	PAGE 1

Rocky Flats

Environmental Technology Site

95-QAPjP-0050

Version 9

ROCKY FLATS ENVIRONMENTAL TECHNOLOGY SITE TRU WASTE CHARACTERIZATION
PROGRAM QUALITY ASSURANCE PROJECT PLAN

Responsible K-H Organization:  TRU Waste Programs			Effective Date:	    
  02/11/2004	

Approved By:  RFETS TWCP Site Project Manager 		/		2/5/04	

		Title	Date                     

           G.A. O’Leary				/		/S/					

Print Name							Approval Signature

Review/concurrence documentation is contained in the Document History
File.

IMPORTANT NOTES

ISR review not required.	This plan supersedes 95-QAPjP-0050, Version 8.

SES/USQD review not required.	Periodic Review Frequency:  1 year from
effective date.



	 

		Exempt from Classification Review

	Exemption Number: CEX-032-00		

This page is intentionally blank

APPROVALS

The approvals listed below apply to Version 9 of this document.

Approved by:

Kerry W. Watson   /S/			2/3/04	

CBFO Assistant Manager, National TRU Program (Kerry W. Watson)	Date

Martin P. Navarette for A. L. Holland   /S/			2/2/04	

CBFO Quality Assurance Manager (Ava Holland)	Date

Lam Xuan   /S/			1/28/04	

DOE Rocky Flats Field Office (Lam Xuan)	Date

G. A. O’Leary   /S/			1/28/04	

RFETS TWCP Site Project Manager (G.A. O’Leary)	Date

C. L. Ferrera   /S/			1/28/04	

RFETS TWCP Site Project Quality Assurance Officer (C.L. Ferrera)	Date



This page is intentionally blank

TABLE OF CONTENTS

Section	Page

	TITLE PAGE	1

	APPROVALS	3

	TABLE OF CONTENTS	5

	Version change summary	14

Chapter 	Page

  TOC \o \t "LEVEL 1,1,LEVEL 2,2,LEVEL 3,3,LEVEL 4,4"  

A.	Introduction	  PAGEREF _Toc43090703 \h  17 

A-1	Scope		  PAGEREF _Toc43090704 \h  17 

A-2	Overview	  PAGEREF _Toc43090705 \h  17 

A-3	Description of RFETS	  PAGEREF _Toc43090706 \h  18 

A-4	Project Description	  PAGEREF _Toc43090707 \h  19 

A-5	RFETS Organization and Responsibilities	  PAGEREF _Toc43090708 \h 
21 

A-5a	TWCP Site PM	  PAGEREF _Toc43090709 \h  21 

A-5a(1)	Project Data Control Officer (PDCO)	  PAGEREF _Toc43090710 \h 
23 

A-5a(2)	Headspace Analytical Services	  PAGEREF _Toc43090711 \h  24 

A-5b	TWCP Site PQAO	  PAGEREF _Toc43090712 \h  25 

A-5c	Technical Operations	  PAGEREF _Toc43090713 \h  26 

A-5c(1)	Waste Systems	  PAGEREF _Toc43090714 \h  26 

A-5c(2)	Waste Requirements Group	  PAGEREF _Toc43090715 \h  27 

A-5d	Waste Operations	  PAGEREF _Toc43090716 \h  27 

A-5d(1)	Nondestructive Testing (NDT)	  PAGEREF _Toc43090717 \h  28 

A-5e	TRU Waste Certification Official (WCO)	  PAGEREF _Toc43090718 \h 
29 

A-5f	Material Stewardship QA Manager	  PAGEREF _Toc43090719 \h  30 

A-5f(1)	Headspace Analytical Services Quality Assurance Officer (HASQAO)
  PAGEREF _Toc43090720 \h  30 

A-5g	Remediation, Industrial D&D, and Site Services (RISS)	  PAGEREF
_Toc43090721 \h  31 

A-5g(1)	Analytical Laboratories Manager	  PAGEREF _Toc43090722 \h  31 

A-5g(2)	Analytical Laboratories Project Quality Assurance Officer
(LPQAO)	  PAGEREF _Toc43090723 \h  32 

A-5h	Building Closure Projects	  PAGEREF _Toc43090724 \h  33 

A-5h(1)	Waste Generators	  PAGEREF _Toc43090725 \h  33 

A-5i	INEEL TWCP Responsibilities	  PAGEREF _Toc43090726 \h  33 

A-6	Hierarchy of Documents	  PAGEREF _Toc43090727 \h  34 

A-7	Indoctrination and Training	  PAGEREF _Toc43090728 \h  34 

B.	WASTE ANALYSIS PLAN	  PAGEREF _Toc43090729 \h  37 

B-1	Identification of TRU Waste to be Managed at the WIPP Facility	 
PAGEREF _Toc43090730 \h  39 

B-1a	Waste Stream Identification	  PAGEREF _Toc43090731 \h  39 

B-1b	Waste Summary Category Groups and Hazardous Waste Accepted at the
WIPP Facility	  PAGEREF _Toc43090732 \h  39 

B-1c	Waste Prohibited at the WIPP Facility	  PAGEREF _Toc43090733 \h  39


B-1d	Control of Waste Acceptance	42

B-1e	Waste Generating Processes at the WIPP Facility (termed “derived
waste”)	  PAGEREF _Toc43090734 \h  42 

B-2	Waste Parameters	  PAGEREF _Toc43090735 \h  42 

B-3	Characterization Methods	  PAGEREF _Toc43090736 \h  43 

B-3a	Sampling and Analytical Methods	  PAGEREF _Toc43090737 \h  43 

B-3a(1)	Headspace Gas Sampling and Analysis	  PAGEREF _Toc43090738 \h 
43 

B-3a(2)	Homogeneous Waste Sampling and Analysis	  PAGEREF _Toc43090739
\h  45 

B-3a(3)	Laboratory Qualification	  PAGEREF _Toc43090740 \h  45 

B-3b	Acceptable Knowledge	46

B-3c	Radiography and Visual Examination	  PAGEREF _Toc43090741 \h  46 

B-3d	Characterization Techniques and Frequency for Newly Generated and
Retrievably Stored Waste	  PAGEREF _Toc43090742 \h  48 

B-3d(1)	Newly Generated Waste	  PAGEREF _Toc43090743 \h  50 

B-3d(2)	Retrievably Stored Waste	  PAGEREF _Toc43090744 \h  52 

TABLE OF CONTENTS (continued)

Chapter	Page

B-4	Data Verification and Quality Assurance	  PAGEREF _Toc43090745 \h 
54 

B-4a	Data Generation and Project Level Verification Requirements	 
PAGEREF _Toc43090746 \h  54 

B-4a(1)	Data Quality Objectives	  PAGEREF _Toc43090747 \h  54 

B-4a(2)	Quality Assurance Objectives	  PAGEREF _Toc43090748 \h  55 

B-4a(3)	Sample Control	  PAGEREF _Toc43090749 \h  55 

B-4a(4)	Data Generation	  PAGEREF _Toc43090750 \h  56 

B-4a(5)	Data Verification	  PAGEREF _Toc43090751 \h  56 

B-4a(6)	Data Transmittal	  PAGEREF _Toc43090752 \h  56 

B-4a(7)	Records Management	  PAGEREF _Toc43090753 \h  57 

B-4b	WIPP Facility Level: Waste Screening and Verification of TRU Waste	
 PAGEREF _Toc43090754 \h  58 

B-4b(1)	Phase I Waste Stream Screening and Verification	  PAGEREF
_Toc43090755 \h  58 

B-4b(2)	Phase II Waste Shipment Screening and Verification	  PAGEREF
_Toc43090756 \h  59 

B1.	WASTE CHARACTERIZATION SAMPLING METHODS	  PAGEREF _Toc43090757 \h 
79 

B1-1	Headspace Gas Sampling	  PAGEREF _Toc43090758 \h  79 

B1-1a	Method Requirements	  PAGEREF _Toc43090759 \h  79 

B1-1a(1)	Summary Category S5000 Requirements	  PAGEREF _Toc43090760 \h 
79 

B1-1a(2)	Summary Category S3000/S4000 Requirements	  PAGEREF
_Toc43090761 \h  80 

B1-1a(3)	General Requirements	  PAGEREF _Toc43090762 \h  81 

B1-1a(4)	Manifold Headspace Gas Sampling	  PAGEREF _Toc43090763 \h  85 

B1-1a(5)	Direct Canister	  PAGEREF _Toc43090764 \h  87 

B1-1a(6)	Sampling Heads	  PAGEREF _Toc43090765 \h  88 

B1-1b	Quality Control	  PAGEREF _Toc43090766 \h  91 

B1-1b(1)	Field Blanks	  PAGEREF _Toc43090767 \h  92 

B1-1b(2)	Equipment Blanks/Manifold Blank	  PAGEREF _Toc43090768 \h  93 

B1-1b(3)	Field Reference Standards	  PAGEREF _Toc43090769 \h  93 

B1-1b(4)	Field Duplicates	  PAGEREF _Toc43090770 \h  93 

B1-1c	Equipment Testing, Inspection, and Maintenance	  PAGEREF
_Toc43090771 \h  94 

B1-1c(1)	Headspace Gas Sample Canister Cleaning	  PAGEREF _Toc43090772
\h  94 

B1-1c(2)	Sampling Equipment Initial Cleaning and Leak-Check	  PAGEREF
_Toc43090773 \h  94 

B1-1c(3)	Sampling Equipment Routine Cleaning and Leak-Check	  PAGEREF
_Toc43090774 \h  94 

B1-1c(4)	Manifold Cleaning After Field Reference Standard Collection	 
PAGEREF _Toc43090775 \h  95 

B1-1c(5)	Sampling Head Cleaning	  PAGEREF _Toc43090776 \h  95 

B1-1d	Equipment Calibration and Frequency	  PAGEREF _Toc43090777 \h  95 

B1-2	Sampling of Homogeneous Solids and Soil/Gravel	  PAGEREF
_Toc43090778 \h  96 

B1-2a	Method Requirements	  PAGEREF _Toc43090779 \h  96 

B1-2a(1)	Core Collection	  PAGEREF _Toc43090780 \h  96 

B1-2a(2)	Sample Collection	  PAGEREF _Toc43090781 \h  99 

B1-2b	Quality Control Requirements	  PAGEREF _Toc43090782 \h  99 

B1-2b(1)	Field Duplicates	  PAGEREF _Toc43090783 \h  99 

B1-2b(2)	Equipment Blanks	  PAGEREF _Toc43090784 \h  99 

B1-2b(3)	Sample Equipment Cleaning	  PAGEREF _Toc43090785 \h  100 

B1-2c	Equipment Testing, Inspection, and Maintenance	  PAGEREF
_Toc43090786 \h  101 

B1-2d	Equipment Calibration and Frequency	  PAGEREF _Toc43090787 \h  101


B1-3	Radiography	  PAGEREF _Toc43090788 \h  102 

B1-3a	Methods Requirements	  PAGEREF _Toc43090789 \h  102 

B1-3b	Quality Control	  PAGEREF _Toc43090790 \h  104 

B1-3b(1)	Formal Training	  PAGEREF _Toc43090791 \h  105 

B1-3b(2)	On-the-Job Training	  PAGEREF _Toc43090792 \h  105 

B1-3b(3)	Visual Examination (to Confirm RTR)	  PAGEREF _Toc43090793 \h 
108 

B1-3b(4)	Formal Training	  PAGEREF _Toc43090794 \h  110 

B1-3b(5)	On-the-Job Training	  PAGEREF _Toc43090795 \h  110 

TABLE OF CONTENTS (continued)

Chapter	Page

B1-4	Custody of Samples	  PAGEREF _Toc43090796 \h  111 

B1-4a	Gas Samples	  PAGEREF _Toc43090797 \h  112 

B1-4a(1)	Sequence of Activities for Gas Canisters, COC form, and Other
Sample Documents	  PAGEREF _Toc43090798 \h  112 

B1-4a(2)	COC Practices	  PAGEREF _Toc43090799 \h  115 

B1-4a(3)	Headspace Sample Size, and Sample Canister Holding Temperatures
and Storage

	Conditions	  PAGEREF _Toc43090800 \h  115 

B1-4a(4)	WIPP Sample Identification Number	  PAGEREF _Toc43090801 \h 
116 

B1-4a(5)	Canister Identification Number	  PAGEREF _Toc43090802 \h  116 

B1-4a(6)	Laboratory Sample Identification Number	  PAGEREF _Toc43090803
\h  116 

B1-4b	Homogeneous Solids and Soil/Gravel Sample Container	  PAGEREF
_Toc43090804 \h  117 

B1-4b(1)	Chain-of-Custody	  PAGEREF _Toc43090805 \h  117 

B1-4b(2)	Handling	  PAGEREF _Toc43090806 \h  117 

B1-4b(3)	Homogeneous Solids and Soil/Gravel Sample Containers	  PAGEREF
_Toc43090807 \h  118 

B1-5	Sample Packing and Shipping	  PAGEREF _Toc43090808 \h  119 

B2.	statistical methods used in sampling and analysis	  PAGEREF
_Toc43090809 \h  139 

B2-1	Approach for Statistically Selecting Waste Containers for Visual 

	Examination (to Confirm RTR)	  PAGEREF _Toc43090810 \h  139 

B2-2	Approach for Selecting Waste Containers for Statistical Sampling	 
PAGEREF _Toc43090811 \h  141 

B2-2a	Statistical Selection of Containers for Total (or TCLP) Analysis	 
PAGEREF _Toc43090812 \h  141 

B2-2b	Statistical Selection of Containers for Headspace Gas Analysis	 
PAGEREF _Toc43090813 \h  143 

B2-3	Upper Confidence Limit for Statistical Sampling	  PAGEREF
_Toc43090814 \h  144 

B2-3a	Upper Confidence Limit for Statistical Solid Sampling	  PAGEREF
_Toc43090815 \h  144 

B2-3b	Upper Confidence Limit for Statistical Headspace Gas Sampling	 
PAGEREF _Toc43090816 \h  144 

B2-4	Control Charting for Newly Generated Waste Stream Sampling	 
PAGEREF _Toc43090817 \h  145 

B3.	Quality assurance objectives and data validation techniques for
Waste characterization sampling and analytical methods	  PAGEREF
_Toc43090818 \h  149 

B3-1	Validation Methods	  PAGEREF _Toc43090819 \h  149 

B3-1a	Precision	  PAGEREF _Toc43090820 \h  149 

B3-1b	Accuracy	  PAGEREF _Toc43090821 \h  150 

B3-1c	Method Detection Limit	  PAGEREF _Toc43090822 \h  150 

B3-1d	Completeness	  PAGEREF _Toc43090823 \h  151 

B3-1e	Comparability	  PAGEREF _Toc43090824 \h  151 

B3-1f	Representativeness	  PAGEREF _Toc43090825 \h  152 

B3-1g	Nonconformance to DQOs	  PAGEREF _Toc43090826 \h  152 

B3-1h	Identification of Tentatively Identified Compounds	  PAGEREF
_Toc43090827 \h  152 

B3-2	Headspace Gas Sampling	  PAGEREF _Toc43090828 \h  155 

B3-2a	Quality Assurance Objectives	  PAGEREF _Toc43090829 \h  155 

B3-2b	Precision	  PAGEREF _Toc43090830 \h  155 

B3-2c	Accuracy	  PAGEREF _Toc43090831 \h  155 

B3-2d	Completeness	  PAGEREF _Toc43090832 \h  156 

B3-2e	Comparability	  PAGEREF _Toc43090833 \h  156 

B3-2f	Representativeness	  PAGEREF _Toc43090834 \h  157 

B3-3	Sampling of Homogeneous Solids and Soils/Gravel	  PAGEREF
_Toc43090835 \h  158 

B3-3a	Quality Assurance Objectives	  PAGEREF _Toc43090836 \h  158 

B3-3b	Precision	  PAGEREF _Toc43090837 \h  158 

B3-3c	Accuracy	  PAGEREF _Toc43090838 \h  159 

B3-3d	Completeness	  PAGEREF _Toc43090839 \h  159 

B3-3e	Comparability	  PAGEREF _Toc43090840 \h  159 

B3-3f	Representativeness	  PAGEREF _Toc43090841 \h  159 

TABLE OF CONTENTS (continued)

