discrepancy
resolution
for
the
AK
is
described
in
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.

Procedures
listed
in
Section
B4­
3b
comply
with
the
following
AK
requirements:

 
Procedures
for
identifying
and
assigning
the
physical
waste
form
of
the
waste:

 
INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
 
INST­
OI­
16,
Drum
Coring
Operations
 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

179
 
Procedures
for
delineating
waste
streams
and
assigning
Waste
Matrix
Codes:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
 
MP­
TRUW­
8.11,
Data
Reconciliation
 
Procedures
for
resolving
inconsistencies
in
AK
documentation:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
 
MP­
TRUW­
8.11,
Data
Reconciliation
 
Procedures
for
confirming
AK
information
through
headspace
gas
sampling
and
analysis,
visual
examination
and/
or
radiography,
and
homogeneous
waste
sampling
and
analysis:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
Acceptable
Knowledge
Documentation
 
INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
 
INST­
OI­
16,
Drum
Coring
Operations
 
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operations
 
ACMM
­
9260,
Volatile
Organic
Compounds
by
Gas
Chromatography
Mass
Spectrometry
 
ACMM­
9441,
Determination
of
Nonhalogenated
Volatile
Organics
by
Gas
Chromatography
 
ACMM­
9500,
Sample
Preparation
for
Semivolatile
Organic
Compounds
and
PCBs
 
ACCM­
9270,
Semivolatile
Organic
Compounds
by
Gas
Chromatography/
Mass
Spectrometry
 
ACMM­
9080,
Determination
Polychlorinated
Biphenyls
(
PCBs)
by
Gas
Chromatography
 
ACMM­
8909,
Microwave
Assisted
Digestion
of
Homogeneous
Solids
and
Soil/
Gravel
 
ACMM­
2901,
Determination
of
Metals
by
ICP­
AES
for
TRU
Waste
Characterization
 
ACMM­
2810,
Determination
of
Mercury
by
CVAA
for
TRU
Waste
Characterization
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

180
 
Procedures
describing
management
controls
used
to
ensure
prohibited
items
(
specified
in
the
WIPPWAP
Permit
Attachment
B)
are
documented
and
managed:

 
INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
 
INST­
OI­
16,
Drum
Coring
Operations
 
Procedures
to
ensure
radiography
and
visual
examination
include
a
list
of
prohibited
items
that
the
operator
shall
verify
are
not
present
in
each
container
of
waste
(
e.
g.,
liquids
exceeding
TSDF­
WAC
limits,
corrosives,
ignitable,
reactives,
and
incompatible
wastes):

 
INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
 
INST­
OI­
16,
Drum
Coring
Operations
 
Procedures
to
document
how
changes
to
Waste
Matrix
Codes,
waste
stream
assignment,
and
associated
EPA
HWNs
based
on
material
composition
are
documented
for
any
waste:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
Acceptable
Knowledge
Documentation
 
MP­
TRUW­
8.11,
Data
Reconciliation
 
Procedures
for
newly
generated
waste
shall
describe
how
AK
is
confirmed
using
either
the
visual
examination
technique
or
radiography
(
or
VE
in
lieu
of
radiography)
and
procedures
shall
also
describe
the
criteria
for
selecting
either
radiography
or
VE
to
ensure
there
is
documentation
and
adequate
justification
of
the
process
selected:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
 
INST­
OI­
16,
Drum
Coring
Operations
 
INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

181
B4­
2c
Supplemental
Acceptable
Knowledge
Documentation
Supplemental
AK
information,
as
appropriate,
is
collected
to
support
required
TRU
waste
stream
information.
This
supplemental
information
is
included
in
the
AK
written
record.
Supplemental
AK
documentation
that
may
be
used
(
if
available)
in
addition
to
the
required
information
specified
above
include,
but
are
not
limited
to,
the
following
information:

 
Process
design
documents
(
e.
g.,
Title
II
Design).

 
Standard
operating
procedures
that
may
include
a
list
of
raw
materials
or
reagents,
a
description
of
the
process
or
experiment
generating
the
waste,
and
a
description
of
waste
generated
and
how
the
wastes
are
managed
at
the
point
of
generation.

 
Preliminary
and
final
safety
analysis
reports
and
technical
safety
requirements.

 
Waste
packaging
logs.

 
Test
plans
or
research
project
reports
that
describe
reagents
and
other
raw
materials
used
in
experiments.

 
Site
databases
(
e.
g.,
chemical
inventory
database
for
Superfund
Amendments
and
Reauthorization
Act
Title
III
requirements).

 
Information
from
site
personnel
(
e.
g.,
documented
interviews).

 
Standard
industry
documents
(
e.
g.,
vendor
information).

 
Analytical
data
relevant
to
the
waste
stream,
including
results
from
fingerprint
analyses,
spot
checks,
or
routine
verification
sampling.
This
may
also
include
new
information
acquired
apart
from
the
confirmatory
process
which
supplements
required
information
(
e.
g.,
visual
examination
not
performed
in
compliance
with
the
WIPP­
WAP).

 
Material
Safety
Data
Sheets,
product
labels,
or
other
product
package
information.

 
Sampling
and
analysis
data
from
comparable
or
surrogate
waste
streams
(
e.
g.,
residues,
equivalent
nonradioactive
materials).

 
Laboratory
notebooks
that
detail
the
research
processes
and
raw
materials
used
in
an
experiment.

All
specific,
relevant
supplemental
AK
documentation
assembled
and
used
in
the
AK
process,
whether
it
supports
or
contradicts
any
required
AK
documentation,
is
identified
and
an
explanation
provided
for
its
use
(
e.
g.,
identification
of
a
toxicity
characteristic).
Supplemental
documentation
may
be
used
to
further
document
the
rationale
for
the
hazardous
characterization
results.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

182
Similar
to
required
information,
if
discrepancies
exist
between
supplemental
information
and
the
required
information,
then
the
AMWTP
applies
all
hazardous
waste
codes
indicated
by
the
supplemental
information
to
the
subject
waste
stream.
Alternatively,
the
AMWTP
may
choose
to
justify
an
alternative
assignment
and
document
the
justification
in
the
auditable
record.
Discrepancy
resolution
for
the
AK
is
described
in
MPTRUW
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation.

B4­
3
Acceptable
Knowledge
Training,
Procedures
and
Other
Requirements
A
three
phase
process
is
used
to
characterize
TRU
waste
by
means
of
AK
information:
1)
compiling
the
required
and
supplemental
AK
documentation
in
an
auditable
record,
2)
confirming
and
updating
knowledge
information
using
radiography
and/
or
VE,
and
headspace
gas
and
homogeneous
waste
sampling
and
analysis,
and
3)
auditing
AK
records.

B4­
3a
Qualifications
and
Training
Requirements
To
ensure
compliance
with
the
requirements
for
compiling
assembling,
evaluating,
assessing
and
resolving
discrepancies
associated
with
AK,
AMWTP
AK
personnel
shall
be
trained
in
accordance
with
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification.

The
training
requirements
shall
include
the
following
subjects:

 
WIPP­
WAP
in
permit
Attachment
B
and
the
Treatment,
Storage
and
Disposal
Facility
Waste
Acceptance
Criteria
specified
in
this
permit.

 
State
and
Federal
RCRA
regulations
associated
with
solid
and
hazardous
waste
characterization.

 
Discrepancy
resolution
and
reporting
processes.

 
Site­
specific
procedures
associated
with
waste
characterization
using
AK.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

183
B4­
3b
Acceptable
Knowledge
Assembly,
Compilation,
and
Confirmation
Procedures
and
Required
Administrative
Controls
Site­
specific
AK
procedures
address
the
following:

 
A
written
procedure(
s)
outlining
the
specific
methodology
used
to
assemble
AK
records,
including
the
origin
of
the
documentation,
how
it
will
be
used,
and
any
limitations
associated
with
the
information
(
e.
g.,
identify
the
purpose
and
scope
of
a
study
that
included
limited
sampling
and
analysis
data).
Refer
to
Section
B4­
3b(
l)
of
this
document.

 
A
written
procedure(
s)
to
compile
the
required
AK
record.
Refer
to
Section
B4­
3b(
2)
of
this
document.

 
A
written
procedure(
s)
that
ensures
unacceptable
wastes
(
e.
g.,
reactive,
ignitable,
corrosive)
are
identified
and
segregated
from
TRU
waste
populations
sent
to
WIPP.
Refer
to
Section
B4­
3b(
3)
of
this
document.

 
A
written
procedure(
s)
to
evaluate
AK
and
resolve
discrepancies.
If
different
sources
of
information
indicate
different
hazardous
wastes
are
present,
then
AMWTP
includes
all
sources
of
information
in
its
records
and
conservatively
assign
all
potential
hazardous
waste
codes
unless
AMWTP
chooses
to
justify
an
alternative
assignment
and
document
the
justification
in
the
auditable
record.
The
assignment
of
hazardous
waste
codes
is
tracked
in
the
auditable
record
to
all
required
documentation.
Refer
to
Section
B4­
3b(
4)
of
this
document.

 
A
written
procedure(
s)
to
identify
hazardous
wastes
and
assign
the
appropriate
hazardous
waste
codes
to
each
waste
stream.
The
following
are
minimum
baseline
requirements/
standards
that
site­
specific
procedures
include
to
ensure
comparable
and
consistent
characterization
of
hazardous
waste:

 
Compilation
of
all
of
the
required
information
in
an
auditable
record.

 
Review
of
the
required
information
to
determine
if
the
waste
is
listed
under
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261),
Subpart
D.
All
listed
hazardous
waste
codes
are
assigned
unless
AMWTP
chooses
to
justify
an
alternative
assignment
and
document
the
justification
in
the
auditable
record.

 
Review
of
the
required
information
to
determine
if
the
waste
contains
hazardous
constituents
included
in
the
toxicity
characteristics
specified
in
20
NMAC
4.1.200
(
incorporating
40
CFR
§
261),
Subpart
C.
If
a
toxicity
characteristic
contaminant
is
identified
and
is
not
included
as
a
listed
waste,
the
toxicity
characteristic
code
is
assigned
unless
data
are
available
that
demonstrate
that
the
concentration
of
the
constituent
in
the
waste
is
less
than
the
toxicity
characteristic
regulatory
level.
When
data
are
not
available,
the
toxicity
characteristic
hazardous
waste
code
for
the
identified
hazardous
constituent
is
applied
to
the
mixed
waste
stream.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

184
For
newly
generated
wastes,
procedures
are
implemented
to
characterize
hazardous
waste
using
AK
prior
to
packaging
the
waste.
Refer
to
Section
B4­
3b(
5)
of
this
document.