Chapter	Page

B3-4	Radiography	  PAGEREF _Toc43090842 \h  160 

B3-4a	Quality Assurance Objectives	  PAGEREF _Toc43090843 \h  160 

B3-4b	Precision	  PAGEREF _Toc43090844 \h  160 

B3-4c	Accuracy	  PAGEREF _Toc43090845 \h  160 

B3-4d	Completeness	  PAGEREF _Toc43090846 \h  161 

B3-4e	Comparability	  PAGEREF _Toc43090847 \h  161 

B3-5	Gas Volatile Organic Compound Analysis	  PAGEREF _Toc43090848 \h 
162 

B3-5a	Quality Assurance Objectives	  PAGEREF _Toc43090849 \h  162 

B3-5b	Precision	  PAGEREF _Toc43090850 \h  162 

B3-5c	Accuracy	  PAGEREF _Toc43090851 \h  162 

B3-5d	Calibration	  PAGEREF _Toc43090852 \h  163 

B3-5e	Method Detection Limit	  PAGEREF _Toc43090853 \h  163 

B3-5f	Program Required Quantitation Limit	  PAGEREF _Toc43090854 \h  163


B3-5g	Completeness	  PAGEREF _Toc43090855 \h  163 

B3-5h	Comparability	  PAGEREF _Toc43090856 \h  164 

B3-5i	Representativeness	  PAGEREF _Toc43090857 \h  164 

B3-5j	Method Performance Samples (MPS)	  PAGEREF _Toc43090858 \h  164 

B3-6	Total Volatile Organic Compound Analysis	  PAGEREF _Toc43090859 \h 
165 

B3-6a	Quality Assurance Objectives	  PAGEREF _Toc43090860 \h  165 

B3-6b	Precision	  PAGEREF _Toc43090861 \h  165 

B3-6c	Accuracy	  PAGEREF _Toc43090862 \h  166 

B3-6d	Calibration	  PAGEREF _Toc43090863 \h  167 

B3-6e	Method Detection Limit	  PAGEREF _Toc43090864 \h  167 

B3-6f	Program Required Quantitation Limit	  PAGEREF _Toc43090865 \h  167


B3-6g	Completeness	  PAGEREF _Toc43090866 \h  167 

B3-6h	Comparability	  PAGEREF _Toc43090867 \h  168 

B3-6i	Representativeness	  PAGEREF _Toc43090868 \h  168 

B3-7	Total Semivolatile Organic Compound Analysis	  PAGEREF _Toc43090869
\h  169 

B3-7a	Quality Assurance Objectives	  PAGEREF _Toc43090870 \h  169 

B3-7b	Precision	  PAGEREF _Toc43090871 \h  169 

B3-7c	Accuracy	  PAGEREF _Toc43090872 \h  170 

B3-7d	Calibration	  PAGEREF _Toc43090873 \h  171 

B3-7e	Method Detection Limit	  PAGEREF _Toc43090874 \h  171 

B3-7f	Program Required Quantitation Limit	  PAGEREF _Toc43090875 \h  171


B3-7g	Completeness	  PAGEREF _Toc43090876 \h  171 

B3-7h	Comparability	  PAGEREF _Toc43090877 \h  172 

B3-7i	Representativeness	  PAGEREF _Toc43090878 \h  172 

B3-8	Total or TCLP Metal Analysis	  PAGEREF _Toc43090879 \h  173 

B3-8a	Quality Assurance Objectives	  PAGEREF _Toc43090880 \h  173 

B3-8b	Precision	  PAGEREF _Toc43090881 \h  173 

B3-8c	Accuracy	  PAGEREF _Toc43090882 \h  174 

B3-8d	Calibration	  PAGEREF _Toc43090883 \h  175 

B3-8e	Program Required Detection Limits	  PAGEREF _Toc43090884 \h  175 

B3-8f	Program Required Quantitation Limit	  PAGEREF _Toc43090885 \h  175


B3-8g	Completeness	  PAGEREF _Toc43090886 \h  175 

B3-8h	Comparability	  PAGEREF _Toc43090887 \h  176 

B3-8i	Representativeness	  PAGEREF _Toc43090888 \h  176 

B3-9	Acceptable Knowledge	  PAGEREF _Toc43090889 \h  177 

TABLE OF CONTENTS (continued)

Chapter	Page

B3-10	Data Review, Validation, and Verification Requirements	  PAGEREF
_Toc43090890 \h  178 

B3-10a	Data Generation Level	  PAGEREF _Toc43090891 \h  179 

B3-10a(1)	Independent Technical Review	  PAGEREF _Toc43090892 \h  181 

B3-10a(2)	Technical Supervisor Review	  PAGEREF _Toc43090893 \h  182 

B3-10a(3)	QA Officer Review	  PAGEREF _Toc43090894 \h  183 

B3-10b	Project Level	  PAGEREF _Toc43090895 \h  183 

B3-10b(1)	TWCP Site PQAO Review	  PAGEREF _Toc43090896 \h  184 

B3-10b(2)	TWCP Site PM Review	  PAGEREF _Toc43090897 \h  185 

B3-10b(3)	Preparation of theTWCP Site PQAO Summary and the TWCP Site PM
Data Validation Summary	  PAGEREF _Toc43090898 \h  185 

B3-10b(4)	Preparation of the Waste Stream Characterization Package	 
PAGEREF _Toc43090899 \h  186 

B3-10b(5)	Sample Disposition	  PAGEREF _Toc43090900 \h  186 

B3-11	Reconciliation with Data Quality Objectives	  PAGEREF _Toc43090901
\h  187 

B3-11a	Reconciliation at the Project Level	  PAGEREF _Toc43090902 \h 
187 

B3-12	Data Reporting Requirements	  PAGEREF _Toc43090903 \h  189 

B3-12a	Data Generation Level to the Project Level	  PAGEREF _Toc43090904
\h  189 

B3-12b	Project Level to DOE/CBFO Level	  PAGEREF _Toc43090905 \h  189 

B3-12b(1)	Waste Stream Profile Form	  PAGEREF _Toc43090906 \h  190 

B3-12b(2)	Characterization Information Summary	  PAGEREF _Toc43090907 \h
 191 

B3-12b(3)	Waste Stream Characterization Package	  PAGEREF _Toc43090908
\h  191 

B3-12c	WIPP Waste Information System (WWIS)	  PAGEREF _Toc43090909 \h 
192 

B3-13	Nonconformances and Corrective Actions	  PAGEREF _Toc43090910 \h 
192 

B3-13a	Nonconformances	  PAGEREF _Toc43090911 \h  193 2

B3-13b	Corrective Actions	  PAGEREF _Toc43090912 \h  195 

B3-14	Special Training Requirements and Certification	  PAGEREF
_Toc43090913 \h  196 

B3-15	This section has been deleted	  PAGEREF _Toc43090914 \h  196 

B3-16	Hydrogen and Methane Analysis	  PAGEREF _Toc43090915 \h  197 

B3-16a	Methods Requirements	  PAGEREF _Toc43090916 \h  197 

B3-16b	Quality Control	  PAGEREF _Toc43090917 \h  197 

B3-16c	Instrument Testing, Inspection, and Maintenance Requirements	 
PAGEREF _Toc43090918 \h  197 

B4.	TRU WASTE CHARACTERIZATION USING ACCEPTABLE KNOWLEDGE	  PAGEREF
_Toc43090919 \h  221 

B4-1	Introduction	  PAGEREF _Toc43090920 \h  221 

B4-2	Acceptable Knowledge Documentation	  PAGEREF _Toc43090921 \h  222 

B4-2a	Required TRU Waste Management Program Information	  PAGEREF
_Toc43090922 \h  222 

B4-2b	Required TRU Waste Stream Information	  PAGEREF _Toc43090923 \h 
223 

B4-2c	Supplemental Acceptable Knowledge Documentation	  PAGEREF
_Toc43090924 \h  225 

B4-3	Acceptable Knowledge Training, Procedures and Other Requirements	 
PAGEREF _Toc43090925 \h  226 

B4-3a	Qualifications and Training Requirements	  PAGEREF _Toc43090926 \h
 226 

B4-3b	Acceptable Knowledge Assembly, Compilation, and Confirmation
Procedures and Required Administrative Controls	  PAGEREF _Toc43090927
\h  228 

B4-3b(1)	Procedures Used to Assemble the Acceptable Knowledge Record	 
PAGEREF _Toc43090928 \h  229 

B4-3b(2)	Procedures Used to Compile the Acceptable Knowledge Record	 
PAGEREF _Toc43090929 \h  229 

B4-3b(3)	Procedures Used to Ensure Unacceptable Waste is Identified and
Segregated	  PAGEREF _Toc43090930 \h  230 

B4-3b(4)	Procedures Used to Evaluate Acceptable Knowledge, Resolve
Discrepancies, Assign Hazardous Waste Numbers, etc.	  PAGEREF
_Toc43090931 \h  231 

B4-3b(5)	Procedures Used to Identify Hazardous Waste	  PAGEREF
_Toc43090932 \h  231 

B4-3b(6)	Procedures Used to Confirm Acceptable Knowledge and to
Re-Evaluate Acceptable Knowledge	  PAGEREF _Toc43090933 \h  232 

B4-3b(7)	Procedures Used to Cross-Reference to the Applicable Waste
Summary Category Group	  PAGEREF _Toc43090934 \h  234 

B4-3b(8)	Procedures Used to Ensure that Audit Results are Available	 
PAGEREF _Toc43090935 \h  234 

B4-3b(9)	Procedures Used for Administrative Control	  PAGEREF
_Toc43090936 \h  234 

B4-3c	Criteria for Assembling an Acceptable Knowledge Record and
Delineating the Waste Stream	  PAGEREF _Toc43090937 \h  236 

TABLE OF CONTENTS (continued)

Chapter	Page

B4-3d	Requirements for Confirmation of Acceptable Knowledge	  PAGEREF
_Toc43090938 \h  237 

B4-3d(1)	Re-Evaluation Based on RTR and Visual Examination	  PAGEREF
_Toc43090939 \h  238 

B4-3d(2)	TRU Heterogeneous Debris	  PAGEREF _Toc43090940 \h  238 

B4-3d(3)	Headspace Gas Sampling	  PAGEREF _Toc43090941 \h  239 

B4-3d(4)	Homogeneous Solids and Soil/Gravel	  PAGEREF _Toc43090942 \h 
240 

B4-3e	Acceptable Knowledge Data Quality Requirements	  PAGEREF
_Toc43090943 \h  241 

B4-3e(1)	Precision	  PAGEREF _Toc43090944 \h  241 

B4-3e(2)	Accuracy	  PAGEREF _Toc43090945 \h  241 

B4-3e(3)	Completeness	  PAGEREF _Toc43090946 \h  241 

B4-3e(4)	Comparability	  PAGEREF _Toc43090947 \h  241 

B4-3e(5)	Representativeness	  PAGEREF _Toc43090948 \h  242 

B4-3f	Audits of Acceptable Knowledge	  PAGEREF _Toc43090949 \h  242 

B4-4	Additional Final Confirmation of Acceptable Knowledge at the WIPP
Facility	  PAGEREF _Toc43090950 \h  243 

B5.	quality assurance project plan requirements	  PAGEREF _Toc43090951
\h  245 

B5-1	Site-Specific Quality Assurance Project Plan	  PAGEREF _Toc43090952
\h  245 

B5-2	Document Review, Approval, and Control	  PAGEREF _Toc43090953 \h 
245 

B5-3	Quality Assurance Records Management	  PAGEREF _Toc43090954 \h  247


B5-3a	Waste Records Center	  PAGEREF _Toc43090955 \h  247 

B5-3b	Flow of Data Records	  PAGEREF _Toc43090956 \h  248 

B5-4	QA Reports to Management	  PAGEREF _Toc43090957 \h  248 

B5-5	QA Grading	  PAGEREF _Toc43090958 \h  249 

B6.	RFETS audit and surveillance program	  PAGEREF _Toc43090959 \h  253 

B6-1	Internal Management Assessments and Independent Surveillances	 
PAGEREF _Toc43090960 \h  253 

B6-2	External Audits	  PAGEREF _Toc43090961 \h  253 

C.	RECORDS PROCESSING	  PAGEREF _Toc43090962 \h  255 

D.	REFERENCES	  PAGEREF _Toc43090963 \h  257 

D-1	External References	  PAGEREF _Toc43090964 \h  257 

D-2	RFETS References	  PAGEREF _Toc43090965 \h  261 

E.	Glossary	  PAGEREF _Toc43090966 \h  269 

E-1	Acronyms and Abbreviations	  PAGEREF _Toc43090967 \h  269 

E-2	Definitions	  PAGEREF _Toc43090968 \h  274 

 

TABLE OF CONTENTS (continued)

FIGURES AND TABLES 	Page

  TOC \t "TABLE TITLE,1"  Table B-1, Summary of Hazardous Waste
Characterization Requirements for         Transuranic Waste	  PAGEREF
_Toc43091108 \h  60 

Table B-2, Maximum Allowable VOC Room-Averaged HeadspaceConcentration   
                  Limits (PPMV)	  PAGEREF _Toc43091109 \h  66 

Table B-3, Headspace Gas: Target Analyte List and Methods	  PAGEREF
_Toc43091110 \h  67 

Table B-4, Required Organic Analyses and Test Methods Organized by
Organic         Analytical Groups	  PAGEREF _Toc43091111 \h  68 

Table B-5, Summary of Sample Preparation and Analytical Methods for
Metals	  PAGEREF _Toc43091112 \h  69 

Table B-6, Summary of Parameters, Characterization Methods, and
Rationale for CH Transuranic Waste	  PAGEREF _Toc43091113 \h  70 

Table B-7, Required Program Records Maintained in RFETS Project Files	 
PAGEREF _Toc43091114 \h  71 

Table B-8, WIPP Waste Information System Data Fields	  PAGEREF
_Toc43091115 \h  72 

Figure B-1, WIPP Waste Stream Profile Form	  PAGEREF _Toc43091116 \h  73


FIGURE b-2, DATA COLLECTION DESIGN FOR CHARACTERIZATION OF NEWLY
GENERATED WASTE	75

Figure B-3, Data Collection Design for Characterization of Retrievably
Stored Waste	  PAGEREF _Toc43091117 \h  76 

Figure B-4, Levels of Data Verification	  PAGEREF _Toc43091119 \h  77 

Figure B-5, TRU Mixed Waste Screening Flow Diagram	  PAGEREF
_Toc43091120 \h  78 

Table B1-1, Headspace Gas: SUMMA® Canisters, Canister Volumes and
Holding        Temperatures	  PAGEREF _Toc43091121 \h  120 

Table B1-2, Headspace Gas: Summary of Field Quality Control Sample
Frequencies	  PAGEREF _Toc43091122 \h  120 

Table B1-3, Headspace Gas: Summary of Field Quality Control Sample
Acceptance          Criteria	  PAGEREF _Toc43091123 \h  121 

Table B1-4, Sample Handling Requirements for Homogeneous Solids and
Soil/Gravel	  PAGEREF _Toc43091124 \h  121 

TABLE B1-5, HEADSPACE GAS DRUM AGE CRITERIA SAMPLING SCENARIOS	  PAGEREF
_Toc43091125 \h  122 

TABLE B1-6, SCENARIO 1 DRUM AGE CRITERIA (in days) MATRIX	  PAGEREF
_Toc43091126 \h  123 

TABLE B1-7, SCENARIO 2 DRUM AGE CRITERIA (in days) MATRIX	  PAGEREF
_Toc43091127 \h  124 

TABLE B1-8, SCENARIO 3 PACKAGING CONFIGURATION GROUPS	  PAGEREF
_Toc43091128 \h  125 

TABLE B1-9, SCENARIO 3 DRUM AGE CRITERIA (in days) MATRIX FOR S5000
WASTE BY PACKAGING CONFIGURATION GROUP	  PAGEREF _Toc43091129 \h  128 

TABLE B1-10, SCENARIO 3 DRUM AGE CRITERIA (in days) MATRIX FOR S3000 AND
S4000 WASTE BY PACKAGING CONFIGURATION GROUP	  PAGEREF _Toc43091130 \h 
130 

TABLE OF CONTENTS (continued)

FIGURES AND TABLES 	Page

Figure B1-1, Example of the Chain-of-Custody for Headspace Gas Sample
Canisters	  PAGEREF _Toc43091131 \h  132 

Figure B1-2, Example of the Sample Canister Information Document	 
PAGEREF _Toc43091132 \h  133 

Figure B1-3, Example of the Sample Canister Tag	  PAGEREF _Toc43091133
\h  134 

Figure B1-4, Example of the Chain-of-Custody/Sample Analysis Request
(WIPP)	  PAGEREF _Toc43091135 \h  135 

Figure B1-5, Example Custody Seal	  PAGEREF _Toc43091136 \h  136 

Figure B1-6, Overall Programmatic Approach to Visual Examination of the
Waste for Confirmation of RTR	  PAGEREF _Toc43091137 \h  137 

Figure B1-7, Headspace Gas Drum Age Criteria Sampling Scenario Selection
Process	  PAGEREF _Toc43091138 \h  138 

Table B2-1, Number of Waste Containers Requiring Visual Examination	 
PAGEREF _Toc43091139 \h  147 

Figure B2-1, Statistical Approach to Sampling and Analysis of Waste
Streams of   Retrievably Stored Homogeneous Solids and Soil/Gravel	 
PAGEREF _Toc43091140 \h  148 

Table B3-1, Physical form of waste (waste material parameter) and
Descriptions	  PAGEREF _Toc43091141 \h  198 

Table B3-2, Gas Volatile Organic Compounds Target Analyte List and
Quality            Assurance Objectives When Using SUMMA® Canisters or
On-Line Systems	  PAGEREF _Toc43091143 \h  199 

Table B3-3, Summary of Laboratory Quality Control Samples and
Frequenciesfor Gas Volatile Organic Compounds AnalysisWhen Using SUMMA®
Canisters or On-Line       Systems	  PAGEREF _Toc43091146 \h  200 

Table B3-4, Volatile Organic Compounds Target Analyte List and Quality
Assurance Objectives	  PAGEREF _Toc43091147 \h  201 

Table B3-5, Summary of Laboratory Quality Control Samples and
Frequencies for     Volatile Organic Compounds Analysis	  PAGEREF
_Toc43091148 \h  202 

Table B3-6, Semi-Volatile Organic Compounds Target Analyte List and
Quality          Assurance Objectives	  PAGEREF _Toc43091149 \h  203 

Table B3-7, Summary of Laboratory Quality Control Samples and
Frequencies for              Semi-Volatile Organic Compounds Analysis	 
PAGEREF _Toc43091150 \h  204 

Table B3-8, Metals Target Analyte List and Quality Assurance Objectives	
 PAGEREF _Toc43091151 \h  206 

Table B3-9, Summary of Laboratory QC Samples and Frequencies for Metals
Analysis	  PAGEREF _Toc43091152 \h  207 

TABLE B3-10, MINIMUM TRAINING AND QUALIFICATIONS REQUIREMENTS	  PAGEREF
_Toc43091153 \h  208 

Table B3-11, Testing Batch Data Report Contents	  PAGEREF _Toc43091154
\h  209 

Table B3-12, Sampling Batch Data Report Contents	  PAGEREF _Toc43091155
\h  212 

Table B3-13, Analytical Batch Data Report Contents	  PAGEREF
_Toc43091156 \h  215 

TABLE OF CONTENTS (continued)

FIGURES AND TABLES 	Page

Table B3-14, Data Reporting Flags	  PAGEREF _Toc43091157 \h  217 

Table B3-15, TC Levels Expressed as RTL Values in the Waste	  PAGEREF
_Toc43091158 \h  218 

Table B3-16A, Hydrogen and Methane Analysis Quality Assurance Objectives
  PAGEREF _Toc43091159 \h  219 

Table B3-16B, Summary of Laboratory Quality Control Samples and 
Frequencies for Hydrogen and Methane Analysis	  PAGEREF _Toc43091160 \h 
219 

Table B5-1, Minimum Requirements for Review, Approval, Implementation
and Control             of QAPjP	  PAGEREF _Toc43091161 \h  250 

Figure B5-1, Flow of Data Records for the Project	  PAGEREF _Toc43091162
\h  251 

 

VERSION CHANGE SUMMARY

The following changes are necessary to update the document to Version 9.

Page	Section	Description of Change





1	Cover Page	Changed “Version 8” to “Version 9.”  Revised
“Important Notes” to indicate this plan supersedes Version 8.

3	Approvals	Changed “Version 8” to “Version 9.”

14-16	VCS	Updated Version Change Summary.

17	A	Revised second paragraph of this section to read “This version of
the document supersedes 95-QAPjP Version 8.  Content changes from the
previous version are marked with a version bar.”

Entire	Document	Revised header on every page from “Version 8” to
“Version 9” and updated effective date.



The following changes are necessary to address offsite sample analysis.

Page	Section	Description of Change





111	B1-4	Added “for solid samples” to 1st paragraph.  Added
“and/or analyzed” to 3rd paragraph.

117	B1-4b	Added “collected and analyzed at RFETS” to 3rd sentence.

	B1-4b(1)	Inserted new paragraph, formally last two sentences of Section
B1-4b.

119	B1-5	Revised section to address shipment of samples offsite.

264, 265	D-2	Added reference to MAN-T91-STSM-001, Site Transportation
Safety Manual (STSM); and PRO-908-ASD-004, On-Site Transfer and Off-Site
Shipment of Samples.



The following changes are necessary as part of document maintenance.

Page	Section	Description of Change





18	A-3	Revised  6th and 8th paragraphs to describe current sample
analysis activities at RFETS.

22	A-5a	Replaced “of data approval” with “for sample release” in
2nd sub-bullet.

26	A-5b	Corrected “Initiating” to “Initiates” for 4th bullet.

32	A-5g(2)	Revised 1st bullet since position no longer matrixed. 
Deleted 6th bullet since this is conducted by TWCP Site PQAO.



VERSION CHANGE SUMMARY (continued)

Document maintenance changes (continued).

Page	Section	Description of Change





143	B2-2a	Replaced reference to 95-WP/SAP-001, Transuranic (TRU/TRM)
Waste Sampling Plan with RMRS-WIPP-98-100, Acceptable Knowledge TRU/TRM
Waste Stream Summaries.

181	B3-10a(1)	Added “or version” to 1st bullet.

196	B3-14	Revised 3rd paragraph to reference correct place in the
TWCP-TIP for site-specific titles.  Updated TWCP-TIP Section 7.6 title
to Continuing Training in 4th paragraph.

208	Table B3-10	Revised notes b and c to reference correct sections of
the TWCP-TIP.

226	B4-3	Revised 1st sentence to reference correct section of updated
TWCP-TIP.



The following changes are necessary as part of document maintenance and
consist of notes added to referenced documents indicating they are
inactive and superseded.

Page	Referenced Documents



	61, 63, 65, 84, 92, 94, 155, 164, 197, 233, 239, 263, 264	Added note to
L-4053, Headspace Gas V&V (Data Generator Level) indicating the
procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V, Headspace Gas V&V (Data Generator Level).

	Added note to L-4231, Headspace Gas Sampling and Analysis Using an
Automated Manifold indicating the procedure is inactive as of June 18,
2003, superseded by PRO-1676-HGAS-S&A, Headspace Gas Sampling and
Analysis Using an On-Line Integrated System.



The following changes are necessary as part of document maintenance and
consist of document number or title changes for referenced documents.

Page	Referenced Documents



	23, 64, 97-98, 232, 266	Corrected number for 1-PRO-077-WIPP-005 to
PRO-077-WIPP-005.

	Corrected title for PRO-1569-SAP-001, Polymerized Organic and Inorganic
Liquid Process – Sampling and Analysis Plan.

	Corrected title for PRO-1729-903-SOIL, TRU Soil Removal From
Pre-Selected Areas, 903 Pad.

	Corrected title for PRO-1730-903-001, TRU 903 Pad Soil Removal/Repack
and Characterization Plan.



The following changes are necessary as part of document maintenance and
consist of notes added to referenced documents indicating they are
inactive or will be deactivated.

Page	Referenced Documents



	60-65, 84, 98, 102-103, 105, 107-109, 115, 117, 161, 165-176, 227, 230,
232-234, 239, 245, 247, 262-267	PRO-1471-VE-771, Visual Examination for
Confirmation of RTR .

	PRO-1608-VECRTR-371, Visual Examination Confirmation, Building 371.

	L-4038, WIPP Data Review and Validation for Volatile Organic Compounds.

	L-4165, GC/MS Determination of Volatile Organic Compounds (Solids,
Liquids, and TCLP Extracts).

	L-4035, Metals Data Verification and Validation Data Generation Level.

	L-4039, WIPP Data Review and Validation for Semi-Volatile Organic
Compounds.

	L-4150, Total Metals Acid Digestion Procedure of Solid, Liquid, and
TCLP Extract Samples.

	L-4151, Waste Analysis by Atomic Absorption Spectroscopy.

	L-4152, Mercury Analysis in Waste (Cold-Vapor Technique).

	L-4153, Trace Metals by ICP Spectrometry (Solids, Liquids, and TCLP
Extracts).

	L-4214, Extraction of Total SVOCs for GC/MS Analysis for WIPP.

	L-4215, GC/MS Determination of Total SVOCs for WIPP.

	L-4217, Metals Analysis Data Compilation and Reporting.

	PRO-717-HDGAS-371, Headspace Gas Sampling, Building 371.

	PRO-1266-SS-002, Tank Sludge Removal from Pre-Selected Areas, Building
774.

	L-4028, Sample Administration for the Radiological Laboratories.

	PRO-1628-A2-001, Tank Sludge Removal from Pre-Selected Areas, Tank
T-207.

	4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-level Waste in Building 569.

	RS-012-005, Cone and Quartering Method – Solid Sampling and Analysis
Plan.

	L-4026, Records Handling, Storage, and Retrieval for the WIPP Project
File.

	L-4108, Toxicity Characteristic Leaching Procedure (TCLP) for Metals in
Waste.

	L-1000, Requirements for Laboratory Procedures.



A.	Introduction

The Rocky Flats Environmental Technology Site (RFETS) intends to dispose
of transuranic (TRU) waste at the Waste Isolation Pilot Plant (WIPP)
facility.  It has developed this TRU Waste Characterization Program
Quality Assurance Project Plan (TWCP QAPjP) to comply with the WIPP
Hazardous Waste Permit, Attachment B, Waste Analysis Plan (WIPP-WAP). 
In this document, the term TRU waste includes TRU and TRU-mixed waste. 
This document complies with quality requirements of the Department of
Energy, Carlsbad Field Office Quality Assurance Program Document (QAPD)
(DOE 2003b).  The structure of this document parallels the structure of
the WIPP-WAP.

This version of the document supersedes 95-QAPjP-0050, Version 8. 
Content changes from the previous version are marked with a version bar.

A-1	Scope	

This document describes how the requirements of the WIPP-WAP are met at
RFETS. This document identifies the quality of data necessary, and the
procedures developed by RFETS to attain and maintain quality in the
TWCP.

RFETS complies with the existing requirements in the WIPP-WAP.  Any
conflicts between this document and existing requirements will be
resolved by the TWCP Site Project Manager (TWCP Site PM).

A-2	Overview

RFETS is a United States (U.S.) government-owned, private contractor
operated facility that is part of the nationwide nuclear weapons
production complex.  Since its inception in 1952, the principal mission
of the Rocky Flats Plant was the production of nuclear weapons
components from plutonium, uranium, beryllium, and various alloys of
stainless steel.  Additional RFETS missions included plutonium recovery
and reprocessing, and waste management.  To support its weapons
component production mission, Rocky Flats Plant operation included
facilities for the storage, treatment and transport of waste, chemical
laboratories, research and development, and facilities for plutonium
recovery.  The production mission of the Rocky Flats Plant was
officially discontinued in 1992 with the end of the Cold War.  The new
mission focuses on environmental restoration, waste management,
decontamination and decommissioning, stabilization of nuclear material
and residues, and economic development.  As part of the transition, the
name for the Rocky Flats Plant was changed to the Rocky Flats
Environmental Technology Site.  RFETS is owned by the U. S. DOE, and is
operated under an integrating contract with Kaiser-Hill.  Throughout the
changing missions, RFETS has generated and will continue to generate TRU
and TRM waste.

A-3	Description of RFETS

RFETS is located in northern Jefferson County, Colorado, and is
approximately 16 miles northwest of Denver.   More than 270 buildings
and structures, of which about 75 are trailers, are located at the
plant.  Major manufacturing, processing, plutonium recovery, and waste
treatment facilities occupy about 1.6 million square feet of this space.
 The remaining floor space is occupied by laboratories, administrative
offices, warehouses, utilities, security, storage, and construction
contractor facilities.

At present, RFETS waste handling operations include storage,
transportation, treatment, and packaging of waste materials.  Waste
managed at RFETS includes nonhazardous, hazardous, radioactive, and
mixed radioactive.

The facilities used to support TWCP activities include: Buildings 371,
440, 559, 569, 664, 707, 771, 776/777, 991, and mobile characterization
services.

Prior to October 22, 2002 headspace gas samples were collected using
both SUMMA( or equivalent canisters and on-line integrated
sampling/analysis systems, operated by the RFETS Analytical
Laboratories.  Currently, all headspace gas sampling and analysis is
conducted at RFETS utilizing on-line integrated systems, operated by
Headspace Analytical Services.  Information relative to headspace
sampling with SUMMA( canisters is included for historical traceability
and consistency with the WIPP-WAP.

Sampling of headspace gases has been performed in processing facilities
located within Buildings 371, 440, 776, and 991.  The Building 440, Room
113 Perma-Con, and Room 123 C-Cell are used to obtain headspace gas
samples.  Buildings 371, 440, and 771 may be used for performing visual
confirmation of waste container contents.  The Building 776 Size
Reduction Vault (SRV) airlocks, (Room 146B or 146C); Advanced Size
Reduction Facility (ASRF) Transfer Airlock (TA); the Manual Disassembly
Airlock (MDA); and the Barrel Dump Glovebox were formerly used to obtain
headspace gas samples, obtain solid waste matrix samples, or for
performing visual confirmation of waste container contents.

Analysis of headspace gas samples and/or solid waste matrix samples was
performed in the Building 559, 707, and 777 analytical laboratories. 
Specific analytical techniques include Inductively Coupled Plasma (ICP)
Mass Spectrometry, Gas Chromatography/Mass Spectrometry (GC/MS), Gas
Mass Spectrometry, and Atomic Absorption (AA) Spectroscopy.  To allow
for decommissioning of RFETS Analytical Laboratories, solid waste matrix
samples collected after December 31, 2003 are shipped off-site for
analysis.  Currently, analysis of headspace gas samples is performed in
Building 440 by the Automated Manifold System using GC/MS and GC/Thermal
Conductivity Detector (TCD) techniques.

Real-Time Radiography (RTR) is performed on waste containers using the
RTR units located in Building 664, and the Mobile RTR system in the
Building 664 Yard.  Prior to building closure for decommissioning, RTR
was also conducted in Building 569.  Nondestructive Assay (NDA) is
performed using the NDA systems identified in 1-MAN-008-WM-001,
Transuranic (TRU) Waste Management Manual (TWMM).

In addition to the facilities identified above, some RFETS wastes are
solid sampled and analyzed at the Idaho National Engineering and
Environmental Laboratory (INEEL).  Solid samples collected at RFETS
after December 31, 2003 are shipped to INEEL for analysis.  The INEEL
TWCP provides sampling and analysis support for client TRU waste sites
as described in the Statement of Work (SOW) for the INEEL TRU Waste
Characterization Program (DOE 2003a).

A-4	Project Description

To ensure that TRU waste is characterized according to established
requirements, RFETS has established the TWCP, which consists of teams
that retrieve, sample, and analyze waste; validate and report data; and
provide project management, quality assurance, audit and assessment, and
records management support.

TWCP personnel characterize TRU waste on a waste stream basis.  A waste
stream is defined as waste material generated from a single process or
activity that is similar in material, physical form, and hazardous
constituents.  TWCP personnel characterize TRU waste by obtaining
chemical, radiological, and physical data as described in this document.

Once a waste stream or an initial portion of the waste stream 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 Carlsbad Field Office (CBFO).  Waste
characterization methods used for completing the WSPF include AK,
headspace gas sampling and analysis, and homogeneous waste sampling and
analysis, nondestructive assay (NDA) (addressed in the TWMM), RTR, and
visual examination (VE).  Data generated by these methods are assessed
on a waste stream basis.  For each waste stream characterized, the TWCP
Site PM 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 in order to verify
consistency with the WSPF.

TWCP personnel use the waste description nomenclature outlined in the
DOE Waste Treatability Group Guidance (DOE 1995a).  The nomenclature
includes three broad matrix categories of waste: homogeneous solids
(summary category S3000), soil/gravel (summary category S4000), and
debris waste (summary category S5000).  The waste matrix codes describe
the physical form of the waste, and are used to determine
characterization requirements.

A-4	Project Description   (continued)

Retrievably stored waste is defined as TRU waste generated after 1970
and before the 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 at RFETS.  Newly generated waste is defined as TRU waste
generated after NMED approves the final audit report for RFETS.  All of
this waste is containerized, stored indoors in various buildings located
throughout RFETS, and can be easily inspected.  All newly generated
waste will also be stored in this manner.

In recent years, RFETS has focused on the stabilization of nuclear
material and radioactive waste.  The Residues Projects (Salt Residue
Stabilization/Repack; Ash Residue Repack; Combustible Residue Repack;
and Dry Residue Repack) were created to manage the radioactive waste
that was left over from the recovery and purification of fissile
materials used in the fabrication of nuclear weapons.  Buildings within
the Protected Area are being shutdown as D&D at RFETS progresses, and
therefore the Residue Projects were consolidated into Building 371.  The
Residues Projects assist in the solid sampling of TRU waste, i.e. Grid
and Cone and Quartering of applicable waste streams.

Approximately 50 percent of the current inventory of RFETS TRU waste
contains hazardous waste that is regulated under the Resource
Conservation and Recovery Act (RCRA).  Waste that is regulated under
both the Atomic Energy Act and RCRA is commonly known as mixed waste. 
Throughout this document, the term TRU waste includes both TRU and
TRU-mixed waste.

Over the WIPP facility’s 35-year disposal phase, RFETS plans to
dispose of approximately 3,500 m3 of contact handled TRU waste.  Because
of historic activities, activities in recent years, and current
activities, the categories of TRU waste that exist at RFETS include:

Newly generated waste [Section B-3d and Section B-3d(1)]

Repackaged retrievably stored waste [Section B-3d and newly generated
waste requirements]

Retrievably stored waste  [Section B-3d and Section B-3d(2)]

Table B-1, Summary of Hazardous Waste Characterization Requirements for
Transuranic Waste, lists the parameters to be determined by the various
characterization activities, the techniques to be used, and the
regulatory compliance programs to be undertaken by data users.  All the
constituents to be determined by sampling and analysis of wastes are
also included in Table B-1.

A-5	RFETS Organization and Responsibilities

Material Stewardship, TRU Waste Project, provides program management of
the TWCP.  The TRU Waste Project Manager fulfills the functional role of
the TWCP Site PM.  The TWCP Site PM and the TWCP Site Project Quality
Assurance Officer (PQAO) report within the Material Stewardship
organization.  The principal organizations involved in supporting the
TWCP, their project level positions, and their primary responsibilities
are described in the TWMM, Section 3.1.1 - Organization and QA Program. 
Functional organizational charts are also presented in the TWMM,
Appendix 1.  The following subsections describe functional roles/groups
primarily involved in TWCP WIPP-WAP characterization activities.

A-5a	TWCP Site PM

The TWCP Site PM performs the following:

Provides for project management of the RFETS TWCP.  Defines project
activities, authorizes work, and manages the budget for the project, and
tracks progress.

Performs oversight and/or management of TWCP characterization
activities.

Interfaces with KH, DOE, WIPP and other regulatory agencies on
project-specific matters, and serves as the RFETS Point-of-Contact for
WIPP-related activities.

Manages CBFO and NMED audit preparations for TWCP characterization and
Residues processing.

Ensures through the TWCP Site PQAO that surveillances are scheduled and
performed.

Ensures development and maintenance of program documents, plans and
procedures necessary to implement the TWCP:

Ensures preparation, issuance, control and maintenance of, and approves
the TWMM and the TWCP QAPjP;

Ensures annual review of the TWCP QAPjP and concurs on necessary changes
or revisions;

Reviews and concurs on TWCP characterization plans and procedures [e.g.,
headspace gas, visual examination (VE), Real-Time Radiography (RTR)];

Ensures distribution of CBFO requirements document changes to affected
organizations so that RFETS implementing procedures can be modified as
necessary.

Ensures that projects that support TWCP activities utilize processes
that comply with TWCP requirements.

Concurs with appointment of the TWCP Site PQAO and the PDCO.

Designates the Project Training Officer.

Ensures that applicable personnel are trained and qualified to TWCP
requirements.

A-5a	TWCP Site PM  (continued)

Provides for waste selection and tracking.

Provides for data validation and verification:

Approves Batch Data Reports;

Provides notification to Headspace Analytical Services, the Analytical
Laboratory, and the INEEL TWCP, as applicable for sample release.

Provides for data reconciliation with DQOs:

Ensures that, as applicable, solid sampling and analysis, headspace gas
sampling and analysis, visual examination, and RTR are performed,
completed, and documented in accordance with TWCP requirements;

Provides direction to the TWCP Site PQAO, Project Data Control Officer
(PDCO), and project staff regarding analytical data validation and
reconciliation with QAOs as necessary.