 
A
written
procedure(
s)
for
the
confirmation
of
AK
in
accordance
with
Section
B4­
3(
d).
Refer
to
Section
B4­
3d
of
this
document.

 
A
written
procedure(
s)
that
provides
a
cross­
reference
to
the
applicable
waste
summary
category
group
(
i.
e.,
S3000,
S4000,
and
S5000)
to
verify
all
of
the
required
confirmation
data
has
been
evaluated
and
the
proper
hazardous
waste
codes
have
been
assigned.
Refer
to
Section
B4­
3b(
7)
of
this
document.

 
Ensure
that
results
of
other
audits
of
the
TRU
waste
characterization
programs
at
the
site
are
available
in
the
records.
Refer
to
Section
B4­
3b(
8)
of
this
document.

The
AMWTP
uses
administrative
control
to
ensure
that
prohibited
items
are
documented
and
managed
in
accordance
with
the
following
elements
[
see
Section
B4­
3b(
9)]:

 
Identify
the
organization(
s)
responsible
for
compliance
with
administrative
controls.

 
Identify
the
oversight
procedures
and
frequency
of
actions
to
verify
compliance
with
administrative
controls.

 
Develop
on­
the­
job
training
specific
to
administrative
control
procedures.

 
Ensure
that
personnel
may
stop
work
if
noncompliance
with
administrative
controls
is
identified.

 
Develop
a
nonconformance
process
that
complies
with
the
requirements
in
Section
B3
of
the
WIPPWAP
to
document
and
establish
corrective
actions.

 
As
part
of
the
corrective
action
process,
assess
the
potential
time
frame
of
the
noncompliance,
the
potentially
affected
waste
population(
s),
and
the
reassessment
and
recertification
of
those
waste.

B4­
3b(
l)
Procedures
Used
to
Assemble
the
Acceptable
Knowledge
Record
Written
procedure(
s)
outlining
the
specific
methodology
used
to
assemble
AK
records,
including
the
origin
of
the
documentation,
how
it
will
be
used,
and
any
limitations
associated
with
the
information
are
as
follows:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.
[
This
procedure
provides
instructions
for
compiling,
reviewing,
and
managing
AK.
Waste
stream
summaries
based
on
AK
records
are
maintained
and
controlled
based
on
this
procedure.
A
Document
Change
Request
(
DCR)
is
used
to
provide
an
auditable
record
of
changes
that
occur
to
the
waste
stream
summaries.]
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

185
B4­
3b(
2)
Procedures
Used
to
Compile
the
Acceptable
Knowledge
Record
The
written
procedure
used
to
compile
the
required
AK
record
is
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.

B4­
3b(
3)
Procedures
Used
to
Ensure
Unacceptable
Waste
is
Identified
and
Segregated
Written
procedure(
s)
that
ensure
unacceptable
waste
(
refer
to
Section
B­
1
c)
is
identified
and
segregated
from
TRU
waste
populations
to
be
sent
to
WIPP
are
as
follows:

 
INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
 
INST­
OI­
16,
Drum
Coring
Operations
B4­
3b(
4)
Procedures
Used
to
Evaluate
Acceptable
Knowledge,
Resolve
Discrepancies,
Assign
Hazardous
Waste
Numbers,
etc.

Written
procedure(
s)
to
evaluate
AK
and
resolve
discrepancies,
assign
hazardous
waste
codes,
and
preparation
of
an
auditable
record
of
required
documentation
are
as
follows:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
 
MP­
TRUW­
8.11,
Data
Reconciliation
B4­
3b(
5)
Procedures
Used
to
Identify
Hazardous
Waste
Written
procedure(
s)
to
identify
hazardous
wastes
and
assign
the
appropriate
hazardous
waste
codes
to
each
waste
stream
are
as
follows:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
 
MP­
TRUW­
8.11,
Data
Reconciliation
B4­
3b(
6)
Procedures
Used
to
Confirm
Acceptable
Knowledge
and
to
Re­
Evaluate
Acceptable
Knowledge
The
written
procedure(
s)
for
the
conformation
of
AK
in
accordance
with
Section
B4­
3(
d)
is:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
 

INST­
OI­
12,
Real
Time
Radiography
Operations
 
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
 
INST­
OI­
16,
Drum
Coring
Operations
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

186
The
written
procedure
used
when
the
characterization
of
a
waste
must
be
changed
(
e.
g.,
changes
to
WMCs,
waste
steam
assignment,
EPA
HWNs,
etc.):

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.

B4­
3b(
7)
Procedures
Used
to
Cross­
Reference
to
the
Applicable
Waste
Summary
Category
Group
The
written
procedure
that
provides
the
method
for
developing
the
cross­
reference
to
the
applicable
waste
summary
category
group
(
i.
e.,
S3000,
S4000,
S5000)
and
to
verify
all
of
the
required
confirmation
data
has
been
evaluated
and
the
proper
hazardous
waste
codes
have
been
assigned
is:

 
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation
B4­
3b(
8)
Procedures
Used
to
Ensure
that
Audit
Results
are
Available
The
written
procedure
that
ensures
that
the
results
of
other
audits
of
the
TRU
waste
characterization
program
at
AMWTP
are
available
in
the
records
is
MP­
M&
IA­
17.2,
Independent
Assessments.

B4­
3b(
9)
Procedures
Used
for
Administrative
Control
The
following
minimum
elements
are
addressed
in
site­
specific
documentation
associated
with
administrative
controls:

 
The
organization(
s)
responsible
for
compliance
with
administrative
controls
(
which
includes
oversight
and
frequency
of
actions
to
verify
compliance
with
administrative
controls)
have
been
identified
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.

 
On­
the­
job
training
specific
to
administrative
control
procedures
has
been
developed
as
specified
in
the
MP­
RTQP­
14.6,
Job
and
Training
Needs
Analysis.

 
Personnel
may
stop
work
if
noncompliance
with
administrative
controls
is
identified
in
MP­
Q&
SI­
5.3,
Corrective
Action.

 
A
nonconformance
processes
has
been
developed
that
complies
with
the
requirements
in
Section
B3
of
the
WIPP­
WAP
and
documents
and
establishes
corrective
actions.
As
part
of
the
corrective
action
process,
the
potential
time
frame
of
the
noncompliance
will
be
assessed
along
with
the
potentially
affected
waste
population(
s),
and
the
impact
on
certification
of
those
waste.
This
process
is
described
in
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions,
MP­
Q&
SI­
5.3,
Corrective
Action
and
MP­
TRUW­
8.28,
Project
Level
Administrative
Controls
for
Analytical
Laboratory
Department.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

187
B4­
3c
Criteria
for
Assembling
an
Acceptable
Knowledge
Record
and
Delineating
the
Waste
Stream
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation
provides
an
overview
of
the
process
for
assembling
AK
documentation
into
an
auditable
record.
The
first
step
is
to
assemble
all
of
the
required
AK
information
and
any
supplemental
information
regarding
the
materials
and
processes
that
generate
a
specific
waste
stream.

Procedures
are
implemented
to
establish
AK
records
in
compliance
with
the
following
criteria:

 
AK
information
is
compiled
in
an
auditable
record,
including
a
road
map
for
all
applicable
information
(
refer
to
Sections
B4­
3b(
l)
and
B4­
3b(
2)
for
a
listing
of
these
procedures).

 
The
overview
of
the
facility
and
TRU
waste
management
operations
in
the
context
of
the
facility's
mission
is
correlated
to
specific
waste
stream
information
(
refer
to
Section
B4­
3b(
1)
for
a
listing
of
these
procedures).

 
The
method
for
documenting
correlations
between
waste
streams,
with
regard
to
time
of
generation,
waste
generating
processes,
and
site­
specific
facilities
are
described
in
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation.
For
newly
generated
waste,
the
rate
(
or
schedule)
and
quantity
of
waste
to
be
generated
will
be
defined.

 
A
reference
list
shall
be
provided
that
identifies
documents,
databases,
Quality
Assurance
protocols,
and
other
sources
of
information
that
support
the
AK
information.
The
creation
and
management
of
this
lot
is
defined
by
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation,
and
Management
of
AK
Documentation.

Container
inventories
for
TRU
waste
currently
in
retrievable
storage
can
be
found
in
the
WTS.
These
container
inventories
will
be
delineated
into
waste
streams
by
correlating
the
container
identification
to
all
of
the
required
AK
information
and
any
supplemental
AK
information.

B4­
3d
Requirements
for
Confirmation
of
Acceptable
Knowledge
Acceptable
knowledge
characterization
results
shall
be
confirmed
for
both
retrievably
stored
and
newly
generated
waste.
All
retrievably
stored
waste
shall
be
characterized
using
radiography
or
visual
examination
to
confirm
the
Waste
Matrix
Code
and
waste
stream
and
certify
compliance
with
WIPP­
WAP
(
Permit
Attachment
B).
If
AMWTP
repackages
its
retrievably
stored
waste,
either
the
visual
examination
technique
prior
to
or
during
waste
packaging
or
radiography
(
VE
in
lieu
of
radiography)
after
waste
packaging
shall
be
used
to
confirm
acceptable
knowledge
information
.
MP­
TRUW­
8.13
defines
the
process
the
AMWTP
uses
to
confirm
AK.
The
procedures
used
for
this
confirmation
of
AK
are
listed
in
Section
B4­
3b(
b).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

188
For
newly
generated
waste,
that
the
AMWTP
elects
to
confirm
AK
during
packaging,
the
AMWTP
has
written
procedures
to
document
the
confirmation
of
AK
information
with
the
visual
examination
technique
prior
to
or
during
waste
packaging
(
refer
to
Section
B4­
3b(
6)).
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation
illustrates
the
process
the
AMWTP
uses
to
confirm
AK
for
newly
generated
waste.
The
procedures
used
for
this
AK
confirmation
are
presented
in
Section
B4­
3b(
6).

The
following
minimum
requirements
are
addressed
in
site­
specific
procedures:

 
scope
(
i.
e.,
waste
streams)
and
purpose
(
refer
to
the
procedures
listed
in
Section
B4­
3b(
l));

 
responsible
organization(
s)
(
responsible
organizations
are
presented
within
each
procedure
listed
in
Section
B4­
3b);

 
administrative
process
controls
[
refer
to
the
procedures
listed
in
Section
B4­
3b(
9)];

 
material
inputs
to
process
[
refer
to
the
procedures
listed
in
Section
B4­
3b(
l)];

 
process
controls
and
range
of
operation
that
affect
final
hazardous
waste
characterization
[
refer
to
the
procedures
listed
in
Sections
B4­
3b(
5)
and
B4­
3b(
6)];

 
rate
and
quantity
of
the
hazardous
waste
generated
(
refer
to
Section
B4­
3c);

 
list
of
applicable
operating
procedures
relevant
to
the
hazardous
waste
characterization
[
refer
to
the
procedures
listed
in
Section
B4­
3b(
5)];

 

process
knowledge
verification
sampling,
(
i.
e.,
headspace
gas
sampling
and/
or
homogeneous
waste
annual
sampling)
[
refer
to
procedures
listed
in
Section
B4­
3b(
6)];
and,

 
reporting
and
records
management
[
refer
to
the
procedures
listed
in
Section
B4­
3b(
8)].

B4­
3d(
1)
Re­
Evaluation
Based
on
Radiography
and
Visual
Examination
The
AMWTP
has
established
procedures
for
reevaluating
AK
if
radiography
or
visual
examination
results
in
the
assignment
of
a
different
Waste
Matrix
Code
[
e.
g.,
Plastic/
Rubber
(
S5310)
versus
Paper/
Cloth
(
S5330)].
These
procedures,
as
listed
in
B4­
3b(
4)
and
B4­
3b(
6),
describe
how
the
waste
is
reassigned,
AK
reevaluated,
and
appropriate
hazardous
waste
codes
assigned.
If
a
waste
must
be
assigned
to
a
different
Waste
Matrix
Code
based
on
radiography
or
visual
examination,
the
following
minimum
steps
are
taken
to
reevaluate
AK.
This
process
is
implemented
in
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation:

 
Existing
information
is
reviewed
based
on
the
container
identification
number
and
all
differences
in
hazardous
waste
code
assignments
are
documented.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

189
 
If
differences
exist
in
the
hazardous
waste
codes
that
were
assigned,
the
information
is
reassessed,
and
all
required
AK
information
(
Section
B4­
3b)
associated
with
the
new
designation
will
be
documented.

 
All
sampling
and
analytical
data
associated
with
the
waste
is
reassessed
and
documented.

 
The
reassignment
of
the
Waste
Matrix
Code
is
documented
and
verified
(
e.
g.,
verification
that
the
waste
was
generated
within
the
specified
time
period,
area
and
buildings,
waste
generating
process,
and
that
the
process
material
inputs
are
consistent
with
the
physical
form
of
waste
(
waste
material
parameter)
identified
during
radiography
or
visual
examination).

 
All
changes
to
AK
records
are
recorded.

 
If
discrepancies
exist
in
the
AK
information
for
the
reassigned
Waste
Matrix
Code,
the
segregation
of
this
container
is
documented,
and
the
actions
necessary
to
fully
characterize
the
waste
are
defined.

B4­
3d(
2)
TRU
Heterogeneous
Debris
The
base
materials
that
compose
TRU
heterogeneous
debris
(
S5000)
waste
(
e.
g.,
lead,
stainless
steel,
glass)
are
well
established
and
potential
toxicity
characteristics
can
be
determined
without
destructive
sampling
and
analysis
based
on
AK.
The
AMWTP
will
assign
a
Waste
Matrix
Code
and
waste
stream
to
each
container
of
waste
using
AK.

In
lieu
of
confirmatory
sampling
and
analytical
or
other
data
to
the
contrary,
the
AMWTP
assigns
toxicity
characteristic
EPA
HWNs
based
on
the
presence
of
constituent,
regardless
of
the
quantity
or
concentration.
Radiography
or
VE
are
used
to
confirm
the
WMC
and
the
waste
stream
identified
using
AK.
If
the
waste
stream
designation
is
so
detailed
that
the
specific
components
cannot
be
differentiated
by
radiography
(
e.
g.,
a
waste
stream
based
on
a
specific
type
of
plastic),
this
waste
stream
confirmation
will
not
be
performed
and
instead
this
omission
shall
be
explained
in
the
auditable
record.
Procedures
describe
how
discrepancies
in
the
Waste
Matrix
Code
are
recorded
and
additions
to
hazardous
waste
codes
based
on
material
composition
are
documented,
as
necessary
[
refer
to
Section
B4­
3b(
5),
(
6),
and
(
7)].

B4­
3d(
3)
Head
Space
Gas
Sampling
Headspace
gas
sampling
and
analysis
is
conducted
on
all
TRU
waste
or
randomly
selected
containers
from
waste
streams
that
meet
the
conditions
for
reduced
headspace
gas
sampling
in
Section
B­
3a(
1),
to
be
sent
to
the
WIPP
facility.
Headspace
gas
data
is
used
to
confirm
the
presence
or
absence
of
volatile
organic
compounds
(
VOCs)
identified
using
AK.

Headspace
gas
sampling
and
analysis
and
data
review
is
conducted
on
TRU
waste
containers
according
to
INST­
OI­
13,
Drum
Vent/
Head
Space
Sample
Operations,
and
MP­
TRUW­
8.8,
Level
I
Data
Validation.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

190
The
AMWTP
uses
AK
to
identify
spent
solvents
associated
with
each
TRU
waste
stream
or
waste
stream
lot.
Headspace
gas
data
is
then
used
to
confirm
AK
concerning
the
presence
or
absence
of
F­
listed
solvents
and
concentration
of
applicable
toxicity
characteristic
constituents.
AMWTP
confirms
the
assignment
of
F­
listed
hazardous
waste
codes
(
20
NMAC
4.1.200,
incorporating
40
CFR
§
261.31)
by
evaluating
the
average
concentrations
of
each
VOC
detected
in
container
headspace
gas
for
each
waste
stream
or
waste
stream
lot
using
the
UCL90
(
refer
to
Section
B2­
3).

The
UCL90
for
the
mean
concentration
is
compared
to
the
program
required
quantitation
limit
(
PRQL)
for
the
constituent.
If
the
UCL90
for
the
mean
concentration
exceeds
the
PRQL,
the
AK
information
is
reevaluated
and
the
potential
source
of
the
constituent
is
determined.
Documentation
is
provided
to
support
any
determination
that
F­
listed
organic
constituents
are
associated
with
packaging
materials,
radioanalysis,
or
other
uses
not
consistent
with
solvent
use.
If
the
source
of
the
detected
F­
listed
solvents
can
not
be
identified,
the
appropriate
spent
solvent
hazardous
waste
code
is
conservatively
applied
to
the
waste
stream.
In
the
case
of
applicable
toxicity
characteristic
VOCs
and
non­
toxic
F003
constituents,
AMWTP
may
assess
whether
the
head
space
gas
concentration
would
render
the
waste
non­
hazardous
for
those
characteristic
and
change
the
initial
AK
determination
accordingly.
This
process
is
described
by
MP­
TRUW­
8.11,
Data
Reconciliation
and
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation.

B4­
3d(
4)
Homogeneous
Solids
and
Soil/
Gravel
Hazardous
wastes
associated
with
S3000
and
S4000
waste
streams
is
verified
based
on
the
results
of
the
Total/
TCLP
analysis
of
a
representative
homogeneous
waste
sample.
If
discrepancies
between
the
results
obtained
from
homogeneous
waste
sampling
and
analysis
and
headspace
gas
sampling
and
analysis
exist
(
i.
e.,
a
VOC
is
detected
in
the
solidified
waste
but
not
in
the
headspace),
the
most
conservative
results
are
used
to
verify
AK
and
assign
hazardous
waste
codes,
as
applicable.
If
the
Total
or
TCLP
results
indicate
that
the
concentration
of
a
characteristic
waste
or
non­
toxic
constituent
of
an
F003
waste
is
below
regulatory
levels,
the
hazardous
waste
code
assigned
initially
by
AK
may
be
changed
as
part
of
the
confirmatory
process.
If
an
F­
listed
waste
constituent
is
detected
and
the
source
cannot
be
identified
and
justified,
the
appropriate
hazardous
waste
code
is
applied.

If
the
confirmatory
process
determines
that
the
source
of
the
F­
listed
constituent
is
a
spent
solvent
used
in
the
process
or
is
determined
to
be
the
result
of
mixing
a
listed
waste
with
a
solid
waste
during
waste
packaging,
or
applicable
toxicity
characteristic
constituents
or
non­
toxic
F003
wastes
are
present
in
excess
of
regulatory
levels.
then
the
AMWTP
will
either:
1)
assign
the
applicable
listed
hazardous
waste
code
to
the
entire
waste
stream,
or
2)
segregate
the
drums
containing
detectable
concentrations
of
the
solvent
into
a
separate
waste
stream
and
assign
applicable
hazardous
waste
codes.
The
AMWTP
documents,
justifies,
and
consistently
delineates
waste
streams
and
assign
hazardous
waste
codes
based
on
site­
specific
permit
requirements
and
other
state­
enforced
agreements.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

191
To
determine
the
mean
concentration
of
solvent
VOCs,
all
headspace
gas
data
and
homogeneous
waste
data
for
a
waste
stream
or
waste
stream
lot
(
i.
e.,
the
portion
of
the
waste
stream
that
is
characterized
as
a
unit)
are
used,
including
data
qualified
with
a
'
J'
flag
(
i.
e.,
less
than
the
PRQL
but
greater
than
the
method
detection
limit
[
MDL])
or
qualified
with
a
'
U'
flag
(
i.
e.,
undetected).
For
data
qualified
with
a
U
flag,
one­
half
the
MDL
is
used
in
calculating
the
mean
concentration.
Because
listed
wastes
are
not
defined
based
on
concentration,
the
AMWTP
will
not
remove
listed
hazardous
waste
codes
assigned
using
AK
if
listed
hazardous
constituents
are
not
detected
in
the
headspace
gas
or
solids/
soil
analysis.