Provides for the assignment of EPA Hazardous Waste Codes:

Ensures that applicable sampling is performed (e.g., fingerprint
analysis, headspace sampling, and RCRA solid sampling).

Implements Field Sample Quality Control procedures.

Ensures that feedback from waste characterization activities is used to
update Acceptable Knowledge (AK) documentation.

Approves WSPFs.

Provides technical guidance for treatment and/or disposition of wastes.

Reviews and provides for the transmission of QA/QC reports to the DOE
Field Office.

Provides for data transmission to CBFO:

Signs transmittal of the final Batch Data Reports;

Provides for submittal of the required data packages (through WEMS) to
the WIPP prior to each TRU waste shipment (contains complete package and
shipping information).

A-5a	TWCP Site PM  (continued)

Manages facility operational aspects of the TWCP involving headspace gas
sampling and VE for use in verifying RTR as follows:

Interfaces with the TWCP Site PQAO and Waste Operations on project
activities affecting cost, schedule, and quality-related matters;

Ensures that operator training is conducted according to requirements;

Ensures that visual waste characterization data are obtained for
appropriate waste containers used in the TWCP;

For VE activities used to verify radiography, ensures that activities
are audio/videotaped and that audio/videotape equipment is checked prior
to each day’s use, to including recording and observation of test
patterns;

Ensures that VE (to Confirm RTR) audio/videotapes are transmitted to the
PDCO within 30 days of completion;

Ensures that data are recorded and complete;

Ensures that waste-characterization data forms and reports are
transmitted to the PDCO as soon as possible after data generation; and

Ensures 100% validation of VE raw data.

A-5a(1)	Project Data Control Officer (PDCO)

The Project Data Control Officer (PDCO) performs the following:

Manages and controls the TWCP records in accordance with
PRO-767-WIPP-001, Waste Records Center Processing; and PRO-077-WIPP-005,
Management of Waste Information Prior to Transmittal to the Waste
Records Center.

Supports the TWCP Site PQAO in project quality surveillance, data
coordination, and data acquisition as defined in PRO-767-WIPP-001, Waste
Records Center Processing.

Upon completion of the data generation level data validation and
verification, receives the Batch Data Reports for inclusion in the
project records management system.

Upon request, transmits data generation level Batch Data Reports to the
TWCP Site PQAO for project level data validation and verification.

Upon completion of the project level data validation and verification,
receives the approved Batch Data Reports for inclusion in the project
records management system.

Provides training to WIPP records custodians.

A-5a(2)	Headspace Analytical Services

The Headspace Analytical Services organization conducts headspace gas
sampling and analysis utilizing on-line integrated sampling and analysis
systems in support of TRU waste characterization.

A-5a(2)(i)	Headspace Analytical Services Manager

NOTE:	Responsibilities for this function may be delegated to subordinate
managers.

Interfaces with the TWCP Site PM and the TWCP Site PQAO on TWCP
activities affecting cost, schedule, and quality-related matters.

Ensures that headspace personnel are trained and qualified.

Ensures participation in the PDPs for analytical testing.

When performing the functional role of Technical Supervisor, reviews,
approves, and releases the Analytical Batch Data Report.  Other
qualified personnel [i.e., qualified as specified in PLN-97-007, TWCP
Training Implementation Plan (TWCP TIP)] may perform the role of
Technical Supervisor.

Coordinates and schedules analytical work to support the TWCP.

Ensures that corrective and preventive actions have been completed.

Reviews and approves all Headspace Analytical Services SOPs and reports.

Assigns headspace staff.

Manages the implementation of the Headspace Analytical Services’ roles
and responsibilities.

Verifies that analytical requirements of the WIPP-WAP and QAPjP have
been met.

A-5b	TWCP Site PQAO

The TWCP Site PQAO performs the following:

Ensure that the TRU Waste Program QA program (defined in Section 3 of
the TWMM) provides RFETS compliance with the QAPD.

Schedules, performs, or directs, surveillance of TRU waste
characterization, generation, packaging, control, and acceptance
activities.

Tracks, reviews and approves the disposition of TWCP nonconformances.

Assists the TWCP Site PM in responding to regulator identified
deficiencies and non-conformances.

Performs, or designates individuals to perform, data validation and
verification activities on Batch Data Reports as defined through
procedures identified in the TWCP QAPjP.

Verifies data QA documentation through the data validation and
verification of Batch Data Reports.

Tracks, performs trend analysis, and reports on quality problem areas.

Identifies and reports quality-related problems to the TWCP Site PM,
initiates documentation to track the quality-related problem, reviews
corrective actions, and tracks corrective actions to closure.

Performs verification of corrective actions in accordance with
PRO-943-WIPP-007, TRU Waste Characterization Program Trending and
Analysis of Quality-Affecting Problems.

Provides QA/QC reports to the TWCP Site PM for review, transmittal to
CBFO, and distribution to the RFFO.

A-5b	TWCP Site PQAO  (continued)

Ensures conformance to QA requirements through:

Review and approval of procedures that implement the TWCP QA program;

Review and concurrence on the TWCP QAPjP, the GGTP QAPjP, and the TWMM;

Distribution, to affected organizations, of changes to CBFO requirement
documents so that site implementing procedures can be modified as
necessary.

Provides a list of WIPP-related RFETS documents to Site Document
Control.

Provides day-to-day guidance on quality assurance-related matters, as
necessary, to TWCP staff.

Initiates a stop work order in accordance with 1-V10-ADM-15.02, Stop
Work Action, if quality work is not assured.

Maintains liaison with the CBFO QA organization and sub-tier
organizations.

Interfaces with generators of TWCP data and quality-related records.

A-5c	Technical Operations

The Technical Operations organization is supported by Waste Systems and
the Waste Requirements Group.

A-5c(1)	Waste Systems

Maintains the content and accuracy of the Waste Stream and Residue
Identification and Characterization (WSRIC) Building Books when revision
requests are received from generator organizations.

Maintains the content and accuracy of the Backlog Waste Reassessment
Baseline Book (BWRBB) and coordinates reassessment of characterization
information for packaged waste.

Maintains the Waste and Environmental Management System (WEMS) computer
database.

A-5c(2)	Waste Requirements Group

Provides waste characterization, generation, and packaging assistance to
waste generators.

Prepares Waste Generating Instructions (WGIs) to communicate waste
characterization and packaging requirements to waste generators at the
floor level.

Reviews the Waste/Residue Traveler (W/RT) for conformance to the
Colorado Department of Public Health & Environment (CDPHE) RCRA Permit
and on-site procedural requirements before the waste packages are sent
to respective storage areas to ensure compliance with all applicable
requirements.

Prepares, issues, controls, and maintains waste packaging procedures and
waste segregation guidance documents.

Specifies labeling and marking of waste packages according to DOT and
TSDF requirements in accordance with the appropriate Labeling and
Marking Procedures for Radioactive Waste Material Packages.

Provides Independent Technical Review, Technical Supervisor, and Quality
Assurance Officer reviews of visual verification data generated by waste
generators.

A-5d	Waste Operations

Maintains storage area for off-site shipments.

Stores RCRA regulated wastes in compliance with applicable regulations.

Receives, inspects, logs, serializes, and tracks all spare parts
associated with the TRUPACT-II package (PRO-1418-WO-TRUOP, TRUPACT-II
Operations).

Prepares waste packages and TRUPACT-II packages for off-site shipment.

Performs loading operations of TRUPACT-II packages.

Labels and marks packages according to DOT and TSDF requirements.



A-5d(1)	Nondestructive Testing (NDT)

Responsible for performing helium leak test on the TRUPACT-II Type B
vessel.

Responsible for performing RTR of waste packages.

Responsible for the oversight of mobile RTR vendors.

Manages KH operated RTR processes of waste containers involving the TWCP
as follows:

Interfaces with the TWCP Site PM and the TWCP Site PQAO on TWCP
activities affecting cost, schedule, and quality-related matters;

Reviews and approves RTR data reports and forms;

Ensures that RTR data reports and forms are complete and receive an
independent technical review;

Coordinates and schedules NDT work to support the TWCP;

Reviews and approves the NDT SOPs and forms and reports;

Verifies that TWCP QAPjP requirements are met;

Reviews and concurs with the TWCP QAPjP;

Perform QC checks of NDT equipment to applicable requirements and at
specified frequencies;

Periodically reviews audio/videotape of accepted waste containers by
personnel other than the operator who dispositioned the waste container;

Ensures that the RTR audio/videotapes are transmitted to the PDCO and
that one audio/videotape is retained in the NDT files;

Assigns NDT personnel;

Ensures that RTR operators are trained and certified to existing
industry standards and comply with the training and qualification
requirements of the WIPP-WAP and the QAPD;

Ensures the preventive and routine maintenance is conducted in
accordance with the requirements of this document; and

Ensures that nonconformances are reported and corrective actions have
been completed.

A-5e	TRU Waste Certification Official (WCO)

The TRU Waste Certification Official (WCO) performs the following:

Reports to the Manager of Waste Certification and Oversight (WC&O) who
reports to the Manager, Environmental Compliance.

Maintains independence from waste generating organizations.

Reviews and concurs with process and quality controls.

Reviews and approves NDA Qualification Reports.

Serves as a point-of-contact for TRU waste NCRs.

Certifies that TRU waste is properly segregated and packaged, including
designation of wastes as RCRA/TSCA hazardous constituents or Land
Disposal Restricted materials, as applicable, based on a thorough review
of inspection, test, and surveillance information.

Certifies that TRU waste meets all applicable WIPP-WAC based on the
waste generator’s characterization, RTR, and other quality controls.

Certifies by signature that the TRU waste is properly classified,
packaged, marked, labeled, and loaded in the TRUPACT-II package, and
meets WIPP-WAC requirements.

Signs the TRU waste certification checklist attesting that the TRU waste
shipment meets WIPP-WAC requirements.

Assures waste certification records are maintained as required by
project procedures.

Reviews and concurs with TRU waste management procedures.

A-5f	Material Stewardship QA Manager

Designates and provides oversight of the TWCP Site PQAO

Assures development and maintenance of the TRU Waste Program QA program
in conjunction with the KH Quality Assurance program.

Schedules and conducts assessments of the TRU Waste Program.

Ensures that an independent assessment of the project is performed
annually (this assessment may be comprised of several smaller scope
assessments).

Ensures that Waste Inspectors are trained and qualified to perform waste
inspection.

Ensures that waste inspection procedures and work instructions are
developed and maintained.

Provides for technical guidance for RFETS Waste Inspectors.

Ensures that Waste Inspectors meet responsibilities identified in waste
inspection procedures.

A-5f(1)	Headspace Analytical Services Quality Assurance Officer (HASQAO)

Directs all of the Headspace Analytical Services’ WIPP-related QA
activities and is matrixed to the Headspace Analytical Services’
Manager in fulfilling this function.  

Interfaces directly with the TWCP Site PQAO on headspace specific QA
matters related to this project.

Ensures that all project headspace personnel have a clear understanding
of the special QC requirements for the Project.

Develops, reviews, and revises headspace-related portions of the TWCP
QAPjP.

Provides quality surveillance of headspace TWCP-related activities.

Tracks and reports headspace nonconformances for management reporting to
the TWCP Site PQAO.

Verifies the implementation of project QA requirements.

Identifies and reports headspace quality deficiencies to the appropriate
Project personnel and the TWCP Site PQAO.

Initiates, recommends, and tracks corrective actions to closure.

Reviews and verifies that all Headspace Analytical Services SOPs comply
with QAPjP and WIPP-WAP requirements.

Reviews and approves Batch Data Reports prior to release to the Waste
Records Center and ensures that Batch Data Reports are transmitted in a
timely manner.

Ensures that all headspace requirements of the WIPP-WAP and QAPjP have
been met.

A-5g	Remediation, Industrial D&D, and Site Services (RISS) 

The RISS organization is supported by the Metrology, Laboratory, and
Analytical Services groups.  The Laboratory group is responsible for the
following:

Provides analytical chemistry services in support of waste
characterization.

Performs the material testing.

Performs the destructive analysis of wastes and radioactive materials.

Appointing the Analytical Laboratories Manager.

A-5g(1)	Analytical Laboratories Manager

NOTE:	Responsibilities for this function may be delegated to subordinate
managers.

Interfaces with the TWCP Site PM and the TWCP Site PQAO on TWCP
activities affecting cost, schedule, and quality-related matters.

Ensures that analytical personnel are trained and qualified.

Ensures participation in the PDPs for analytical testing.

When performing the functional role of Technical Supervisor, reviews,
approves, and releases the Analytical Batch Data Report.  Other
qualified personnel [i.e., qualified as specified in PLN-97-007, TWCP
Training Implementation Plan (TWCP TIP)] may perform the role of
Technical Supervisor.

Coordinates and schedules analytical work to support the TWCP.

Ensures that corrective and preventive actions have been completed.

Reviews and approves all Analytical Laboratory SOPs and reports.

Assigns laboratory staff.

Manages the implementation of the Analytical Laboratories’ roles and
responsibilities.

Verifies that analytical requirements of the WIPP-WAP and QAPjP have
been met.

A-5g(2)	Analytical Laboratories Project Quality Assurance Officer
(LPQAO)

Directs all of the Analytical Laboratories’ WIPP-related QA
activities.  

Interfaces directly with the TWCP Site PQAO on analytical laboratory
specific QA matters related to this project.

Ensures that all project laboratory personnel have a clear understanding
of the special QC requirements for the Project.

Develops, reviews, and revises laboratory-related portions of the TWCP
QAPjP.

Provides quality surveillance of analytical laboratory TWCP-related
activities.

Verifies the implementation of project QA requirements.

Identifies and reports laboratory quality deficiencies to the
appropriate Project personnel and the TWCP Site PQAO.

Initiates, recommends, and tracks corrective actions to closure.

Reviews and verifies that all Analytical Laboratory SOPs comply with
QAPjP and WIPP-WAP requirements.

Reviews and approves Batch Data Reports prior to release to the Waste
Records Center and ensures that Batch Data Reports are transmitted in a
timely manner.

Ensures that all analytical laboratory requirements of the WIPP-WAP and
QAPjP have been met.

A-5h	Building Closure Projects

Manage the generation, packaging, and some characterization operations
for the higher radioactive activity, contact-handled wastes formerly
managed as recyclable residues and newly generated waste. Specific areas
of responsibility supporting the TWCP are listed below.

Management of waste generation and packing operations associated with
TRU waste.

Develop PCPs as applicable to identify specific waste stream Item
Description Codes (IDCs), their physical and chemical characteristics,
and the controls established to ensure consistent production to WIPP
requirements.

Ensuring independent Building Closure Projects Project Quality Assurance
activities are performed.

A-5h(1)	Waste Generators

Properly segregate regulated wastes from each other and from those not
regulated by using procedures and reference information sources that
include:

The WSRIC Building Books

Analytical data

Material Safety Data Sheets (MSDSs)

Documented recommendations from RFETS Waste Characterization SMEs

Knowledge of process materials

WGIs

Provides the physical control of packages before TID sealing using
locking fixtures or enclosures.

Maintain the accuracy of the WSRIC Building Books.

Ensure on-site transfers of waste packages meet the requirements of
RFETS procedures.

Attend required classroom and OJT.

Certify by signature on the W/RT that all waste generated is properly
identified, segregated, and characterized according to applicable
written procedures.

A-5i	INEEL TWCP Responsibilities

The INEEL TWCP conducts solids sampling and analysis of some RFETS waste
according to the Attachment to the SOW for the INEEL TWCP (DOE 2003a).

A-6	Hierarchy of Documents

The following items, found in the TWMM, outline the flowdown
requirements and hierarchy of TWCP programmatic documents:

Section 2.1, CBFO Requirements Documents

Figure 2-1, CBFO Requirements Flowdown Characterization

Figure 2-2, CBFO Requirements Flowdown Certification

Figure 2-3, CBFO Requirements Flowdown Quality Assurance

Correspondingly, Section B5-2, Document Review, Approval, and Control,
of this document, provides a description of the program documents used
for demonstrating compliance to CBFO requirements.  A summary of these
documents is found in the TWMM, Table 2-1, Summary of RFETS Program
Documents.

A-7	Indoctrination and Training

The management of each organization is responsible for ensuring that
personnel assigned to the TWCP from their organization meet the training
requirements stated in the WIPP-WAP.  This is in addition to meeting the
training requirements defined in MAN-131-QAPM, Quality Assurance Program
Manual (QAPM) and implemented in accordance with MAN-094-TPM, Training
Program Manual (TPM).  Implementation of the QAPM and TPM requirements
occurs through prime operating contractor training programs (program
manuals and implementing procedures or instructions).  PLN-97-007, TWCP
Training Implementation Plan (TWCP TIP), specifically addresses the
requirements of the WIPP-WAP and this document for education,
experience, training and qualification of TWCP participants.  The TWCP
TIP includes references to the prime contractor training program
documentation, which implement personnel qualification and training
programs in accordance with the WIPP-WAP, the QAPD, and 10 CFR 830.120.

A TWCP indoctrination class provides TWCP personnel with information on
scope, purpose and objectives of the program, and references information
on specific QAOs for their assigned tasks (for a listing of courses
refer to the TWCP TIP, Appendix 1, TWCP Project Training Matrix, and
Appendix 3, Residues Program Training Matrix).  The TWCP TIP requires
that all assigned personnel complete this indoctrination course.  A
supplemental WIPP-WAP Indoctrination is also required for all personnel
covering the scope, purpose, objectives, and QAOs in the WIPP-WAP.

The TWCP TIP (Section 7.1, Job Analyses and Training Needs Assessments)
requires completion of job analyses (JA) for each job position
responsible for TWCP tasks and activities.  This position JA documents
the assessment of the position description and the functions, tasks,
work processes and procedures involved in the job.  The position JA
yields requirements for the education and experience (E&E) of assigned
personnel and a training needs assessment (TNA) which contains the
training and qualification requirements for the position.  The JA and
TNA are periodically reviewed to identify changes in requirements and
additional necessary training.