TRU
headspace
gases
and
homogeneous
waste
matrices
may
contain
one
or
two
constituents
(
e.
g..
carbon
tetrachloride
and
1,1,1­
trichloroethane)
at
concentrations
that
are
orders
of
magnitude
higher
than
the
other
target
analytes.
In
these
cases,
samples
shall
be
diluted
to
remain
within
the
instrument
calibration
range
for
the
elevated
constituents.
Sample
dilution
results
in
elevated
MDLs
for
the
non­
detected
target
analytes
in
these
cases.
Only
the
concentrations
of
detected
constituents
will
be
used
to
calculate
the
mean
for
the
purpose
of
assigning
F­
listed
hazardous
waste
codes.
Because
the
presence
or
absence
of
F­
listed
solvents
can
not
be
confirmed
based
on
the
artificially
high
MDLs
that
are
caused
by
sample
dilution,
data
flagged
as
'
U'
and
showing
an
elevated
MDL
will
not
be
used
in
calculating
the
mean
concentration.
The
above
process
is
described
by
MP­
TRUW­
8.11,
Data
Reconciliation
and
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation.

The
overall
sampling
and
analysis
strategy
for
homogeneous
solids
and
soil/
gravel
is
illustrated
in
Figure
B2­
5
of
this
document.
Specific
instructions
and
methods
used
to
perform
the
RCRA
characterization
of
retrievably
stored
homogeneous
solids
and
soil/
gravel,
as
specified
in
the
WIPP­
WAP,
are
presented
in
MP­
TRUW­
8.25,
RCRA
Statistical
Sampling
and
the
specific
sampling
and
analysis
procedures.

B4­
3e
Acceptable
Knowledge
Data
Quality
Requirements
The
DQOs
for
sampling
and
analysis
techniques
are
provided
in
Attachment
B3
of
this
document.
Analytical
results
are
used
to
confirm
the
characterization
of
wastes
based
on
AK.
AK
includes
records;
past
sampling
and
analytical
data;
material
inputs
to
the
waste
generating
process;
and
the
production
and
waste
handling
procedures
used
over
the
time
period
during
which
the
waste
was
generated.
The
purpose
of
AK
documentation
is
to
provide
a
clear
and
convincing
argument
about
the
characteristics
of
the
waste.
To
ensure
that
the
AK
process
is
consistently
applied,
the
AMWTP
complies
with
the
quality
requirements
presented
below
for
AK
documentation.

Precision
Precision
is
the
agreement
of
a
set
of
replicate
measurements
without
assumption
of
the
knowledge
of
a
true
value.
The
qualitative
determinations
of
AK,
such
as
compiling
and
assessing
knowledge
documentation,
do
not
lend
themselves
to
statistical
evaluation
of
precision.
Therefore,
precision
requirements
are
not
established
for
AK.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

192
Accuracy
Accuracy
is
the
degree
of
agreement
between
an
observed
sample
result
and
the
true
value.
The
percentage
of
waste
containers
that
require
reassignment
to
a
new
WMC
or
designation
of
different
EPA
HWNs
based
on
the
re­
evaluation
of
AK
or
on
obtaining
sampling
and
analysis
data
will
be
reported
as
a
measure
of
AK
accuracy
as
required
by
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation.

Completeness
Completeness
is
an
assessment
of
the
number
of
waste
streams
or
number
of
samples
collected
to
the
number
of
samples
determined
to
be
useable
through
the
data
validation
process.
The
AK
record
contains
100
percent
of
the
information
specified
in
Section
B4­
2
and
is
documented
according
to
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation.

Comparability
Data
are
considered
comparable
when
one
set
of
data
can
be
compared
to
another
set
of
data.
Comparability
is
ensured
through
meeting
the
training
requirements
and
complying
with
the
minimum
standards
in
the
procedures
that
are
used
to
implement
the
AK
process.
The
AMWTP
has
assigned
WMCs,
assigned
EPA
HWNs,
and
identified
the
physical
form
of
waste
(
waste
material
parameter)
in
accordance
with
Section
B4­
3b(
5)
and
(
7).
AK
information
regarding
the
waste
shall
be
provided
to
other
sites
who
store
or
generate
a
similar
waste
stream.

Representativeness
Representativeness
expresses
the
degree
to
which
sample
data
accurately
and
precisely
represent
a
population.
Representativeness
is
a
qualitative
parameter
that
will
be
satisfied
by
ensuring
that
the
process
of
obtaining,
evaluating,
and
documenting
AK
information
is
performed
in
accordance
with
the
minimum
standards
established
in
Section
B4­
3b.
The
AMWTP
has
also
assessed
and
documented
the
limitations
of
the
AK
information
used
to
assign
EPA
HWNs
(
e.
g.,
purpose
and
scope
of
information,
date
of
publication,
type
and
extent
to
which
waste
parameters
are
addressed
and
limitation
of
information
in
identifying
hazardous
waste).

The
AMWTP
addresses
quality
control
by
tracking
its
performance
with
regard
to
the
use
of
AK
by:
1)
assessing
the
frequency
of
inconsistencies
among
information,
and
2)
documenting
the
results
of
AK
confirmation
through
radiography
or
VE,
headspace
gas
analyses,
and
homogeneous
waste
analyses.
In
addition,
the
AK
process
and
waste
stream
documentation
is
evaluated
through
internal
assessments
by
quality
assurance
organizations
and
assessments
by
auditors
or
observers
external
to
the
organization
(
i.
e.,
CBFO,
NMED,
EPA).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

193
Audits
of
Acceptable
Knowledge
CBFO
will
conduct
an
initial
audit
prior
to
certifying
AMWTP
for
shipment
of
TRU
waste
to
the
WIPP
facility.
This
initial
audit
will
establish
an
approved
baseline
that
will
be
reassessed
annually.
Those
audits
verify
compliance
with
the
WIPP­
WAP,
ensure
the
consistent
compilation,
application,
and
interpretation
of
AK
information
throughout
the
DOE
complex,
and
evaluate
the
completeness
and
defensibility
of
sitespecific
AK
documentation
related
to
hazardous
waste
determinations.

The
QA
organization
performs
a
periodic
independent
audit,
or
several
small
scope
audits,
of
AMWTP
activities
in
accordance
with
MP­
M&
IA­
17.2,
Independent
Assessments.
QA
AK
audit
checklists
include
the
elements
listed
below
for
review
during
the
periodic
audit,
and
the
AMWTP
provides
information
as
requested
by
QA
to
satisfy
the
AK
audit/
surveillance
requirements:

 
Documentation
of
the
process
used
to
compile,
evaluate,
and
record
AK
is
available
and
implemented.

 
Personnel
training
and
qualifications
are
documented.

 
All
of
the
required
AK
documentation
specified
in
Section
B4­
2
has
been
compiled
in
an
auditable
record.

 
All
the
required
procedures
specified
in
Section
B4­
3
have
been
developed
and
implemented,
including
but
not
limited
to
 
A
procedure
exists
for
assigning
hazardous
waste
codes
as
referenced
in
Section
B4­
3b(
5).

 
A
procedure
exists
for
resolving
discrepancies
as
referenced
in
Section
B4­
3b(
4)
and
(
6).

 
A
procedure
exists
for
confirming
AK
information
through:
a)
radiography
or
VE,
b)
headspace
gas
sampling
and
analysis,
and
c)
homogeneous
waste
sampling
as
referenced
in
Section
B4­
3b(
6).

 
Results
of
other
audits
of
the
TRU
waste
characterization
programs
at
AMWTP
are
available
in
site
records.

B4­
4
Additional
Final
Confirmation
of
Acceptable
Knowledge
at
the
WIPP
Facility
Prior
to
shipping
waste,
the
AMWTP
provides
all
of
the
required
data
associated
with
waste
stream
characterization,
including
summary
AK
information,
radiography
or
VE,
headspace
gas
sampling
and
analysis,
and
homogeneous
solids
and
soil/
gravel
sampling
and
analysis
results
to
the
WIPP
facility
for
review.
In
addition,
the
AMWTP
designates
the
assigned
hazardous
waste
codes
for
the
waste
stream
on
the
WSPF.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

194
As
part
of
the
reconciliation
of
DQOs
(
refer
to
Section
B3­
l0),
the
AMWTP
tracks
and
reports
changes
to
hazardous
waste
characterizations.
If
data
consistently
indicate
that
discrepancies
with
AK
information
are
identified
by
the
AMWTP
(
and
were
subsequently
reconciled),
the
AMWTP
reassesses
the
materials
and
processes
that
generate
the
waste,
resubmits
WSPF
information,
and
implement
the
corrective
action
system.
If
review
of
a
WSPF
and
associated
waste
characterization
data
reveal
nonconformance
with
AK
requirements
(
i.
e.,
Project
Level
nonconformance),
the
waste
will
not
be
shipped
to
the
WIPP
facility
until
the
corrective
actions
have
been
implemented
and
the
requirements
of
the
WAP
have
been
met.

Any
drum
with
unresolved
discrepancies
associated
with
hazardous
waste
characterization
will
not
be
shipped
to
WIPP
until
the
discrepancies
are
resolved.
The
AMWTP
will
reassess
the
material
and
processes
that
generate
the
waste,
and
headspace­
gas
sampling
and
analysis,
radiography
or
visual
examination,
and
homogeneous
waste
sampling
and
analysis
results.
All
shipments
of
the
subject
waste
stream
will
cease
until
the
corrective
actions,
as
necessary,
have
been
implemented
and
the
discrepancy
resolved.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

195
B5
QUALITY
ASSURANCE
PROJECT
PLAN
REQUIREMENTS
B5­
1
Site­
Specific
Quality
Assurance
Project
Plan
The
AMWTP
has
developed
and
implemented
this
QAPjP
to
addresses
the
applicable
requirements
specified
in
the
WIPP­
WAP.
This
QAPjP
includes
the
qualitative
or
quantitative
criteria
to
ensure
that
waste
characterization
activities
are
being
performed
satisfactorily.
The
organizations
and
positions
responsible
for
the
implementation
of
the
qualitative
and
quantitative
criteria
are
identified
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.
Throughout
this
QAPjP,
site­
specific
documents
are
referenced
that
detail
how
each
of
the
required
elements
of
the
characterization
program
are
performed.