A-7	Indoctrination and Training  (continued)

All E&E, training and qualification requirements are documented in the
TWCP TIP appendices by functional area and position.  Management
evaluates the resumes of assigned personnel and personnel who change
positions or are assigned to short-term or temporary work.  Management
documents that they meet the E&E requirements (refer to the TWCP TIP,
Section 7.2, Personnel Selection and Assignment).  Completion of the
training and qualification requirements by TWCP participants is reviewed
by management and the Project Training Officer (refer to the TWCP TIP,
Section 7.4, Administration of Training) to ensure that personnel
maintain proficiency.  

The education, experience and specialized training requirements for
headspace gas and laboratory system Operators and Technical Supervisors
as presented in the WIPP-WAP, Table B3-10, Minimum Training and
Qualification Requirements, are covered in the TWCP TIP, Appendix 1,
TWCP Project Training Matrix, which is applicable to Chemical Analysis
personnel.  Other WIPP-WAP requirements for training are discussed in
Sections B1-3b, B3-14, and B4-3a of this document.  Section B1-3b of
this document discusses the RFETS position title and training
requirements for RTR operators pursuant to the WIPP-WAP Table B3-10,
Minimum Training and Qualification Requirements.



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B.	WASTE ANALYSIS PLAN 

RFETS disposes of TRU waste (i.e., TRU and TRU-mixed 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
(WIPP-WAC; DOE/WIPP-02-3122).  In this document, the term TRU waste
includes TRU and TRU-mixed waste.

TRU waste is designated and separately packaged as either
contact-handled (CH) or remote-handled (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 not be shipped to the WIPP facility for disposal.

The hazardous components of the TRU waste to be shipped for disposal at
the WIPP facility from RFETS are designated in the WIPP Hazardous Waste
Permit, Attachment O (NMED 1999).

Retrievably stored waste is defined as TRU waste generated after 1970
and before NMED notifies the WIPP facility, by approval of the final
audit report, that the characterization requirements of the WIPP-WAP
have been implemented appropriately at RFETS.  Newly generated waste is
defined as TRU waste that is generated after NMED approves the final
audit report for RFETS.  Acceptable Knowledge (AK) information is
assembled for both 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(1) 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 Site uses the
characterization techniques described in the WIPP-WAP to assign
appropriate Waste Matrix Code Groups for WIPP disposal.

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.

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 (20.4.1.800 NMAC (incorporating 40 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.

B.	WASTE ANALYSIS PLAN  (continued) 

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
20.4.1.800 NMAC (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).  

Once the required waste characterization is complete, RFETS completes a
WSPF to document the results of their characterization activities (see
Section B-1d).  The WSPFs and the Characterization Information Summary
for the waste stream resulting from waste characterization activities
are transmitted to the WIPP facility, reviewed for completeness, and
screened for acceptance prior to loading any TRU waste into the Contact
Handled Packaging as described in  Section B-4.  Only TRU waste that has
been characterized in accordance with this document and that meets the
Treatment Storage Disposal Facility Waste Acceptance Criteria (TSDF-WAC)
of the WIPP Hazardous Waste Permit  is shipped to the WIPP facility for
disposal.

If WIPP requests detailed information on a waste stream, RFETS 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 WIPP.

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.  RFETS delineates waste streams using acceptable
knowledge.  Required acceptable knowledge is specified in Section B-3b
and Section B4 of this document.  If acceptable knowledge 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.

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 based on staging, transportation, or
handling issues.  Characterization activities are then undertaken on a
waste stream lot basis.  A WSPF need not be submitted for subsequent
waste stream 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.

RFETS ships only those TRU waste streams which have EPA Hazardous Waste
Codes already listed on the WIPP Hazardous Waste Permit, Attachment O
(NMED 1999).  If during the characterization process, new Hazardous
Waste Codes are identified, those wastes will not be shipped for
disposal to the WIPP facility until the code is added to the permit
(refer to the TWMM, Section 5.5.2, Hazardous Waste, and Section 5.5.2.1,
Methods of Compliance; 1-PRO-087-WEMS-WP-1201, WEMS Waste Package
Inventory, Tracking and Control; and 4-G83-WEM-WP-1209, WEMS Waste
Package Verification and Certification).

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.  Payload containers with U134
waste shall have no detectable liquid).  Refer to the TWMM, Section
5.4.1, Residual Liquids; and Section B4-3b(3) of this document.

Non-radionuclide pyrophoric materials (refer to the TWMM, Section 5.5.1,
Pyrophoric Materials; and Section B4-3b(3) of this document).

Hazardous wastes not occurring as co-contaminants with TRU waste
(non-mixed hazardous waste).  Refer to the TWMM, Section 5.5.2,
Hazardous Waste; and Section B4-3b(3) of this document.

Wastes incompatible with backfill, seal and panel closures materials,
container and packaging materials, shipping container materials, or
other wastes (refer to the TWMM, Section 5.5.3, Chemical Compatibility;
and Section B4-3b(3) of this document).

B-1c	Waste Prohibited at the WIPP Facility  (continued)

Wastes containing explosives or compressed gases (refer to the TWMM,
Section 5.5.4, Explosives, Corrosives, and Compressed Gases; and Section
B4-3b(3) of this document).

Wastes with polychlorinated biphenyls (PCBs) not authorized under an EPA
PCB waste disposal authorization.  (Refer to the TWMM, Section 5.5.6,
Polychlorinated Biphenyls; and Section B4-3b(3) of this document).

Wastes exhibiting the characteristic of ignitability, corrosivity, or
reactivity (EPA Hazardous Waste Numbers of D001, D002, or D003).  Refer
to the TWMM, Section 5.5.2; 1-PRO-087-WEMS-WP-1201, WEMS Waste Package
Inventory, Tracking, and Control; 4-G83-WEM-WP-1209, WEMS Waste Package
Verification and Certification; Section B1-b of this document; and
Section B4-3b(3) of this document.

RH TRU waste (waste with a surface dose rate of 200 millirem per hour or
greater).  Refer to the TWMM, Section 5.3.5, Radiation Dose Rate; and
Section B4-3b(3) of this document.

Any waste container that does not have VOC concentration values reported
for the headspace (refer to Section B-3a(1) of this document and to the
TWMM, Section 5.5.5, Headspace Gas Concentrations; and Section 5.6, Data
Package Contents).

Any waste container which has not undergone either radiographic
examination or VE (refer to Section B-3c and Section B1-3 of this
document).

Any waste container from a waste stream which has not been preceded by
an appropriate, certified WSPF (refer to Section B-1d of this document
and PRO-944-WIPP-008, Completion of Waste Stream Profile Form for Waste
to be Disposed of at WIPP).

RTR, visual examination to confirm RTR, and visual verification are all
techniques used to confirm acceptable knowledge that prohibited waste is
not present in waste containers to be shipped to WIPP.  This
confirmation is accomplished by examining the waste container contents
for the following:

Specific prohibited waste items (such as free liquid and compressed
gases) that are readily discernable upon examination, and

Conditions/items that would indicate the presence of prohibited waste
items that cannot be readily discerned by examination.  For example:

Compliance with the prohibition for waste exhibiting the characteristic
of ignitability, corrosivity, or reactivity is verified if the
examination does not detect free liquids or conditions which would
indicate that abnormal reactions are occurring (e.g., bulging
containers).

Compliance with the requirement that the packaged waste be compatible
with the packaging material, shipping container, backfill, etc. is
established by verification of compliance with the TRUCON Code. 

B-1c	Waste Prohibited at the WIPP Facility  (continued)

Final characterization of a waste is done in conjunction with acceptable
knowledge confirmation.    

Before shipping a container holding TRU waste to the WIPP facility,
RFETS examines the RTR or VE data records (refer to Section B-4 and
Section B1-3) 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
(to Confirm RTR) 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.  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 carbon composite particulate filters or
filters with equivalent VOC dispersion characteristics.  This venting
allows 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 (refer to the TWMM, Section 5.2.7, Filter
Vents).

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 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 WIPP (refer to the TWMM, Section 5.5.3, Chemical Compatibility; and
Section B4-3b(3) of this document).

The VOC concentrations in the headspace of waste containers have been
limited 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 RFETS, 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
RFETS, 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 M&O Contractor on a
case-by-case basis.  Approval for containers exceeding the averaged
limits will be done through the WIPP Waste Information System (WWIS)
exception process (refer to the TWMM, Section 5.5.5, Headspace Gas
Concentrations).

B-1d	Control of Waste Acceptance

Every waste stream shipped to WIPP is preceded by a WSPF (Figure B-1). 
The required WSPF information and the Characterization Information
Summary elements are found in Section B3-12b.

RFETS provides the WSPF and the Characterization Information Summary for
each waste stream to the WIPP facility for acceptance prior to shipping
the waste (refer to PRO-944-WIPP-008, Completion of Waste Stream Profile
Form for Waste to be Disposed of at WIPP).  When requested by CBFO,
RFETS will provide a Waste Stream Characterization Package as described
in Section B3-10b(4).  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.

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 RFETS:

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

Toxicity characteristic contaminants listed in 20.4.1.200 NMAC
(incorporating 40 CFR, §261.24), Table 1 (excluding pesticides), as
specified in the WIPP Hazardous Waste Permit, Attachment O (NMED 1999).

F-listed and P-listed solvents or waste (F001, F002, F003, F004, F005,
F006, F007, F009, P015) found in 20.4.1.200 NMAC (incorporating 40 CFR
§261.31).

Hazardous constituents included in 20.4.1.200 NMAC (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 acceptable knowledge.

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 RFETS include acceptable
knowledge, which incorporates confirmation by headspace gas sampling and
analysis; RTR; VE; and homogeneous waste sampling and analysis.  All
confirmation characterization activities are performed in accordance
with the WIPP-WAP.  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 or in batches (i.e., sampling
batch, analytical batch, or on-line batch).  Refer to Section E-2 for a
definition of these terms, and refer to Section B3 for additional
clarification regarding the expected contents of Batch Data Reports.

Coring, solid sampling, and analysis of some RFETS waste is conducted at
INEEL.  These confirmation activities are conducted in accordance with
the WIPP-WAP as described in the Attachment to the SOW for the INEEL
TWCP (DOE 2003a).

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 will
be compared to those assigned by acceptable knowledge and hazardous
waste codes will be assigned as warranted.  The comparison will consider
radiolysis when assessing the presence of listed waste, and whether
radiolysis would generate waste which exhibits the toxicity
characteristic.  TRU mixed waste containers or statistically selected
containers from waste streams that meet the conditions for reduced
headspace gas sampling listed in this section are sampled and analyzed
to determine the concentrations of VOCs (presented in Table B-3) in
headspace gases.  If composite samples are used, containers used in the
composite sample are from the same waste stream with no more than 20
containers included in a single composite sample.  Sampling protocols,
equipment, and QA/QC methods for headspace gas sampling are provided in
Section B1 of this document.  In accordance with EPA convention,
identification of hazardous constituents detected by gas
chromatography/mass spectrometry methods that are not on the list of
target analytes are reported.  These compounds are reported as
tentatively identified compounds (TICs) in the analytical batch data
report and are 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.  This site-specific
procedure which addresses adding TICs to the target analyte list is
PRO-944-WIPP-008, Completion of Waste Stream Profile Form for Waste to
be Disposed of at WIPP.  The headspace gas analysis Quality Assurance
Objectives (QAOs) are specified in Section B3 of this document.

B-3a(1)(i)	Reduced HSG Sampling Requirements for Homogeneous Solid or
Soil/Gravel Waste Streams with no VOC-related Hazardous Waste Codes

Headspace gas VOCs that do not exceed the PRQLs in Table B3-2 are not
significant and do not impact the acceptable knowledge confirmation,
assignment of additional hazardous waste codes, or worker/public health.
 Headspace gas samples that do not exceed the PRQLs are not significant
to the activities that use the results of headspace gas sampling defined
in the WIPP Hazardous Waste Permit.  Therefore, 100% headspace gas
sampling of homogeneous solid and soil/gravel wastes that have no
VOC-related hazardous waste codes assigned is unnecessary and does not
provide additional protection of human health and the environment.  Such
waste streams may qualify for reduced headspace sampling if they meet
certain criteria.

In order for a waste stream to qualify for reduced headspace gas
sampling, the waste stream or waste stream lot must consist of more than
10 containers and the following conditions must be met:

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.

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

B-3a(1)(ii)	Reduced HSG Sampling Requirements for Thermally Processed
Waste Streams

The potential sources of VOCs in the headspace of TRU waste containers
are:  the matrix, the packaging, and the byproducts of radiolysis.  If
the waste matrix contains no significant VOCs due to high-temperature
thermal processes, the contribution from each of these potential sources
can be quantified without the use of 100% headspace gas sampling, while
maintaining data quality sufficient for the purposes specified in the
WIPP Hazardous Waste Permit.  If the waste matrix contains no
significant VOCs because high-temperature thermal processes were used in
generating the waste or the waste was subject to high-temperature
thermal processes, then any significant concentrations of VOCs measured
in the headspace gas will likely not have originated from the waste
matrix.

Consequently, the only remaining sources for VOCs present in the
headspace gas are the packaging and the byproducts of radiolysis. 
Hazardous waste codes are not assigned based on headspace gas VOCs that
are the result of packaging or radiolysis.  It is not necessary to
sample 100% of the containers for headspace gas VOCs to establish a
representative concentration of VOCs present in the headspace gas due to
packaging and radiolysis.  Such waste streams may qualify for reduced
headspace sampling if they meet certain criteria.

In order for a waste stream to qualify for reduced headspace gas
sampling, the waste stream or waste stream lot must consist of more than
10 containers and the following conditions must be met:

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 resulted in the reduction of
matrix-related VOCs in the headspace to concentrations below the PRQLs
listed in Table B3-2.

The site must have documentation demonstrating that high-temperature
thermal processes were used.

If a waste stream meets these conditions for reduced headspace gas
sampling, RFETS may choose to randomly select containers for headspace
gas sampling and analysis using the statistical approach described 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
acceptable knowledge.  Sampling is accomplished through core or other
EPA approved sampling, which is described in Section B1 of this
document.  For those waste streams defined as Summary Category Groups
S3000 or S4000, debris that may also be present within these wastes need
not be 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 B2-2
of this document.

As appropriate, Totals or Toxicity Characteristic Leaching Procedure
(TCLP) analyses for VOCs, SVOCs, 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 20.4.1.200 NMAC (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 20.4.1.200 NMAC (incorporating 40 CFR §261,
Subpart C), 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 (DOE 1997a), and a discussion of the UCL90  is
included in Section B2 of this document.  If toxicity characteristic
(TC) wastes are identified, these will be compared to those determined
by acceptable knowledge and TC waste codes will be revised, as
warranted.  Refer to Section B4 of this document for additional
clarification regarding hazardous waste code assignment and homogeneous
solid and soil/gravel analytical results.

B-3a(3)	Laboratory Qualification

RFETS conducts analyses using laboratories and equipment that are
qualified through participation in the Performance Demonstration Program
(DOE 1999a and DOE 1999b).  Required QAOs are specified in Section B3 of
this document.

Analytical methods used by Headspace Analytical Services and the
Analytical Laboratories: 1) satisfy all of the appropriate QAOs, and
2) are implemented through standard operating procedures.  These
analytical QAOs are discussed in detail in Section B3 of this document.

As described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a), the INEEL TWCP laboratories are qualified through participation
in the Performance Demonstration Program and analytical methods used
satifisfy all appropriate QAOs through implementation of standard
operationg procedures.

B-3b	Acceptable Knowledge

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 [New Mexico Hazardous Waste Management Regulations in
Title20 New Mexico Administrative Code, Chapter 4, Part 1, Section 200
(20.4.1.200 NMAC), incorporating 40 CFR §261.24].

To assess whether TRU wastes are listed (20.4.1.200 NMAC, incorporating
40 CFR §261.31).

Acceptable knowledge is discussed in detail in Section B4 of this
document, which outlines the minimum set of requirements that are met by
RFETS in order to use acceptable knowledge.

B-3c	Radiography and Visual Examination

Real-Time Radiography (RTR) is a nondestructive qualitative and
quantitative technique that involves X-ray scanning of waste containers
to identify and verify waste container contents.  Visual examination
(VE) constitutes opening a container and physically examining its
contents.  At RFETS there are three specific reasons for utilizing VE as
follows:

VE performed to confirm RTR: VE that is performed as a confirmation of
RTR data requires audio/videotaping.  This VE is performed on a
statistically selected subpopulation of waste containers that have
already undergone RTR (refer to Section B2-1 for a discussion of the
statistical selection of these waste containers).

VE performed in lieu of RTR: VE that is performed in lieu of RTR 
requires audio/videotaping.  (VE in lieu of RTR is not currently
conducted at RFETS.)

VE performed as a visual verification of acceptable knowledge.  This VE
is referred to as the VE Technique in the WIPP-WAP, and at RFETS this is
commonly known as Visual Verification (VV): VE that is performed for
newly generated waste or when repackaging retrievably stored waste does
not require audio/videotaping.

For Repackaged Retrievably Stored Waste from Residues Projects
(characterized by VE), the VV activity requires two operators.  The
first operator confirms 1) that the physical form of the waste agrees
with the assigned IDC, the Waste Stream description, the Waste Matrix
Code (includes Summary Category Group), the Waste Material Parameter,
and the TRUCON Code, and 2) confirms that the waste does not contain
prohibited items.  The second operator, who is equally trained to the
requirements, provides real-time verification of the waste by reviewing
the contents of the waste container as the container is being packaged. 
The results are recorded on the Visual Verification and Packaging Data
Form, and a Visual Verification Batch Report is prepared as detailed in
Section B3-10 and Table B3-11 (for procedures refer to Table B-1,
Physical Waste Form – Repackaging of Retrievably Stored Waste).