The
AMWTP
utilizes
procedures
to
ensure
tasks
are
performed
in
a
consistent
manner
that
results
in
achieving
the
quality
required
for
the
quality
assurance
program.
The
pertinent
procedures
are
identified
throughout
the
text
of
this
QAPjP.

Procedures
include
the
following
sections:

 
Purpose/
Scope:
The
purpose
and
scope
of
the
procedure.

 
References:
Documents
referenced
in
the
procedure
(
as
necessary).

 
Definitions:
Definitions
of
terms
used
in
procedure
(
as
necessary).

 
Procedure:
Step
by
step
instructions
to
accomplish
the
tasks
covered
by
the
procedure.

 
Records:
Identifies
any
records
resulting
from
the
procedure.

 
Exhibits:
Figures
and
tables
used
in
procedure
(
as
necessary).

 
Appendices:
As
necessary.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

196
B5­
2
Document
Review,
Approval,
and
Control
The
preparation,
issuance,
and
change
to
documents
that
specify
quality
requirements
or
prescribe
activities
affecting
quality
for
the
characterization
program
are
controlled
to
ensure
the
correct
and
current
documents
are
used
and
referenced.
All
quality
documents
for
the
characterization
program
will
be
reviewed
prior
to
issuance
by
qualified
and
independent
individuals.
AMWTP
compliance
with
the
WIPP­
WAP
requirements
for
document
review,
approval,
and
control
is
defined
in
Section
4
of
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.
The
CBFO
approves
this
QAPjP
and
other
program
documents
defining
performance
criteria
or
data
quality.
These
documents
are
identified
in
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste.

Table
B5­
1,
Minimum
requirements
for
review,
approval
implementation,
and
control
of
QAPjP,
presents
the
minimum
requirements
for
review,
approval,
and
implementation
of
the
QAPjP.
The
QAPjP
review
will
consider
the
technical
adequacy,
completeness,
and
correctness,
and
the
inclusion
of
requirements
established
by
the
WIPP­
WAP.

Table
B5­
1.
Minimum
requirements
for
review,
approval,
implementation
and
control
of
QAPjP.

RESPONSIBLE
PARTY
Manager,
CBFO
QA
Team
Leader,
National
TRU
Program
DOE­
ID
AMWTP
SPM
AMWTP
SQAO
Review/
Approval
X
X
X
X
X
Implementation
X
Change
Approval
X
X
X
X
X
Change
Control
X
Revisions
to
documents
that
implement
the
requirements
of
the
WAP
will
be
denoted
by
including
the
current
revision
number
on
the
documents
title
page,
the
revised
signature
page,
and
each
page
that
has
been
revised.
Only
revised
pages
need
to
be
reissued
although
the
entire
document
may
be
reissued.
Changes
to
documents,
other
than
those
defined
as
editorial
changes
or
minor
changes,
will
be
reviewed
and
approved
by
the
same
functional
organizations
that
performed
the
original
review
and
approval,
unless
other
organizations
are
specifically
designed
in
accordance
with
approved
procedures.
Editorial
or
minor
changes
may
be
made
without
the
same
level
of
review
and
approval
as
the
original
or
otherwise
changed
document.
The
following
items
are
considered
editorial
or
minor
changes:

 
Correcting
grammar
or
spelling
(
the
meaning
has
not
changed)

 
Renumbering
sections
or
attachments
 
Updating
organizational
titles
 
Changes
to
nonquality­
affecting
schedules
 
Revised
or
reformatted
forms,
providing
the
original
intent
of
the
form
has
not
been
altered
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

197
 
Attachments
marked
"
Example",
"
Sample",
or
exhibits
that
are
clearly
intended
to
be
representative
only
A
change
in
an
organizational
title
accompanied
by
a
change
in
the
responsibilities
is
not
considered
an
editorial
change.
Changes
to
the
text
shall
be
clearly
indicated
in
the
document.

All
members
of
the
project
staff
are
responsible
for
reporting
any
obsolete
or
superseded
information
to
the
SPM.
All
site­
specific
changes
shall
be
evaluated
and
approved
by
the
SPM
and
SQAO
or
designee
before
implementation.
The
SPM
shall
notify
the
appropriate
personnel
and
the
affected
documents
shall
be
revised
as
necessary.
The
SPM
is
responsible
for
notifying
the
DOE
field
office
of
document
changes.

B6
AUDIT
AND
SURVEILLANCE
PROGRAM
B6­
1
CBFO
Audit
Conduct
If
a
discrepancy
is
identified
during
a
CBFO
audit,
the
audit
team
may
prepare
a
Corrective
Action
Report
(
CAR).
The
AMWTP
will
review
the
CAR,
evaluate
the
extent
and
cause
of
the
deficiency,
and
provide
a
response
to
CBFO
indicating
the
remedial
actions
and
action
taken
to
preclude
recurrence.
After
all
corrective
actions
have
been
complete,
the
CBFO
may
schedule
and
perform
a
verification
visit
to
assure
that
corrective
actions
have
been
completed
and
are
effective.

The
corrective
action
response
will
include
a
discussion
of
the
investigation
performed
to
determine
the
extent
and
impact
of
the
deficiency,
a
description
of
the
remedial
actions
taken,
determination
of
root
cause,
and
actions
to
preclude
recurrence.

The
AMWTP
will
respond
to
any
deficiencies
and
observations
within
thirty
days
after
receipt
of
any
CARs
and
indicate
the
corrective
action
taken
or
to
be
taken.
If
the
corrective
action
has
not
been
completed,
the
response
will
indicate
the
expected
date
the
action
will
be
completed.
CARs
applicable
to
WAP
requirements
will
be
resolved
prior
to
shipment.

Only
personnel
with
appropriate
U.
S.
Department
of
Energy
clearances
will
have
access
to
classified
information
during
audits.
Classified
information
will
not
be
included
in
audit
reports
and
records.

B6­
2
Internal
Management
Assessments
and
Independent
Surveillances
AMWTP
personnel
schedule
and
conduct
management
assessments
of
the
TRU
Waste
Characterization
activities
in
accordance
with
MP­
M&
IA­
17.1,
Management
Assessments.
AMWTP
QA
schedule
and
conduct
formal
internal
independent
assessment
in
accordance
with
MP­
M&
IA­
17.2,
Independent
Assessments.

When
a
deficiency
is
identified
by
the
audit
team,
the
assessment
team
member
who
identified
the
deficiency
prepares
a
Corrective
Action
Report
(
CAR)
in
accordance
with
MP­
Q&
SI­
5.3,
Corrective
Action.

The
corrective
action
response
will
include
a
discussion
of
the
investigation
performed
to
determine
the
extent
and
impact
of
the
deficiency,
a
description
of
the
remedial
actions
taken,
determination
of
root
cause,
and
actions
to
preclude
recurrence.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

198
C.
RECORDS
PROCESSING
Record
Description
Classification
MP­
TRUW­
8.2
Lifetime/
QA
D.
REFERENCES
D­
1
AMWTP
Documents
Bechtel
BWXT
Idaho,
LLC
(
BWXT),
2000,
Determination
of
Drum
Age
Criteria
and
Prediction
Factors
Based
on
Packaging
Configurations,
INEEL/
EXT­
2000­
01207,
October
2000,
Liekhus,
K.
J.,
S.
M.
Djordjevic,
M.
Kevarakonda,
and
M.
J.
Connolly,
Idaho
National
Engineering
and
Environmental
Laboratory,
Idaho
Falls,
Idaho.

INST­
CMNT­
10.1.2,
Maintenance
Management
System
INST­
OI­
12,
Real
Time
Radiography
Operations
INST­
OI­
13,
Drum
Vent/
Headspace
Gas
Sample
Operations
INST­
OI­
14,
Drum
Assay
Operations
INST­
OI­
16,
Drum
Coring
Operations
INST­
OI­
34,
VE
Operating
Procedures
&
Data
Reporting
INST­
TRUW­
8.2.1,
HSG
Calibration
MP­
CMNT­
10.1,
Maintenance
Management
MP­
DOCS­
18.2,
AMWTP
Records
Management
MP­
DOCS­
18.4,
Document
Control
MP­
M&
IA­
17.1,
Management
Assessments
MP­
M&
IA­
17.2,
Independent
Assessments
MP­
Q&
SI­
5.3,
Corrective
Action
MP­
Q&
SI­
5.4,
Identification
of
Nonconforming
Conditions
MP­
RTQP­
14.4,
Personnel
Qualification
and
Certification
MP­
RTQP­
14.6,
Job
and
Training
Needs
Analysis
MP­
RTQP­
14.19,
Training
Records
Administration
MP­
TRUW­
8.1,
Certification
Plan
for
INEEL
Contact­
Handled
Transuranic
Waste
MP­
TRUW­
8.11,
Data
Reconciliation
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

199
MP­
TRUW­
8.13,
Collection,
Review,
Confirmation
and
Management
of
AK
Documentation
MP­
TRUW­
8.14,
Preparation
of
Waste
Stream
Profile
Forms
MP­
TRUW­
8.16,
WWIS
Data
Transfer
MP­
TRUW­
8.17,
Co­
located
Core
Sampling
Control
Charts
MP­
TRUW­
8.19,
RTR/
VE
Drum
Selection
MP­
TRUW­
8.25,
RCRA
Statistical
Sampling
MP­
TRUW­
8.28,
Project
Level
Administrative
Controls
for
Analytical
Laboratory
Department
MP­
TRUW­
8.8,
Level
I
Data
Validation
MP­
TRUW­
8.9,
Level
II
Data
Validation
ALD
Documents
ACMM­
2810,
Determination
of
Mercury
by
CVAA
for
TRU
Waste
Characterization
ACMM­
2901,
Determination
of
Metals
by
ICP­
AES
for
TRU
Waste
Characterization
ACMM­
8909,
Microwave
Assisted
Digestion
of
Homogeneous
Solids
and
Soil/
Gravel
ACMM­
9080,
Determination
of
Polychlorinated
Biphenyls
(
PCB)
by
Gas
Chromatography
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
Organics
by
Gas
Chromatography
ACMM­
9500,
Sample
Preparation
for
Semivolatile
Organic
Compounds
and
Polychlorinated
Biphenyls
MCP­
2002,
Analytical
Sample
Management
MCP­
2008,
Analytical
Data
Reporting,
Review,
and
Reporting
PLN­
342,
Analytical
Laboratories
Department
Quality
Assurance
Plan
for
the
AMWTP
D­
2
External
References
40
CFR
Part
261.
October
1994.
Identification
and
Listing
of
Hazardous
Waste.
Code
of
Federal
Regulations,
Washington,
D.
C.,
Office
of
the
Federal
Register
National
Archives
and
Records
Administration.

40
CFR
Part
262.
Code
of
Federal
Regulations,
Washington,
D.
C.,
Office
of
the
Federal
Register
National
Archives
and
Records
Administration.

20
NMAC
4.1
New
Mexico
Hazardous
Waste
Management
Regulations,
Title
20,
New
Mexico
Administrative
Code,
Chapter
4,
Part
1,
Sections
200,
300,
500,
and
800
ASTM.
1983a.
Test
Method
for
Chemical
Composition
of
Gases
by
Mass
Spectrometry,
ASTM
D2650­
83,
American
Society
for
Testing
and
Materials
ASTM.
1983b.
Type
II
Water
Dl
193­
77,
American
Society
for
Testing
and
Materials
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

200
ASTM.
1998.
Standard
Practice
for
Sampling
Waste
and
Soils
for
Volatile
Organic
Compounds.
ASTM
D4547­
98,
Annual
Book
of
ASTM
Standards,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials
ASTM.
1993.
Standard
Practice
for
Reducing
Samples
of
Aggregate
to
Testing
Size,
Method
B
Quartering,
ASTM
C702­
93,
Annual
Book
of
ASTM
Standards,
Philadelphia,
Pennsylvania,
American
Society
for
Testing
and
Materials
BWXT.
2000.
Determination
of
Drum
Age
Criteria
and
Prediction
Factors
Based
On
Packaging
Configurations.
INEEL/
EXT­
2000­
1207,
October
2000.
Liekhus,
K.
J.,
S.
M.
Djordjevic,
M.
Devarakonda,
M.
J.
Connolly.
Bechtel
BWXT
Idaho,
LLC.
Idaho
National
Engineering
and
Environmental
Laboratory,
Idaho
Falls,
Idaho.

DOE.
1995a.
DOE
Waste
Treatability
Group
Guidance.
DOE/
LLW­
217,
Revision
0,
Idaho
Falls,
ID,
INELLockheed
Idaho
Technologies
Company,
U.
S.
Department
of
Energy
DOE.
1995b.
Waste
Isolation
Pilot
Plant
Transuranic
Waste
Baseline
Inventory
Report.
DOE/
CAO­
94­
1005,
Current
Revision,
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy
DOE.
1997.
WIPP
RCRA
Part
B
Permit
Application
DOE.
1998a.
Quality
Assurance
Program
Document.
DOE/
CAO­
94­
1012,
Current
Revision,
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy
DOE.
1999a,
Performance
Demonstration
Program
Plan
for
the
Analysis
of
Simulated
Headspace
Gases
for
the
TRU
Waste
Characterization
Program.
DOE/
CAO­
95­
1076,
Current
Revision,
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy
2002.

DOE.
1999b,
Performance
Demonstration
Program
Plan
for
the
RCRA
Constituent
Analysis
of
Solidified
Wastes,
DOE/
CAO­
95­
1077,
Current
Revision,
Carlsbad,
New
Mexico,
Carlsbad
Area
Office,
U.
S.
Department
of
Energy
2002.

DOE/
CAO­
97­
2273,
WIPP
Waste
Information
System
User's
Manual
for
Use
by
Shipper's/
Generators,
U.
S.
Department
of
Energy,
Carlsbad
Area
Office
(
DOE/
CAO),
Carlsbad,
New
Mexico.

DOE/
WIPP­
02­
3122,
Contact­
Handled
Transuranic
Waste
Acceptance
Criteria
for
the
Waste
Isolation
Pilot
Plant,
U.
S.
Department
of
Energy,
Carlsbad
Field
Office,
Carlsbad,
New
Mexico.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

201
EPA.
1988.
Compendium
Method
TO­
14.
The
Determination
of
Volatile
Organic
Compounds
(
VOC)
in
Ambient
Air
Using
SUMMA
Passivated
Canister
Sampling
and
Gas
Chromatographic
Analyses.
Compendium
of
Methods
for
the
Determination
of
Toxic
Organic
Compounds
in
Ambient
Air.
Research
Triangle
Park,
NC,
Quality
Assurance
Division,
Environmental
Monitoring
Systems
Laboratory,
U.
S.
Environmental
Protection
Agency
EPA.
1992.
Specification
and
Guidance
for
Obtaining
Contaminant­
Free
Sample
Containers.
Directive
No.
9240.0
 
5A,
Office
of
Solid
Waste
and
Emergency
Response,
U.
S.
Environmental
Protection
Agency
EPA.
1994a.
Laboratory
Guidelines
for
Evaluating
Organics
Analyses,
EPA/
540/
R/
94/
082,
U.
S.
Environmental
Protection
Agency
EPA.
1994b.
Laboratory
Guidelines
for
Evaluating
Inorganics
Analyses,
EPA/
540/
R194/
083,
U.
S.
Environmental
Protection
Agency
EPA.
1995.
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods,
Third
Edition,
Final
Update
I
and
Final
Update
II,
SW­
846,
U.
S.
Environmental
Protection
Agency
EPA.
1996.
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods,
Third
Edition.
SW­
846,
U.
S.
Environmental
Protection
Agency
EPA.
1997.
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods,
Rev.
2,
Third
Edition,
including
Final
Update
III,
SW­
846,
U.
S.
Environmental
Protection
Agency
Gilbert,
Richard
O.
1987.
Statistical
Methods
for
Environmental
Pollution
Monitoring.
New
York,
Van
Nostrand
Reinhold
Lockheed.
1995.
Position
for
Determining
Gas
Phase
Volatile
Organic
Compound
Concentrations
in
Transuranic
Waste
Containers,
INEL­
95/
0109/
Revision
1,
M.
J.
Connolly,
et.
al.,
Lockheed
Idaho
Technologies
Company
NMED.
Waste
Isolation
Pilot
Plant
(
WIPP)
Hazardous
Waste
Permit,
New
Mexico
Environment
Department,
#
NM4890
139088­
TSDF
TRUPACT
­
II
SARP.
Safety
Analysis
Report
for
the
TRUPACT­
Il
Shipping
Package
(
SARP).
U.
S.
NRC
Docket
No.
71­
9218
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202
E.
GLOSSARY
E­
1
Acronyms
and
Abbreviations
ACMM
Analytical
Chemistry
Methods
Manual
AK
Acceptable
Knowledge
ALARA
as
low
as
reasonably
achievable
ALD
Analytical
Laboratories
Department
AMWTF
Advanced
Mixed
Waste
Treatment
Facility
AMWTP
Advanced
Mixed
Waste
Treatment
Project
ASTM
American
Society
for
Testing
and
Materials
BFB
4­
bromofluorobenzene
BNFL
Inc.
British
Nuclear
Fuel
Limited
Incorporated
BIR
Waste
Isolation
Pilot
Plant
Transuranic
Waste
Baseline
Inventory
Report
(
DOE
1995b)
C
degrees
Celsius
%
C
percent
complete
CAO
Carlsbad
Area
Office
CAR
Corrective
Action
Report
CAS
chemical
abstract
services
CBFO
Carlsbad
Field
Office
CCC
calibration
check
compounds
CCV
continuing
calibration
verification
CFR
Code
of
Federal
Regulations
CH
contact­
handled
CH­
TRU
contact­
handled
transuranic
COC
Chain­
of­
Custody
CVAA
Cold
Vapor
Atomic
Absorption
Spectrometry
%
D
percent
difference
D&
D
Decommissioning
&
Decontamination
DFTPP
decafluorotriphenylphosphine
DOE
U.
S.
Department
of
Energy
DOT
U.
S.
Department
of
Transportation
DQO
Data
Quality
Objective
EPA
Environmental
Protection
Agency
FID
Flame
Ionization
Detector
FRC
Federal
Records
Center
FRS
Field
Reference
Sample
FTIRS
Fourier
Transform
Infrared
Spectroscopy
g
gram
GC
Gas
Chromatography
GC/
ECD
Gas
Chromatography/
Electron
Capture
Detection
GC/
FID
Gas
Chromatography/
Flame
Ionization
Detection
GC/
MS
Gas
Chromatography/
Mass
Spectrometry
HSGS
Headspace
Gas
Sampling
HWN
hazardous
waste
number
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HWMA
Hazardous
Waste
Management
Act
ICP­
AES
Inductively
Coupled
Plasma­
Atomic
Emission
Spectroscopy
ICS
interference
check
standards
ICV
initial
calibration
verification
ID
Idaho
IDC
Item
Description
Code
IDL
Instrument
Detection
Limit
INEL
Idaho
National
Engineering
Laboratory
INEEL
Idaho
National
Engineering
and
Environmental
Laboratory
INST
instruction
INTEC
Idaho
Nuclear
Technology
and
Engineering
Center
ITR
Independent
Technical
Review
kg
kilogram
L
liter
LCS
Laboratory
Control
Sample
LDR
Land
Disposal
Restrictions
LLW
low­
level
waste
µ
g/
L
micrograms
per
liter
M&
O
management
and
operations
MDL
method
detection
limit
mg/
kg
milligrams
per
kilogram
mg/
L
milligrams
per
liter
mL
milliliter
mm
millimeter
mm
Hg
millimeters
mercury
MMDDYY
Month­
Day­
Year
Format
MP
Management
Procedure
MSD
matrix
spike
duplicate
MSDS
Material
Safety
Data
Sheet
nCi/
g
nanocuries
per
gram
NCR
Nonconformance
Report
NDA
Nondestructive
Assay
NDE
nondestructive
examination
NDT
Nondestructive
Testing
ng
nanogram
NIST
National
Institute
of
Standards
and
Technology
NMED
New
Mexico
Environment
Department
NRC
Nuclear
Regulatory
Commission
OLCS
on­
line
control
sample
OSHA
Occupational
Safety
and
Health
Administration
OJT
on­
the­
job
training
PA
Performance
Assessment
PCB
Polychlorinated
biphenyl
PDP
Performance
Demonstration
Program
ppm
parts
per
million
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ppmv
parts
per
million
by
volume
PRDL
Program
Required
Detection
Limit
PRQL
Program
Required
Quantitation
Limit
psig
pounds
per
square
inch
gauge
pt
point
QA
Quality
Assurance
QAO
Quality
Assurance
Objective
QA/
QC
Quality
Assurance/
Quality
Control
QAPD
Quality
Assurance
Program
Document
QAPjP
Quality
Assurance
Project
Plan
QC
Quality
Control
QPP
Quality
Program
Plan
r
regression
coefficient
%
R
percent
recovery
RA
Radioassay
RCRA
Resource
Conservation
and
Recovery
Act
RCT
Radiation
Control
Technician
RH
remote­
handled
RIDS
Records
Inventory
and
Disposition
Schedule
RPD
Relative
percent
difference
RRF
relative
response
factor
RT
retention
time
RTL
Regulatory
Threshold
Limit
RTR
real­
time
radiography
%
RSD
percent
relative
standard
deviation
RWMC
Radioactive
Waste
Management
Complex
SARP
Safety
Analysis
Report
for
the
TRUPACT­
II
Shipping
Package
SME
Subject
Matter
Expert
SOP
Standard
Operating
Procedure
SPCC
System
performance
check
compound
SPM
Site
Project
Manager
SPO
Site
Project
Office
SQAO
Site
Quality
Assurance
Officer
SVOC
Semivolatile
organic
compound
SW­
846
EPA
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods
SWB
Standard
Waste
Box
TC
Toxicity
Characteristic
TCLP
Toxicity
Characteristic
Leaching
Procedure
TCO
Transportation
Certification
Official
TDOP
Ten
Drum
Overpack
TIC
Tentatively
Identified
Compound
TID
Tamper
Indicating
Device
TRAMPAC
TRUPACT­
II
Authorized
Methods
for
Payload
Control
(
Nuclear
Packaging
Inc.
1992,
Appendix
1.3.7)
TRU
Transuranic
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205
TRUCON
TRUPACT­
II
Content
Codes
(
DOE
1992)
TRUPACT­
II
Transuranic
Package
Transporter
Model
II
TSCA
Toxic
Substance
Control
Act
TSDF
Treatment
Storage
Disposal
Facility
TWBIR
TRU
Waste
Baseline
Inventory
Report
UCL90
upper
90%
confidence
level
UHWM
Uniform
Hazardous
Waste
Manifest
VE
Visual
Examination
VEE
Visual
Examination
Expert
VOA
volatile
organic
analysis
VOC
volatile
organic
compound
VTSR
validated
time
of
sample
receipt
WAC
waste
acceptance
criteria
WCO
Waste
Certification
Official
WIPP
Waste
Isolation
Pilot
Plant
WIPP­
WAC
Waste
Isolation
Pilot
Plant­
Waste
Acceptance
Criteria
WIPP­
WAP
Waste
Analysis
Plan
for
the
Waste
Isolation
Pilot
Plant,
Attachment
B
of
the
WIPP
Hazardous
Waste
Facility
Permit
WSPF
Waste
Stream
Profile
Form
WTS
Waste
Tracking
System
WWIS
WIPP
Waste
Information
System
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206
E­
2
Definitions
Absolute
Pressure.
Pressure
measured
relative
to
absolute
zero
pressure.