B-3c	Radiography and Visual Examination  (continued)

For Newly Generated Waste (characterized by VE), such as D&D waste, and
Repackaged Retrievably Stored Waste the VV activity requires a waste
originator and a waste validator.  The waste originator confirms 1) that
the physical form of the waste agrees with the assigned IDC, the Waste
Stream description, the Waste Matrix Code (includes Summary Category
Group), the Waste Material Parameter, and the TRUCON Code, and 2)
confirms that the waste does not contain prohibited items. The waste
validator, who is equally trained to the requirements, provides
real-time verification of the waste by reviewing the contents of the
waste container as the container is being packaged.  The waste container
contents, the date of the visual verification, the signature of the
Waste Originator, and the signature of the Waste Validator are
documented on the TRU/TRM Waste Visual Verification and Packaging Log
Sheet (refer to PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification
(VV) and Data Review).  A Visual Verification Batch Report is prepared
as detailed in Section B3-10 and Table B3-11 according to
PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Review.

RTR 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.

RTR 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 RTR and/or VE indicate that the waste does not match the
waste stream description arrived at by acceptable knowledge
characterization, a waste nonconformance report (WNCR) 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 WIPP WSPF when necessary), the correct hazardous
waste codes are assigned, and the resolution is documented.  Refer to
Section B4 of the QAPjP for a discussion of acceptable knowledge and its
confirmation process.

RFETS may conduct VE of waste containers in lieu of RTR.  If TWCP
chooses to use VE in lieu of RTR, the detection, through shaking, of any
liquid waste in non-transparent 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 SWB). 
The payload container would then be rejected and/or repackaged to
exclude the container if it does not meet the requirements of Section
B-1c of this document.

When RTR is used, or VE 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.  RTR is normally 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.  However, where RTR is ineffective, VE is performed.

RTR results are confirmed through the use of VE.  In this case, VE is
performed on a statistically selected subpopulation of TRU waste
containers in each TRU waste summary category group as specified in
Section B2-1 of this document.  Radiographic examination protocols and
QA/QC methods are provided in Section B1 of this document.

B-3d	Characterization Techniques and Frequency for Newly Generated and
Retrievably Stored Waste

RFETS uses acceptable knowledge 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 acceptable knowledge used may differ. 
Section B-3b discusses the use of acceptable knowledge, sampling, and
analysis in more detail.  Acceptable knowledge is discussed more
completely in Section B4.  Every waste stream will be assigned hazardous
waste codes based upon acceptable knowledge, 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).

RTR and/or VE are used to verify the physical form of retrievably stored
TRU waste.  For newly generated waste and for repackaged retrievably
stored waste, the physical form of the waste and absence of prohibited
items are either verified during packaging (using Visual Verification,
refer to Section B-3c) or are verified after packaging using radiography
(or VE in lieu of radiography).  RFETS may use either VV or radiography,
separately or together, as long as 100 percent of the containers undergo
confirmation of AK.  RTR and/or VE are also used in conjunction with
acceptable knowledge to characterize heterogeneous debris wastes.  RTR
and/or VE, and the associated information compiled from acceptable
knowledge (e.g., age of the waste, generating process) are used to
determine the RCRA-regulated constituents present in the waste.  VE, VV,
and/or radiography are performed prior to any treatment designed to
supercompact waste prior to shipment.

All waste containers (retrievably stored and newly generated) or
randomly selected containers from waste streams that meet the conditions
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 B2-2).  Sampling and analysis methods used for waste
characterization are discussed in Section B-3a.

B-3d	Characterization Techniques and Frequency for Newly Generated and
Retrievably Stored Waste (continued)

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
20.4.1.200 NMAC (incorporating 40 CFR §261) Appendix VIII, are compared
with acceptable knowledge data to determine if the TIC is in a listed
hazardous waste in the waste stream (refer to PRO-944-WIPP-008,
Completion of Waste Stream Profile Form for Waste to be Disposed of at
WIPP, and 4-H19-WSRIC-001, WSRIC Characterization and Reverification). 
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
non-toxic F003 constituents, RFETS may take concentration into account
when assessing whether to add a hazardous waste code.  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 acceptable knowledge
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, RFETS will add these TICs to the list of
hazardous constituents for the waste stream and assign additional EPA
listed hazardous waste codes if appropriate.  RFETS will notify the
INEEL TWCP and CBFO for the addition of TICs to the target list for
RFETS waste sampled and analyzed at INEEL.  For toxicity characteristic
compounds and non-toxic F003 constituents, RFETS may consider waste
concentration when determining whether to change a hazardous waste code.

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.  

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
retrievably stored waste if RFETS demonstrates 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 retains the
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 acceptable knowledge 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 delineated
into waste streams using acceptable knowledge.  Visual verification (VV)
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 (refer to Section B-3c, bullet number 3, for detailed
information on VV) or by performing radiography as specified in Section
B1-3 for retrievalby stored waste.  RFETS may use either VV or
radiography, separately or together, as long as100 percent of the
containers undergo confirmation of AK.

This VV activity 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,
corrective actions will be taken as specified in Section B3 of this
document.  A second operator, who is equally trained to the requirements
stipulated in Section B1of this document, provides 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. 
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 Section B1-1, is documented
as part of the characterization information collected during packaging
of newly generated waste or repackaging of retrievably stored waste. 
The rigid liner vent hole diameter for newly generated waste has been
established as 0.75-inch based on RFETS procurement specifications (see
SPEC-11170-0485 and ELD-057-01).  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 VV does not apply.

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 concentrations prior to shipment.
 If RFETS believes that the HSG sampling and analysis frequency can be
reduced in the future based on trends in analytical results, they may
provide technical arguments for such reduction to WIPP and request that
WIPP consider the preparation of a permit modification.  The headspace
gas sampling method is provided in Section B1.  Headspace gas data is
used to confirm acceptable knowledge waste characterization, as
specified in Section B4.

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, and metals, as
applicable.  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.

B-3d(1)(a)	Sampling of Newly Generated Homogeneous Solids (continued)

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 of this document.

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.

RFETS 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.

To date, no waste streams have been identified for which control
charting is appropriate.  When and if a waste stream is identified for
which control charting is appropriate, 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 waste
constituents identified in the waste stream or that would add relevant
prohibited materials.  If process changes are discovered, RFETS will not
ship any additional waste from the waste stream until a follow-up sample
is collected and analyzed to assess whether the waste has the same
characteristics identified on the WSPF.  If RFETS changes a process but
determines that increased sampling is not required because the change
will not affect waste generated by that process, RFETS notifies the WIPP
facility in the form of a memorandum to the CBFO Waste Characterization
Manager.  The WIPP facility will concur with the decision to not
increase the sampling frequency before any additional waste from that
process is shipped.

B-3d(1)(b)	Sampling of Newly Generated Soils/Gravels 

The toxicity characteristics of newly generated 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 20.4.1.200 NMAC (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.

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.  RFETS 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 drums will be used.  Refer to Section B2 of
this document for additional information.

B-3d(2)	Retrievably Stored Waste

All retrievably stored waste containers are first delineated into waste
streams using acceptable knowledge.  All retrievably stored waste
containers are examined using RTR 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 acceptable knowledge, is 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 RFETS demonstrates that
control charting cannot be applied effectively to the repackaging or
treatment process.  This determination is documented on the
Characterization Information Summary for the waste stream and is
examined by WIPP during audits.  In this case, the minimum number of
solids samples required for any S3000 waste stream or waste stream lot
is the number of samples determined in accordance with Section B2-2a. 
Radiographic results are compared to acceptable knowledge 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. 
RFETS may elect to substitute VE for radiographic analysis.

To confirm the results of RTR, a statistically selected number of the
TRU waste container population undergoes VE by opening containers to
inspect waste contents to verify RTR results.  Section B2-1 contains the
approach used to statistically select the number of containers 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) will 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 acceptable
knowledge waste characterization, as specified in Section B4.

B-3d(2)	Retrievably Stored Waste (continued)

A statistically selected portion of retrievably stored homogeneous
solids and soil/gravel wastes are sampled and analyzed for total 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 4.1.200 NMAC
(incorporating 40 CFR §261, Subpart C), TCLP may be used instead of
total analyses.  Appendix C3 of the WIPP RCRA Part B Permit Application
(DOE 1997a) discusses comparability of totals analytical results to
those of the TCLP method.

Representativeness is ensured by using a truly random process to select
containers for VE and sampling (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).

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 WAP
requirements.  Verification steps are taken at three levels: 1) the
RFETS data generation level, or INEEL TWCP data generation level, 2) the
RFETS project level, and 3) the WIPP facility level.  The validation and
verification process and requirements at each level are described in
Section B3-10.

B-4a	Data Generation and Project Level Verification Requirements

B-4a(1)	Data Quality Objectives

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 20.4.1.500 NMAC (incorporating 40 CFR,
§264.601(c)), and to confirm hazardous waste identification by
acceptable knowledge.

Homogeneous Waste Sampling and Analysis

To compare UCL90 values for the mean measured contaminant concentrations
in a waste stream with specified toxicity characteristic levels in
20.4.1.200 NMAC (incorporating 40 CFR §261), to determine if the waste
is hazardous, and to confirm hazardous waste identification by
acceptable knowledge.

To report the average concentration of hazardous constituents in a waste
stream, as specified in 20.4.1.200 NMAC (incorporating 40 CFR §261)
Appendix VIII, with a 90 percent confidence interval, with all averages
greater than 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 acceptable knowledge.

RTR

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 acceptable knowledge.

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 RTR, and to confirm the waste stream
delineation by acceptable knowledge.

Reconciliation of these DQOs by the TWCP Site PM 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.

B-4a(2)	Quality Assurance Objectives

RFETS demonstrates compliance with each QAO associated with the various
characterization methods as presented in Section B3-2 through B3-9.  The
TWCP Site PM performs a reconciliation at the project

level of the data sets submitted by the various RFETS and INEEL
organizations with the DQOs established in the WIPP-WAP.  The TWCP Site
PM 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 a 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

RFETS 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 document, or
procedures referenced in this document, document this program and
include COC forms to control the sample from the point of origin to the
final analysis result reporting.  Details of this 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.  

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

RFETS utilizes Batch Data Reports, in a format approved by WIPP, for
reporting waste characterization data.  This format is included in this
TWCP QAPjP, in controlled electronic databases, or in site-specific
procedures (refer to Table B-1) and includes the elements required by
the WIPP-WAP for Batch Data Reports (refer to Section B3).  The Batch
Data Report formats utilized by RFETS have been approved by WIPP by
virtue of the numerous audits that have been conducted at RFETS.  

Headspace Analytical Services and the Analytical Laboratory's QA/QC
program include the following:

Facility organization

A list of equipment/instrumentation

Operating procedures

Headspace and laboratory QA/QC procedures

Quality assurance review

Headspace and laboratory records management

For select RFETS waste solid sampling and analysis conducted at INEEL,
Batch Data Reports are prepared by the INEEL TWCP.  The INEEL TWCP Batch
Data Report format and QA/QC program are described in the Attachment to
the SOW for the INEEL TWCP (DOE 2003a).

B-4a(5)	Data Verification

Batch Data Reports document the testing, sampling, and analytical
results from the required characterization activities and document
required QA/QC activities.  Data validation and verification at both the
data generation level and the project level are performed as required by
the WIPP-WAP before the required data are transmitted to the WIPP
facility.  Section B3 discusses the data validation process in more
detail.

B-4a(6)	Data Transmittal

Batch Data Reports for each container include the information specified
in 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.  INEEL transmission of Batch Data Reports to
the RFETS TWCP is conducted by hard copy.

As part of the waste characterization data submittal, RFETS enters data
into WEMS (refer to 4-G83-WEM-WP-1209, WEMS Waste Package Verification
and Certification), and electronically transmits the data on a container
basis to WWIS using the WEMS off-site shipping module (refer to
4-K47-WEM-WP1210, WEMS Offsite Shipping Module).  The data is
transmitted to WWIS in the exact format required by the database.

Once a waste stream is fully characterized, the TWCP Site PM also
submits to the WIPP facility a WSPF (Figure B-1) accompanied by the
Characterization Information Summary for that waste stream which
includes reconciliation with DQOs (refer to Section B3-12b).  The WSPF,
the Characterization Information Summary, and information from the WWIS
is used as the basis for acceptance of waste characterization
information on TRU wastes to be disposed of at the WIPP. 

B-4a(7)	Records Management

Records related to waste characterization sampling and analysis are
maintained in the testing, sampling, or analytical facility files or at
the Waste Records Center.  Contract laboratories forward testing,
sampling, and analytical records along with Batch Data Reports, to the
Waste Records Center.  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 Section
B5-3 of this document for a detailed description of site-specific
records management and a listing of the site-specific records management
procedures.

A Records Inventory and Disposition Schedule (RIDS) has been prepared,
approved, and implemented by RFETS.  All records relevant to an
enforcement action under the WIPP Permit, regardless of disposition,
will be maintained at RFETS until NMED determines that the records are
no longer needed for enforcement action.  The records will then be
dispositioned as specified in the approved RIDS.  All waste
characterization data and related QA/QC records in the Waste Record
Center 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 RFETS
TWCP 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
Non-Permanent Records are maintained for ten years from the date of
(record) generation and then dispositioned according to their approved
RIDS.  If RFETS 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.

Classified information will not be transferred to WIPP.  All RFETS
documentation released to the public domain (i.e., WIPP), is reviewed
for classification and the documentation marked with the classification
status according to1-MAN-026, Rocky Flats Environmental Technology Site
Security Manual.  Notations are provided to WIPP for those instances
where characterization information is not transmitted due to its
classification status.  The RFETS RIDS will identify appropriate
disposition of classified information.  To ensure external auditors with
appropriate classification clearances have the opportunity to review
characterization data for classified TRU waste, such as classified RTR
tapes, all classified characterization data will be maintained at RFETS
through calendar year 2003.  Following this time period, these records
may be transferred to the Federal Records Center, e.g., Neosho,
Missouri.  Nothing in the WIPP-WAP 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 and
need-to-know to view such information.

B-4b	WIPP Facility Level: Waste Screening and Verification of TRU Waste

With the exception of preparing a QAPjP, receiving audits, submitting a
WSPF, the use of the WWIS,  LDR documentation, and resolving shipping
manifest discrepancies, the requirements contained in Attachment B-4b
(i.e., B-4b through B-4b(2)(viii)) of the WIPP-WAP are specific to
operations at the WIPP facility. The site requirements for WIPP level
waste screening and verification of TRU waste are included in the
following subsections.

B-4b(1)	Phase I Waste Stream Screening and Verification

RFETS has prepared this QAPjP which includes applicable WAP
requirements, and submitted it to the CBFO for review and approval. 
RFETS will implement the specific parameters of this QAPjP once it is
approved.  The initial RFETS RCRA audit was performed after this
implementation has taken place, but prior to shipment of TRU mixed waste
to WIPP.  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 RFETS and the initial RFETS audit has been successfully completed,
the TWCP Site PM will verify that waste stream characterization meets
the applicable WIPP-WAP requirements as part of the project level
verification (Section B3-10b).  If the waste characterization does not
meet the applicable requirements of the WIPP-WAP, the mixed waste stream
cannot be managed, stored, or disposed at WIPP until those requirements
are met.  The TWCP Site PM then completes a WSPF and submits it to the
WIPP facility, along with the accompanying Characterization Information
Summary for that waste stream (refer to Section B3-12b).  All data
necessary to check to the accuracy of the WSPF will be transmitted to
the WIPP facility for verification.  If the WIPP facility determines
(through data comparison) that the characterization information is
adequate, the WSPF will be approved.  If the data comparison indicates
that analyzed containers have hazardous wastes not present on the WSPF,
or a different Waste Matrix Code applies, the WSPF is determined to be
in error and is resubmitted.

For subsequent shipments, RFETS transmits the data on a container basis
via the WWIS prior to shipment of the container.  This data submittal
can occur at any time as the data are being collected, but is complete
for each container prior to shipment of that container.

B-4b(1)(i)	WWIS Description

RFETS will supply the required data to the WWIS.  The WWIS conducts
internal limit checks as the data are entered.  The WWIS automatically
notifies RFETS if any of the supplied data fails to meet the
requirements of the edit and limit checks via an appropriate error
message.  RFETS then corrects the discrepancy with the waste or the
waste data and re-transmits the corrected data prior to acceptance of
the data by the WWIS.  Table B-8 gives a partial listing of the data
fields contained in the WWIS that are required as part of the WIPP
Permit, and the WIPP Waste Information System User’s Manual for Use by
Shippers/Generators (DOE 2001) gives a full explanation of the WWIS data
fields and format requirements.  RFETS transmitted data is accessible to
RFETS, and only until the data have been formally accepted by the WIPP
facility.  After the data have been accepted, the data will be protected
from indiscriminant change and can only be changed by an authorized Data
Administrator.

B-4b(1)(ii)	Examination of the WSPF and Container Data Checks

If the WSPF is inaccurate, the WIPP facility will make efforts to
resolve discrepancies by contacting RFETS.  If discrepancies in the
waste stream are detected at RFETS, RFETS will implement a
non-conformance program to identify, document, and reported
discrepancies as described in Section B3.

The Characterization Information Summary indicates if the waste has been
checked for the characteristics of ignitability, corrosivity, and
reactivity.

B-4b(2)	Phase II Waste Shipment Screening and Verification

B-4b(2)(i)	Examination of the EPA Uniform Hazardous Waste Manifest and
Associated Waste Tracking Information

A manifest discrepancy is a difference between the quantity or type of
hazardous waste designated on the manifest and the quantity and type of
hazardous waste the WIPP facility actually receives.  The RFETS
technical contact (as listed on the manifest) is contacted to resolve
discrepancies.  Errors on the manifest can be corrected by the WIPP
facility with a verbal (followed by a written) concurrence by the RFETS
technical contact.  If RFETS manifest discrepancies are not resolved
within thirty (30) days of waste receipt at WIPP, the shipment will be
returned to RFETS.