Accuracy.
The
degree
of
agreement
between
a
measured
value
and
an
accepted
reference
or
the
true
value.
Accuracy
is
determined
as
the
percent
recovery
(%
R).

Analyte.
The
element,
ion,
or
compound
the
analysis
seeks
to
determine;
the
element
of
interest.

Analytical
Batch.
A
suite
of
samples
of
a
similar
matrix
(
that
is,
gas
or
solid)
processed
as
a
unit,
using
the
same
analytical
method,
within
a
specific
time
period.
An
analytical
batch
can
be
up
to
20
samples
(
excluding
laboratory
QC
samples),
all
of
which
must
be
received
by
the
laboratory
within
14
days
of
the
validated
time
of
sample
receipt
(
VTSR)
of
the
first
sample
of
the
batch.

Analytical
Method.
Defines
the
sample
preparation
and/
or
instrumentation
procedure
that
must
be
performed
to
estimate
the
quantity
of
one
or
more
analytes
in
a
sample.

Analytical
Sample.
Any
solution
or
media
introduced
into
an
instrument
on
which
an
analysis
is
performed,
excluding
instrument
calibration,
initial
calibration
verification,
initial
calibration
blank,
continuing
calibration
verification,
and
continuing
calibration
blank.
Note
the
following
are
all
defined
as
analytical
samples:
TRU
waste
samples,
duplicate
samples,
spiked
samples,
laboratory
control
samples,
and
field
and
manifold
blanks.

Audit.
A
planned
and
documented
independent
assessment
to
determine
by
investigation,
examination,
or
evaluation
of
objective
evidence,
the
adequacy
of,
and
compliance
with
established
procedures,
instructions,
drawings,
and
other
applicable
documents,
and
the
effectiveness
of
implementation.
An
audit
should
not
be
confused
with
surveillance
or
inspection
activities
performed
for
the
sole
purpose
of
process
control
or
product
acceptance.

Base
Materials.
Those
materials
that
make
up
individual
items
in
debris
waste.
Base
materials
may
include,
but
are
not
limited
to:
glass,
metals,
or
organic
compounds.

Calibration.
(
A)
The
process
of
establishing
the
accuracy
of
measurement
and
test
equipment;
(
B)
the
check
or
correction
of
accuracy
of
a
measuring
instrument
to
ensure
proper
operational
characteristics
(
see
"
counter");
(
C)
the
comparison
of
a
measurement
standard
or
item
of
test
and
measurement
and
test
equipment
of
unknown
accuracy
to
a
standard
or
instrument
of
known
accuracy
to
detect,
correlate,
report,
or
eliminate
by
adjustment,
any
variation
(
deviation)
in
the
accuracy
of
the
item
being
compared;
(
D)
the
establishment
of
a
curve
relating
the
measurement
and
test
equipment
response
to
analyte
amount
or
concentration
based
on
analyses
with
analytes
of
known
amount
or
concentration.

Calibration
Blank.
An
analyte­
free
matrix
used
to
establish
zero­
response
during
calibration.

Chain­
of­
Custody
(
COC).
A
set
of
procedures
established
to
ensure
sample
and
data
integrity
is
maintained.

Comparability.
A
qualitative
parameter
expressing
the
confidence
with
which
one
data
set
can
be
compared
with
another.
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207
Completeness.
The
percentage
of
measurements
made
that
are
judged
to
be
valid
measurements.
The
completeness
goal
is
to
generate
a
sufficient
amount
of
valid
data
based
on
Program
needs.

Container.
DOT­
approved
container
(
serialized
white
drum
or
metal
box)
for
shipping
radioactive
or
mixed
waste
via
TRUPACT­
II.

Continuing
Calibration.
Analytical
standards
run
periodically
to
verify
the
calibration
of
the
analytical
system.

Control
Limits.
A
range
within
which
specified
measurement
results
must
fall
to
be
compliant.
Control
limits
may
be
mandatory,
requiring
corrective
action
if
exceeded,
or
advisory,
requiring
that
noncompliance
data
be
flagged.

Corrective
Action.
Measures
taken
to
rectify
conditions
adverse
to
quality
and,
where
necessary,
to
preclude
repetition.

Curie
(
Ci).
A
unit
of
radioactivity
equal
to
3.7
x
1010
disintegrations
per
second;
a
nanocurie
(
nCi)
is
10­
9Ci
or
37
disintegrations
per
second.

Data
Quality
Objectives
(
DQOs).
Qualitative
and
quantitative
statements
derived
from
the
outputs
of
the
first
six
steps
of
the
DQO
Process..
DQOs:
1)
clarify
the
study
objective,
2)
define
the
most
appropriate
type
of
data
to
collect,
3)
determine
the
most
appropriate
conditions
from
which
to
collect
the
data,
and
4)
specify
tolerable
limits
on
decision
errors
be
used
as
the
basis
for
establishing
the
quantity
and
quality
of
data
needed
to
support
compliance
decisions.
DQOs
are
used
to
develop
a
scientific
and
resource­
effective
data
collection
design.

Data
Reduction.
Operations
necessary
to
correct
data
from
raw
to
final
form,
as
required
by
the
customer.

Equipment
Blanks.
Samples
of
high
purity
gas
or
water
used
to
establish
cleanness
of
sampling
equipment.
They
are
collected
after
the
equipment
has
been
cleaned
and
before
sampling.
These
blanks
are
useful
in
documenting
adequate
cleaning
of
sampling
equipment.

Equipment
Cleaning
Batch.
A
number
of
sampling
equipment
items
cleaned
together
at
one
time
using
the
same
cleaning
method.

Field
Blank.
A
background
sample
collected
in
the
field
in
the
immediate
vicinity
of
the
sample
collection
location;
field
blanks
accompany
sample
containers
through
collection,
shipment
to
the
analytical
laboratory,
and
storage
before
analysis
and
are
used
to
identify
any
contamination
from
field
conditions.

Field
Duplicate.
Two
separate,
independent
samples
collected
from
the
same
source,
as
closely
as
possible
to
the
same
place
and
time,
stored
in
separate
containers,
independently
labeled
and
independently
analyzed
to
document
the
precision
of
the
sampling
and
analysis
process.

Field
Sample.
A
portion
of
material
received
for
analysis
contained
in
single
or
multiple
containers
and
identified
by
a
unique
DOE
Sample
Number.
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208
Field
Reference
Sample
(
FRS).
Standard
samples
of
known
concentration
of
target
analytes,
introduced
through
the
sampling
equipment,
to
identify
any
bias
in
the
sampling
process.

Headspace.
For
any
volume
contained
by
a
drum,
55­
gal
poly
bag,
or
innermost
layer
of
confinement,
the
total
contained
volume
minus
the
volume
occupied
by
the
waste
material.
"
Headspace"
is
also
used
to
refer
to
the
gases
contained
in
this
volume.