B-4b(2)(ii)	Examination of the Land Disposal Restriction (LDR) Notice

TRU waste is exempt from the Land Disposal Restrictions (LDRs) by the
Land Withdrawal Act Amendment (Public Law 104-201).  This amendment
states that WIPP “Waste is exempted from treatment standards
promulgated pursuant to section 3004(m) of the Solid Waste Disposal Act
(42 U.S.  C.  6924(m)) and shall not be subjected to the Land Disposal
prohibitions in section 3004(d), (e), (f), and (g) of the Solid Waste
Disposal Act.”  Therefore, with the initial waste shipment of a TRU
mixed waste stream, RFETS provides to the WIPP facility a one-time
written notice. The notice includes the information listed below:

	Land Disposal Restriction Notice Information:

EPA Hazardous Waste Code(s) and Manifest Numbers of first shipment of a
mixed waste stream

Statement:  this waste is not prohibited from land disposal

Date the waste was subject to prohibition

RFETS prepares this notice in accordance with the applicable
requirements of 20.4.1.800 NMAC (incorporating 40 CFR §268.7(a)(4)).



Physical Waste Form

Summary

Category   Names

S3000	Homogeneous Solid

S4000	Soil/Gravel

S5000	Debris Wastes	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

4-I19-NDT-00569 Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569n

 

4-W30-NDT-00664 Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 664

PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste

4-H80-776-ASRF-007, Visual Examination for Confirmation of RTRk

PRO-1358-440-VERP, Glovebox and C-Cell Waste Operations

PRO-1471-VE-771, Visual Examination for Confirmation of RTRr

PRO-1608-VECRTR-371, RTR Visual Examination Confirmation, Building 371s

	RTR/Visual Examination

Retrievably Stored Waste

4-I19-NDT-00569 Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569n

4-W30-NDT-00664 Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 664

PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste

4-H80-776-ASRF-007, Visual Examination for Confirmation of RTRk

PRO-1358-440-VERP, Glovebox and C-Cell Waste Operations

PRO-1471-VE-771, Visual Examination for Confirmation of RTRr

PRO-1608-VECRTR-371, RTR Visual Examination Confirmation, Building 371s

	Newly Generated Waste

VV of Acceptable Knowledge	Newly Generated Waste

PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Review	Newly Generated Waste

PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Review

	Repackaging of Retrievably Stored Waste

VV of Acceptable Knowledge	Repackaging of Retrievably Stored Waste

PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Reviewj

Salt

4-W84-RS-0114, Salt Residue Stabilization/Repack, Bldg. 707g

 

PRO-544-SALT REPACK-371, Residue Repack, Building 371o

Ash

PRO-X56-RS-0123, Ash Residue Repack, Bldg. 707h 

Or

PRO-544-SALT REPACK-371, Residue Repack, Building 371o

Combustible

PRO-544-SALT REPACK-371, Residue Repack, Building 371o

PRO-823-REPACK-371, Combustible Residue Repackagingo

Dry

PRO-X32-RS-0128, Dry Residue Repackaging, Bldg. 707i

Or

PRO-544-SALT REPACK-371, Residue Repack, Building 371o	Repackaging of
Retrievably Stored Waste

PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Reviewj

Salt

PRO-264-RS-0141, Data Review and Verification of Residue Repack Batch
Reports

Ash

PRO-404-RS-0145, Data Review and Verification Of Ash Residue Repack
Batch Reportsm

Or

PRO-264-RS-0141, Data Review and Verification of Residue Repack Batch
Reports

Combustible

PRO-264-RS-0141, Data Review and Verification of Residue Repack Batch
Reports

Dry

PRO-X32-RS-0128, Dry Residue Repackaging, Bldg. 707i

Or

PRO-264-RS-0141, Data Review and Verification of Residue Repack Batch
Reports





Headspace Gases

Gas Volatile Organic Compounds

Benzene	Alcohols and Ketones

Bromoform	Acetone

Carbon tetrachloride	Butanol

Chlorobenzene	Methanol

Chloroform

Cyclohexane f	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

Formaldehyde b

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 f

1,3,5-Trimethylbenzene f

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

Fourier Transform Infrared Spectroscopy (FTIRS), SW-846	Analysis 

(refer to Section B1-1 and Section B3-5)

L-4111, GC/MS Determination of Volatile Organics For Waste
Characterizationl

L-4148, Preparation of Samples and Calibration Standards for
Determination of Gases in Sample Canistersl

L-4231, Headspace Gas Sampling and Analysis Using an Automated Manifoldw

PRO-1676-HGAS-S&A, Headspace Gas Sampling and Anaysis Using an On-Line
Integrated System

	Analysis

L-5017, HVOC Data Review and Validation (Data Generator Level)l

L-4053, Headspace Gas V & V (Data Generator Level)v

Total Volatile Organic Compounds

Acetone 

Benzene

Bromoform

Butanol

Carbon disulfide

Carbon tetrachloride

Chlorobenzene

Chloroform

1,4-Dichlorobenzene d

1,2-Dichlorobenzene d

1,2-Dichloroethane

1,1-Dichloroethylene

Ethyl benzene

Ethyl ether

Formaldehyde b

Hydrazine c

(trans)-1,2-Dichloro-

ethylene	

Isobutanol

Methanol

Methyl ethyl ketone

Methylene chloride

Pyridined

1,1,2,2-Tetrachloroethane

Tetrachloroethylene

Toluene

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

Attachment to the SOW for the INEEL TWCP (DOE 2003a)

Acceptable Knowledge for Summary Category S5000 (Debris Wastes)	Analysis

(refer to Section B3-6)

L-4165, GC/MS Determination of Volatile Organic Compounds (Solids,
Liquids, and TCLP Extracts)o

Attachment to the SOW for the INEEL TWCP (DOE 2003a)	Analysis

L-4038, WIPP Data Review and Validation for Volatile Organic Compoundso

Attachment to the SOW for the INEEL TWCP (DOE 2003a)





Total Semivolatile Organic Compounds

Cresols

1,4-Dichlorobenzene e

1,2-Dichlorobenzene e

2,4-Dinitrophenol

2,4-Dinitrotoluene

Hexachlorobenzene

Hexachloroethane

Nitrobenzene

Pentachlorophenol

Pyridine e	Total Semivolatile Organic Compound Analysis

TCLP, SW-846 1311

GC/MS, SW-846 8250 or 8270 

Attachment to the SOW for the INEEL TWCP (DOE 2003a)

Acceptable Knowledge for Summary Category S5000 (Debris Wastes)

	Analysis

(refer to Section B3-7)

L-4214. Extraction of Total SVOCs for GC/MS Analysis for WIPPo

L-4215, GC/MS Determination of Total SVOCs for WIPPo

Attachment to the SOW for the INEEL TWCP (DOE 2003a)	Analysis

L-4039, WIPP Data Review and Validation for Semi-Volatile Organic
Compounds in Solid Sampleso

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 

Attachment to the SOW for the INEEL TWCP (DOE 2003a)

Acceptable Knowledge for Summary Category S5000 (Debris Wastes)	Analysis

(refer to Section B3-8)

L-4150, Total Metals Acid Digestion Procedure of Solid, Liquid, and TCLP
Extract Samplero

L-4151, Waste Analysis by Atomic Absorption Spectroscopyo

L-4152, Mercury Analysis in Waste (Cold-Vapor Technique)o

L-4153, Trace Metals by ICP Spectrometry (Solids, Liquids, and TCLP
Extracts)o

L-4217, Metals Analysis Data Compilation And Reportingo

Attachment to the SOW for the INEEL TWCP (DOE 2003a)	Analysis

L-4035, Metals Data Verification and Validation Data Generation Levelo

Attachment to the SOW for the INEEL TWCP (DOE 2003a)





Hydrogen and Methane	Hydrogen and Methane Analysis

ASTM Method D2650-83 (ASTM 1983a)	Analysis

(refer to Section B3-16)

SUMMA® Canisters

L-2421, Precision Gas Mass Spectrometry Operations and Analysis (VG
30-38)l

Automated Manifold

L-4231, Headspace Gas Sampling and Analysis Using an Automated Manifoldw

PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System	Analysis

SUMMA® Canisters

L-5016, Data Review and Validation for Inorganic Gases for WIPP-TRU
Waste Characterization Program (TWCP) – Data Generation Levell

Automated Manifold

L-4053, Headspace Gas V & V (Data Generator Level)v

Headspace Gas Sampling/Analysis 	Headspace Gas Sampling/Analysis

	Sampling/Analysis

SUMMA® Canisters

(refer to Section B1-1 and Section B3-2)

PRO-1141-WP-4701, Waste Characterization Gas Samplingl

L-4138, SUMMA( Passivated Stainless Steel Canister Cleaning and
Certificationl

L-4146, Headspace Gas Sampling of Waste Containersl

L-4006, Chain-of-Custody and Sample Administration for Headspace Sample
Canistersl

Automated Manifold

L-4231, Headspace Gas Sampling and Analysis Using an Automated Manifoldw

PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System

PRO-1351-440-SWB, Room 113 Perma-Con Operations

PRO-717-HDGAS-371, Headspace Gas Sampling, Building 371p
Sampling/Analysis

SUMMA® Canisters

L-5017, HVOC Data Review and Validation (Data Generator Level)l

Automated Manifold

L-4053, Headspace Gas V & V (Data Generator Level)v

PRO-1669-HGAS-V&V, Headspace Gas V&V (Data Generator Level)





Homogeneous Solids and Soil/Gravel Sampling

Newly Generated Waste Sampling

	Homogeneous Solids and Soil/Gravel Sampling

EPA SW-846

See the Attachment to the SOW for the INEEL TWCP (DOE 2003a) for RFETS
waste sampled at INEEL

Newly Generated Waste Sampling

Sampling is done in accordance with EPA SW-846

	Sampling

(refer to Section B1-2 and Section B3-3)

PRO-543-ASD-002, Initiation and Preparation of Chain-of-Custody Forms

PRO-1623-SCWS-440, Small Container Waste Sampling - TRU Projects

L-4028, Sample Administration for the Radiological Laboratorieso

See the Attachment to the SOW for the INEEL TWCP (DOE 2003a) for RFETS
waste sampled at INEEL

Newly Generated Waste Sampling

Building 774 Aqueous Sludge

RS-012-004, Grid Method - Solid Sampling and Analysis Plan

PRO-1265-SS-001, Building 774 and Tank T-207 Aqueous Sludge Removal and
Characterization Plan

PRO-1266-SS-002, Tank Sludge Removal from Pre-Selected Areas, Building
774q

PRO-1628-A2-001, Tank Sludge Removal from Pre-Selected Areas, Tank
T-207t

PRO-860-RS-0156, Solid Sampling, Building 371o

TRU Soil

RS-012-004, Grid Method - Solid Sampling and Analysis Plan

PRO-1730-903-001, 903 Pad Soil Removal/Repack and Characterization Plan

PRO-1729-903-SOIL, Soil Removal From Pre-Selected Areas, 903 Pad

PRO-1623-SCWS-440, Small Container Waste Sampling - TRU Projects

Polymerized Organic Liquid Sampling

PRO-1569-SAP-001, Polymerized Organic and Inorganic Liquid Process –
Sampling and Analysis Plan

PRO-1585-PWS-440, Polymerized Waste Sampling Building 440

PRO-1623-SCWS-440, Small Container Waste Sampling - TRU Projects
Sampling

PRO-604-RC-001, Field Sample QC Data Calculation, Review, and Validation
Batch Reports

PRO-1618-PLP-001, Data Review and Verification of Solid Sampling Batch
Data Reports – TRU Projects

See the Attachment to the SOW for the INEEL TWCP (DOE 2003a) for RFETS
waste sampled at INEEL

Newly Generated Waste Sampling

Building 774 Aqueous Sludge

PRO-603-RS-0152, Data Review and Verification of Solid Sampling Batch
Reports

TRU Soil

PRO-1618-PLP-001, Data Review and Verification of Solid Sampling Batch
Data Reports – TRU Projects

Polymerized Organic Liquid Sampling

PRO-1618-PLP-001, Data Review and Verification of Solid Sampling Batch
Data Reports – TRU Projects







	



Retrievably Stored and Repackaged Retrievably Stored Waste Sampling

	Retrievably Stored and Repackaged Retrievably Stored Waste Sampling

Sampling is done in accordance with EPA SW-846

	Retrievably Stored and Repackaged Retrievably Stored Waste Sampling

Salt

Combustible

Low Grade Plutonium Oxides

RS-012-004, Grid Method - Solid Sampling and Analysis Plan 

PRO-860-RS-0156, Solid Sampling, Building 371o

Ash

RS-012-005, Cone and Quartering Method - Solid Sampling and Analysis
Planu

Or

RS-012-004, Grid Method – Solid Sampling and Analysis Plan

PRO-X56-RS-0123, Ash Residue Repack, Building 707h

Or

PRO-860-RS-0156, Solid Sampling, Building 371o

Dry

Not applicable – Debris Waste only

	Retrievably Stored and Repackaged Retrievably Stored Waste Sampling

Salt

Combustible

Low Grade Plutonium Oxides

PRO-603-RS-0152, Data Review and Verification of Solid Sampling Batch
Reports

Ash

PRO-428-RS-0146, Data Review and Validation of Ash Residue Repack Sample
Batch Reportsh

PRO-603-RS-0152, Data Review and Verification of Solid Sampling Batch
Reports

Dry

Not applicable – Debris Waste only

General

PRO-1618-PLP-001, Data Review and Verification of Solid Sampling Batch
Data Reports – TRU Projects



General

PRO-1623-SCWS-440, Small Container Waste Sampling - TRU Projects

	

a Permit Attachment B

b Required only for homogeneous solids and soil/gravel from Savannah
River Site.

c Required only for homogeneous solids and soil/gravel from Oak Ridge
National Laboratory and Savannah River Site.

d Can also be analyzed as a semi-volatile organic compound.

e Can also be analyzed as a volatile organic compound.

f 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.

g The Salt Residue stabilization/repack activity that utilized this
procedure was completed in June 2000.

h The Ash Residue repack and sampling activities that utilized these
procedures stopped operation in Building 707 in December 2000.

i The Dry Residue repack activity that utilized this procedure stopped
operation in Building 707 in November 2000.

j	This procedure is used for repackaged retrievably stored waste not
packaged using a Residue procedure.

k	This procedure is inactive as of November 6, 2001.

l	These procedures are no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS.

m This procedure is inactive as of May 6, 2002.

n  This procedure is inactive as of April 30, 2003.

o This procedure is to be deactivated in February 2004.

p This procedure is inactive as of May 12, 2003.

q This procedure is inactive as of April 29, 2003.

r This procedure is inactive as of November 14, 2003.

s This procedure is inactive as of August 12, 2003.

t This procedure is inactive as of July 10, 2003.

u This plan is inactive as of December 2003.

v This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

w This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.



Table B-2, Maximum Allowable VOC Room-Averaged Headspace Concentration
Limits (PPMV)

COMPOUND	VOC HEADSPACE CONCENTRATION LIMITS a, b, c (PPMV)

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	There are no headspace limits for other VOCs, and there are no
headspace limits for individual containers.

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 RFETS.

c	At RFETS, 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 the WIPP O&M Contractor on a
case-by-case basis.  Approval for containers exceeding the average
limits will be done through the WWIS exception process. 



Table B-3, Headspace Gas: Target Analyte List and Methods

PARAMETER	EPA SPECIFIED ANALYTICAL METHOD

Benzene

Bromoform

Carbon Disulfide (site-specific parameter)

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), 1988, "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 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.

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,d

Nonhalogenated Volatile Organic Compounds (VOCs)	Acetone

Benzene

n-Butanol

Carbon disulfide

Ethyl benzene

Ethyl ether

Formaldehyde

Hydrazineb

Isobutanol

Methanol

Methyl ethyl ketone

Toluene

Xylenes	8015

8240

8260



Halogenated VOCs	Bromoform

Carbon tetrachloride

Chlorobenzene

Chloromethane e

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)	Acetophenone e

Cresols (o, m, p)

1,2-Dichlorobenzenec

1,4-Dichlorobenzenec

2,4-Dinitrophenol

2,4-Dinitrotoluene

Hexachlorobenzene

Hexachloroethane

Nitrobenzene

Pentachlorophenol

Pyridinec	8250

8270



a	U.S.  Environmental Protection Agency (EPA), 1996, "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 Permittees for
approval.

c	These compounds may also be analyzed as VOCs by SW-846 Methods 8240
and 8260.

d	TCLP (SW-846 Method 1311) may be used to determine if compounds in
20.4.1.200 NMAC (incorporating 40 CFR 261, Subpart C) exhibit a toxicity
characteristic.

e	Added as a TIC (see Table B3-4 or Table B3-6).

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

TCLP	1311

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
20.4.1.200 NMAC (incorporating 40 CFR 261, Subpart C) exhibit a toxicity
characteristic.

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	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 (see Tables B-4 and
B-5)	(	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	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 or statistical sampling  a, b
(see Table B-3)	(	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 acceptable knowledge



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.



Table B-7, Required Program Records Maintained in RFETS 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.)





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 or TCLP Metals Char.  Method d

Total Semi-VOC Char.  Method d

Item Description Code

Haz.  Manifest Number

NDE Complete e

	Total VOC Sample Date

Total VOC Analysis Date

Total VOC Analyte Name d

Total VOC Analyte Concentration d

Total or TCLP Metal Sample Date

Total or TCLP Metal Analysis Date

Total or TCLP Metal Analyte Name d

Total or TCLP 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-gallon drums, 4-packs of 85-gallon drums,
or 3-packs of 100-gallon 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.