Holding
Time.
The
maximum
time
allowed
between
time
of
sample
collection
and
time
of
preparation
or
analysis.

Independent
Assessment.
A
QA
program
assessment
conducted
by
an
independent
group
or
organization,
having
authority
and
freedom
from
the
line
organization,
to
evaluate
the
scope,
status,
adequacy,
programmatic
compliance,
and
implementation
effectiveness
of
the
quality
assurance
program.

Item
Description
Code
(
IDC).
A
three­
character
numeric
code
that
describes
each
waste
form
matrix.

Instrument
Detection
Limit
(
IDL).
The
minimum
signal
that
the
instrument
can
detect
with
99%
confidence
that
the
analyte
concentration
is
greater
than
0.

Innermost
Layer
of
Confinement.
Within
a
waste
container,
a
plastic
bag
closest
to
a
waste
source
that
may
be
a
source
of
VOCs
and/
or
hydrogen
and
methane
and
has
a
minimum
of
1
L
of
headspace.

Laboratory
Duplicate.
A
second
aliquot
portion
of
a
sample
treated
and
analyzed
identically
to
the
original;
used
to
determine
the
precision
of
the
method.

Laboratory
Blank.
An
analyte­
free
matrix
to
which
all
reagents
are
added
in
the
same
volumes
or
proportions
used
in
sample
processing;
used
to
document
contamination
resulting
from
laboratory
sample
preparation
and
the
analytical
process.

Laboratory
Control
Sample.
A
standard
of
known
composition
used
to
indicate
method
accuracy.
Laboratory
control
samples
are
analyzed
using
the
same
analytical
methods
employed
for
the
Program
samples
received.

Lot.
When
all
waste
within
a
waste
stream
is
not
available
for
sampling
and
analysis
at
one
time,
the
waste
stream
may
be
divided
into
waste
stream
lots
based
on
staging,
transportation,
or
handling
issues.
Characterization
activities
are
then
undertaken
on
a
waste
stream
lot
basis.
A
WSPF
is
not
submitted
for
subsequent
waste
stream
lots
unless
warranted
by
the
characterization
information.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

209
Management
Assessment.
A
self
determination
of
managerial
effectiveness
in
establishing
and
implementing
quality
assurance
program
plans
that
conform
to
U.
S.
DOE
policy
requirements.
It
is
based
on
an
analysis
of
functional
appraisals,
internal
audits,
and
other
information,
and
on
the
application
of
appropriate
criteria.
It
is
a
review
and
evaluation
of
management
performance
covering
all
QA
and
management
responsibilities
to
ensure
proper
QA
program
balance.

Management
Controls.
Methods
used
to
ensure
work
is
performed
compliant
with
applicable
regulations
and
program
requirements.
Examples
of
management
controls
include,
but
are
not
limited
to,
procedures,
training,
radiological
posting,
established
time
limits,
and
storage
practices.

Waste
matrix
code.
A
collection
of
descriptive
titles,
definitions,
and
associated
numerical
codes
used
to
classify
mixed
waste
at
DOE
facilities.
Waste
matrix
codes
are
defined
in
DOE/
LLW­
217,
DOE
Waste
Treatability
Group
Guidance.

Method
Detection
Limit
(
MDL).
The
minimum
concentration
of
a
substance
that
can
be
measured
and
reported
for
a
given
method
with
99%
confidence
that
the
analyte
concentration
is
greater
than
0.

Needle
Assembly
Batch.
Assembly
of
the
sampling
needle
components
used
for
manual
sample
collection
with
SUMMA
 
canisters.
Equipment
blanks
are
collected
using
randomly
selected
assemblies
analyzed
for
contaminants.
Cleanness
certification
of
the
needle
assembly
batch
is
based
on
the
analytical
results
of
the
equipment
blanks.

Nonconformance.
A
deficiency
in
meeting
program
requirements
that
renders
the
quality
of
an
item
or
sample
unacceptable
or
indeterminate.
Nonconforming
program
data
are
final
reported
data
that
do
not
meet
QA
objectives.

Nondestructive
Assay
(
NDA).
the
measurement
of
radioactivity
and/
or
radionuclide
specific
activity
determined
without
destroying
the
material.

Nondestructive
Testing
(
NDT).
Groups
of
tests,
such
as
RTR,
that
evaluate
an
item
conformance
without
destroying
it
or
modifying
the
physical
state
of
the
sample.

Packaging.
Flexible
containment
materials,
for
example,
plastic
bags
(
Program­
specific
material
definition).

Performance
Assessment
(
PA).
A
determination
of
the
long­
term
performance
of
WIPP
disposal
system
per
the
requirements
of
the
U.
S.
Environmental
Protection
Agency
Standard
40
CFR
Part
191,
Subparts
B
and
C.

Percent
Difference
(%
D).
The
difference
between
an
initial
measurement
and
a
subsequent
one,
expressed
as
a
percentage
of
the
initial
measurement.

Program­
Required
Detection
Limit
(
PRDL).
Minimum
level
of
analyte
detection
acceptable
under
the
WIPPWAP

Precision.
A
measurement
of
mutual
agreement
among
individual
measurements
of
the
same
property,
made
under
prescribed
similar
conditions;
often
expressed
in
terms
of
standard
deviation
or
relative
percent
difference
(
RPD).
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

210
Procedure/
Instruction.
A
written,
formally
approved
and
controlled,
step­
by­
step
sequence
of
detailed
actions
to
be
followed
to
perform
a
given
task.

Program­
Required
Quantitation
Limit
(
PRQL).
Minimum
level
of
analyte
quantitation
acceptable
under
the
WIPP­
WAP.

QA.
Planned
and
systematic
actions
necessary
to
provide
adequate
confidence
that
a
facility,
structure,
system,
or
component
will
perform
satisfactorily
and
safely
in
service.

QC.
A
routine
application
of
procedures
for
controlling
a
process.

Quality
Assurance
Objectives.
The
characteristics
of
data
associated
with
data
ability
to
satisfy
a
given
purpose
or
objective.
The
characteristics
of
major
importance
are
accuracy,
precision,
completeness,
comparability
and
representativeness.

Radioassay
(
RA).
Assay
methods
used
to
identify
and
quantify
radionuclides
in
TRU
waste.

Representativeness.
The
degree
to
which
sample
data
accurately
and
precisely
represent
a
characteristic
of
a
population,
parameter
variations
at
a
sampling
point,
or
an
environmental
condition.

Radiation
Technician
(
RT).
Job
title
of
personnel
who
provide
radiation
protection
through
controls
and
monitoring
of
areas,
items,
and
personnel.

Real­
time
Radiography
(
RTR).
A
radiographic
method
that
allows
simultaneous
remote
imaging
for
the
viewing
of
waste
package
contents.

Sample.
A
portion
of
material
for
analysis
contained
in
a
single
container
and
identified
by
a
unique
sample
number.

Sample
Number.
A
unique
sample
identification
number;
appears
on
all
sample
reports
that
document
information
or
results
derived
from
that
sample.

Sampling
Batch.
A
suite
of
samples
of
a
similar
matrix
(
that
is,
gas
or
solid)
collected
consecutively
using
the
same
sampling
equipment
within
a
specific
time
period.
A
sampling
batch
can
be
up
to
20
samples
(
excluding
filed
QC
samples),
all
of
which
must
be
collected
within
14
days
of
the
first
sample
in
the
batch.
Also
refer
to
"
Analytical
Batch."

SUMMA
®
.
A
stainless­
steel
pressure
vessel
with
SUMMA
®
passivated
interior
surfaces
for
collection
and
stable
storage
of
gas
samples
and
many
specific
organic
compounds.

TRUPACT­
II
Standard
Waste
Box
(
SWB).
A
container
for
solid
radioactive
waste.

Transportation
Certification
Official
(
TCO).
The
person
who
certifies
that
the
shipment
meets
transportation
requirements
of
EPA,
WIPP­
WAC,
DOE,
and
DOT.
AMWTP
MANAGEMENT
PROCEDURE
User
responsible
to
ensure
correct
revision
is
used
MP­
TRUW­
8.2,
Rev
2
Issued:
03/
31/
03
Effective:
03/
31/
03
Quality
Assurance
Project
Plan
(
QAPjP)

211
Tamper
Indicating
Device
(
TID).
A
device
that
may
be
used
on
packages
to
reveal
violations
of
containment
integrity.

Testing
Batch.
A
suite
of
waste
containers
undergoing
radiography
or
radioassay
using
the
same
testing
equipment.
A
testing
batch
can
be
up
to
20
waste
containers
without
regard
to
waste
matrix.

TRU
Waste.
Without
regard
to
source
or
form,
waste
contaminated
with
alpha­
emitting
TRU
radionuclides
with
half­
lives
greater
than
20
years
and
concentrations
greater
than
100
nanocuries
per
gram
(
nCi/
g)
at
the
time
of
assay.

TRUCON.
TRUPACT­
II
Content
Codes
document
developed
to
show
wastes
characterized
and
grouped
together
for
controlling
the
payload
(
authorized
contents)
in
a
TRUPACT­
II,
(
refer
to
DOE
WIPP
89­
004).

TRUPACT­
II.
An
NRC
approved
Type­
B
shipping
container
for
shipping
TRU
radioactive
waste.

Validate.
To
confirm
or
corroborate
that
data
resulting
from
a
characterization
process
are
usable.

Waste
Container.
Container
that
holds
waste
items.

Waste
Package.
Individual
items
placed
into
waste
collection
boxes
and
drums.

Waste
Stream.
Waste
material
generated
from
a
single
process
or
activity
similar
in
material,
physical
form,
and
hazardous
constituents.

Waste
Type.
The
classification
system
describing
the
physical
types
of
waste,
solidified
inorganics
(
Waste
Type
I),
solid
inorganics
(
Waste
Type
II),
solidified
organics
(
Waste
Type
III,)
and
solid
organics
(
Waste
Type
IV)
per
the
Safety
Analysis
Report
for
the
TRUPACT­
II
Shipping
Package
(
SARP)
(
NRC
Docket
No
71­
9218).

Waste
Certification
Official
(
WCO).
The
person
who
affirms
by
signature
that
waste
meets
all
WIPP­
WAC
criteria
for
offsite
shipment.