	Page		1		of		

WIPP WASTE STREAM PROFILE FORM

Waste Stream Profile Number:	

Generator site name:			Technical contact:		

Generator site EPA ID:			Technical contact phone number:		

Date of audit report approved by NMED:		

Title, version number, and date of documents used for WAP certification:
	

	

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

	

Waste Stream Information (1)

WIPP ID: 			Summary Category Group:		

Waste Matrix Code Group: 			Waste Stream Name: 		

Description from the WTWBIR: 		

	

Defense TRU Waste: ( Yes ( No		

Check one: ( CH   ( RH      Number of SWBs _____  Number of Drums _____ 
Number of Canisters 	

Batch Data Report numbers supporting this waste stream characterization:
	

List applicable EPA Hazardous Waste Codes(2):		

	

Applicable TRUCON Content Codes: 		

Acceptable Knowledge Information(1)

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

Required Program Information

•	Map of site: 		

•	Facility mission description: 	

•	Description of operations that generate waste:		

	

•	Waste identification/categorization schemes:		

•	Types and quantities of waste generated:		

•	Correlation of waste streams generated from the same building and
process, as appropriate:	

	

•	Waste certification procedures:		

Required Waste Stream Information

•	Area(s) and building(s) from which the waste stream was generated: 	


•	Waste stream volume and time period of generation:		

•	Waste generating process description for each building:		

•	Process flow diagrams:		

•	Material inputs or other information identifying
chemical/radionuclide content and physical waste form:		

	

•	Which Defense Activity generated the waste:  (Check one)

(	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 materials production

(	Defense nuclear waste and materials security and safeguards and
security investigations

(Example)

Figure B-1, WIPP Waste Stream Profile Form



WASTE STREAM PROFILE FORM AND INSTRUCTIONS (continued)

	Page		2		of		

Supplemental Documentation

•	Process design documents:		

•	Standard operating procedures: 		

•	Safety Analysis Reports:		

·•	Waste packaging logs: 		

•	Test plans/research project reports:		

•	Site data bases:		

•	Information from site personnel:		

•	Standard industry documents:		

•	Previous analytical data:		

•	Material safety data sheets:		

•	Sampling and analysis data from comparable/surrogate Waste:		

•	Laboratory notebooks:		

Sampling and Analysis Information(1)

[For the following, when applicable, enter procedure title(s), number(s)
and date(s)]

(	Radiography:		

(	Visual Examination:		

(	Headspace Gas Analysis

VOCs:		

Flammable:	

Other gases (specify):	

(	Homogeneous Solids/Soils/Gravel Sample Analysis

Total metals:	

VOCs:		

Nonhalogenated VOCs:	

Semi-VOCs:	

Other (specify):	

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.

					

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.

(Example)

Figure B-1, WIPP Waste Stream Profile Form (continued)



Figure B-2, Data Collection Design for Characterization of Newly
Generated Waste 

 

Figure B-3, Data Collection Design for Characterization of Retrievably
Stored Waste

 

Figure B-4, Levels of Data Verification 

 

Figure B-5, TRU Mixed Waste Screening Flow Diagram

B1.	WASTE CHARACTERIZATION SAMPLING METHODS

RFETS uses the following methods for the characterization of TRU waste
that is managed, stored, or disposed at WIPP.  These methods include
requirements for headspace gas sampling, 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

This section describes minimum requirements for collecting headspace gas
samples.  RFETS collects and analyzes headspace gas samples in
accordance with the requirements specified in the WIPP-WAP.  In
addition, headspace gas samples are also collected using the methodology
presented in this section to fulfill site-specific requirements for
hydrogen and methane analysis (refer to Section B3-16).

B1-1a	Method Requirements

Headspace gas sampling is performed in an appropriate contamination area
that meets the facility and RFETS radiological controls.

Before sampling, waste containers are in compliance with the container
equilibrium requirement (i.e., 72 hours at 18o C or higher).  

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 listed in
Section B-3a(1) and which are designated as summary category S5000
(Debris waste) are categorized under one of the sampling scenarios shown
in Table B1-5 and depicted in Figure B1-7.  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 are 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 (Section B-3d(1)), a conservative
default Packaging Configuration Group of 3 for drums and 6 for 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 (Section
B-3d(1)), repackaging (Section B-3d(1)), and/or venting (Section
B1-1a[6][ii]) are determined using the default conditions in footnote
“b” in Table B1-9.  The DAC for Scenario 3 containers that contain
filters that are either undocumented or are other than those listed in
Table B1-9 are determined using footnote “a” in Table B1-9.  Each of
the Scenario 3 containers are 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.

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 listed in
Section B-3a(1) and which are designated as either summary category
S3000 (Homogeneous solids) or S4000 (Soil/gravel) are categorized under
one of the sampling scenarios shown in Table B1-5 and depicted in Figure
B1-7.  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 are
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 (Section B-3d(1)), a conservative default Packaging
Configuration Group of 3 for drums and 6 for 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 (Section
B-3d(1)), repackaging (Section B-3d(1)), and/or venting (Section
B1-1a[6][ii]) are 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 are determined using footnote “a” in Table B1-10.  Each
of the Scenario 3 containers are 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.

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.  RFETS uses the default conditions specified in Tables
B1-7 through B1-10 for retrievably stored waste, or the data documented
during packaging (Section B-3d(1)), repackaging (Section B-3d(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 Table B1-7;

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;

NOTE:	RFETS newly generated and repackaged retrievably stored waste is
packaged per 1-PRO-079-WGI-001, Waste Characterization, Generation, and
Packaging, which specifies a TRUCON code, and the number of confinement
layers for compliance with the TRUCON code.  The TRUCON code is
documented in the headspace Sample Batch Data Report and is used to
establish the applicable Scenario 3 packaging configuration.

The permit-required equilibrium time; and

The drum age.

For all retrievably stored waste containers, the rigid liner vent hole
diameter is 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 is assumed to
be the most restrictive unless container-specific information clearly
identifies a filter model and/or diffusivity characteristic that is less
restrictive.  For all retrievably stored waste containers that have not
been repackaged, AK is not used to justify any packaging configuration
less conservative than the default (i.e., Packaging Configuration Group
3 for drums and 6 for SWBs).

The RFETS default packaging configuration for retreivably stored waste
containers that have not been repackaged is Packaging Configuration
Group 3 for drums and 6 for SWBs.  The default retrievably stored rigid
liner vent hole diameter is 0.3-inch.  The filters installed on RFETS
retrievably stored waste containers include both NucFil-012 and
NucFil-013, therefore the hydrogen diffusivity for retrievably stored
waste is assumed to be the most restrictive (1.9x10-6 mol/s/mol
fraction).  The packaging configuration, rigid liner vent hole diameter,
and type and number of filters for RFETS repackaged retrievably stored
waste are determined in the same manner as those for newly generated
waste.

B1-1a(3)	General Requirements (continued)

RFETS newly generated waste is defined as TRU waste generated after NMED
approved the final audit report for RFETS (April 8, 2002), and waste
generated prior to this date characterized with VV during packaging. 
For newly generated waste the packaging configuration is documented by
the TRUCON code assigned to the waste.  NucFil-013 filters are installed
on newly generated waste containers, as documented during packaging,
therefore, the hydrogen diffusivity is 3.7x10-6 mol/s/mol fraction per
filter.  The installation of a rigid liner is documented during
packaging of newly generated waste, and the default rigid liner vent
hole diameter is 0.75-inch based on the liner types used at RFETS (see
ELD-057-01 and SPEC-11170-0485).  All rigid liners in RFETS TRU wastes
are Type III, IV, or V, the specifications for which all require
0.75-inch diameter or larger vent holes.

All waste containers with unvented rigid containers greater than 4
liters (exclusive of rigid poly liners) shall be subject to innermost
layer of containment sampling or shall be 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).  Headspace gas samples are analyzed
for the analytes listed in Table B3-2.  Consistent with footnote “a”
in Table B1-8, any waste container that connot be assigned a packaging
configuration specified in Table B1-8, is not 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 in BWXT, 2000.

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.

RFETS requires personnel to collect samples in SUMMA( or equivalent
canisters using standard headspace gas sampling methods that meet the
appropriate general guidelines established by the U.S. Environmental
Protection Agency (EPA) in the Compendium Method TO-14, The
Determination of Volatile Organic Compounds (VOC) in Ambient Air Using
SUMMA( Passivated Canister Sampling and Gas Chromatographic Analysis
(EPA 1988) for TRU waste characterization or by using on-line integrated
sampling/analysis systems.  

B1-1a(3)	General Requirements (continued)

Prior to October 22, 2002 headspace gas samples were collected using
both SUMMA( or equivalent canisters and on-line integrated
sampling/analysis systems, operated by the RFETS Analytical
Laboratories.  Following this date, all headspace gas sampling and
analysis is conducted at RFETS utilizing on-line integrated systems,
operated by Headspace Analytical Services.  Information relative to
headspace sampling with SUMMA( canisters is included for historical
traceability and consistency with the WIPP-WAP.

Headspace Gas Sampling Using SUMMA( or Equivalent Canisters

Headspace gas sampling of waste containers at RFETS was conducted
utilizing SUMMA( or equivalent canisters as specified by the Analytical
Laboratories procedures and Waste Operations (WO) procedures.  The
following procedures list the specific activities, and requirements to
prepare and test the sampling equipment for sampling readiness and for
obtaining the required field blank, field reference standard, and
headspace samples:

L-4138, SUMMA® Passivated Stainless Steel Canister Cleaning and
Certification [This procedure  describes the method for the
batch-process cleaning and certification of sample canisters prior to
being used for headspace sampling].

L-4146, Headspace Gas Sampling of Waste Containers1 [This procedure
describes the headspace sampling manifold and the methods used to
perform headspace gas sampling; includes a diagram of the manifold; and
provides step-by-step instructions for sampling, manifold cleaning,
maintenance, and certification or calibration of monitoring devices].

L-4006, Chain-of-Custody and Sample Administration for Headspace Gas
Sample Canisters1 [This procedure describes the COC and defines the
procedures used to control, secure and prevent tampering with the
samples prior to completion of the analysis.  When a sample is
collected, a COC form is initiated and will accompany the sample until
the sample is destroyed and removed from the TWCP.  Refer to Section
B1-4 of this document].

PRO-1141-WP-4701, Waste Characterization Gas Sampling1 [This procedure
is used by Building 776/777 Closure Project Personnel who assist
analytical laboratory personnel with waste characterization headspace
gas sampling].

B1-1a(3)	General Requirements (continued)

On-Line Headspace Gas Sampling

Samples are directed to an analytical instrument instead of being
collected in SUMMA( or equivalent canisters if a single-sample on-line
integrated sampling/analysis system is used.  If a multi-sample on-line
integrated sampling system/analysis system is used, samples are directed
to an array of Silco( steel passivated stainless steel canisters that
meets the cleaning requirements of Section B1-1c(1).  The leak proof and
inert nature of the interior surface of the canisters will be
demonstrated and documented.  Samples are not transported to another
location when using on-line integrated sampling/analysis systems;
therefore, 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 must be met. 
However, when using an on-line integrated sampling/analysis system, the
sampling batch and analytical batch quality control (QC) samples are
combined as on-line batch QC samples as outlined in Section B1-1b.

Headspace gas sampling of waste containers at RFETS is currently
conducted as specified by Headspace Analytical Services procedures and
WO procedures.    The following procedures list the specific activities,
and requirements to prepare and test the sampling equipment for sampling
readiness and for obtaining the required field blank, field reference
standard, and headspace samples

PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System; and L-4231, Headspace Gas Sampling and Analysis Using
an Automated Manifold [These procedures describe the automated headspace
sampling manifold and the methods used to perform headspace gas
sampling, and provides step-by-step instructions for sampling, manifold
cleaning, maintenance, and calibration of the system].

PRO-1351-440-SWB, Room 113 Perma-Con Operations [This procedure is used
by Building 440 personnel who assist Headspace Analytical Services
personnel with waste characterization headspace gas sampling].

PRO-717-HDGAS-371, Headspace Gas Sampling, Building 371 [This procedure
is used by Building 371 personnel who assist Headspace Analytical
Services personnel with waste characterization headspace gas sampling].

B1-1a(4)	Manifold Headspace Gas Sampling

The headspace gas sampling protocol employs a multiport manifold capable
of collecting multiple simultaneous headspace samples for analysis and
QC purposes.  The manifold can be used to collect samples in SUMMA( or
equivalent canisters or as part of an on-line integrated
sampling/analysis system.  The sampling equipment is leak checked and
cleaned prior to first use and as needed thereafter.  The systems are
evacuated to less than or equal to 0.0039 inches of mercury [equivalent
to 0.10 millimeters (mm) mercury (Hg)] prior to sample collection.  For
headspace gas sampling with SUMMA( canisters, cleaned and evacuated
canisters are attached to the evacuated manifold before the manifold
inlet valve is opened.  The sampling valve is attached to a changeable
filter connected to either a side port needle sampling head capable of
forming an airtight seal (for penetrating a filter and/or a rigid poly
liner when necessary), or a drum punch sampling head (capable of
punching through the metal lid of a drum while maintaining an airtight
seal for sampling through the drum lid), or a sampling head with an
airtight seal for sampling through a pipe overpack component filter vent
hole.  Refer to Section B1-1a(6) for descriptions of these sampling
heads. 

Each system is also equipped with a purge assembly that allows
applicable QC samples to be collected through all sampling components
that may affect compliance with 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.  If using SUMMA( or equivalent canisters,
field blanks are collected directly into the canister, without the use
of the manifold.

The manifold, associated sampling head, and headspace gas sample volume
are designed to ensure the collection of representative samples.  A
logbook, dedicated to headspace gas sample collection, records the
calculated internal manifold volume.  The total volume of headspace
gases collected during each sampling operation is determined by adding
the combined volume of the canisters attached to the manifold and the
internal volume of the manifold.  The sample volume should remain small
in comparison to the volume of the waste container.  A general criterion
is that no more than 10 percent of the available headspace volume should
be withdrawn to ensure that leakage of room air does not seriously
contaminate the sample.  55-gallon drums are considered to have in
excess of 10 liters of available headspace, which is enough to take all
samples and duplicates.

B1-1a(4)(i)	Major Components and Requirements – Sample Side and
Standard Side

The sample side of the headspace system consists of the following major
components:

An applicable sampling head forms a leak tight connection with the
headspace sampling manifold.

A flexible hose assembly is used to allow movement of the sampling head
from the purge assembly to waste container.

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° to 50°C.

B1-1a(4)(i)	Major Components and Requirements – Sample Side and
Standard Side  (continued)

The number of ports for attaching headspace sample canisters is
sufficient to allow simultaneous collection of headspace samples and
duplicates for VOC analysis. If using an on-line integrated
sampling/analysis system, only one port is necessary for the collection
of comparison samples.  Ports not occupied with sample canisters during
cleaning or headspace gas sampling activities require a plug to prevent
ambient air from entering the system.  Valves may be used in place of
plugs.  Ports shall have VCR( fittings for connection to the sample
canister(s) to prevent degradation of the fittings on the canisters and
manifold.

The sample canisters are leak-free stainless steel pressure vessels with
a chromium-nickel oxide SUMMA( passivated interior surface and a bellows
valve. Equivalent designs, such as Silco Steel canisters, may be used so
long as the leak proof and inert nature of the canister interior surface
is demonstrated and documented.  Canisters have VCR( fittings for
connection to sampling and analytical equipment, are helium leak tested
to 1.5x10-7 standard cc/sec, have all stainless steel construction and
are capable of tolerating temperatures to 125( C.  The pressure/vacuum
gauge is mounted on each manifold.  The gauge range is capable of
operating in the leak test range specified in Section B1-1c(1) as well
as the sample collection range.  A pressure gauge connected to the
sampling manifold is used to measure the pressure in SUMMA( canisters
during sampling operations.

A dry vacuum pump or oil vacuum pump is used to reduce the pressure in
the headspace sampling manifold to less than or equal to 0.05 mm Hg.  If
a vacuum pump that requires oil is used, precautions are taken to
prevent diffusion of oil vapors back to the manifold.

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

If real-time equipment blanks are not available for headspace gas
sampling using SUMMA( canisters, the manifold is equipped with an OVA
capable of detecting the analytes listed in Table B3-2. The OVA is
capable of measuring total VOC concentration below the lowest headspace
gas PRQL.  Detection of 1,1,2-trichloro-1,2,2-trifluoroethane may not be
possible if a photoionization detector is used.  The OVA measurement is
confirmed by the collection of 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 air, helium, argon, or nitrogen is used to
clean the manifold between samples and provide gas for the collection of
on-line or equipment blanks.  These high-purity gases are certified by
the manufacturer to contain less than one-ppm total VOCs.  The gases are
metered into the standard side of the manifold using devices 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.

B1-1a(4)(i)	Major Components and Requirements – Sample Side and
Standard Side  (continued)

On-line control sample gases or field reference standard gases are used
for evaluating the accuracy of the headspace sampling process.  Each
cylinder of field-reference gas or on-line control sample gas has a
flow-regulating device.  The field reference standard gases are
certified by the manufacturer to contain selected analytes from Table
B3-2 of the WIPP-WAP at known concentrations.

A humidifier filled with ASTM D1193-77 (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
conditions the equipment blanks and field-reference standards and
assists with system cleaning between headspace gas sample collection. 
In lieu of the humidifier, the compressed gas cylinders (e.g., zero air
and field-reference standard gas) may contain water vapor in the
concentration range of 1000 to 10,000 parts per million by volume
(ppmv).

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

A flow-indicating device or a pressure regulator connected to the purge
assembly, monitors the gas flow rate through the purge assembly.  The
flow rate or pressure through the purge assembly are monitored to assure
excess flow exists during cleaning activities and during QC sample
collection.

The area in which the manifold is operated contains sensors for
measuring ambient pressure and ambient temperature as follows:

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 resolution of 1.0 mm Hg or less.  Calibration performed is
based on National Institute of Standards and Technology (NIST), or
equivalent, standards.

A temperature sensor with a minimum range of 18° to 50°C is in the
sampling/manifold location.  The temperature sensor calibration is
traceable to NIST, or equivalent, standards.

B1-1a(5)	Direct Canister

RFETS does not use the direct canister method for the characterization
of TRU wastes destined for the WIPP facility.

Prior to October 22, 2002 in conjunction with headspace gas sampling
utilizing the SUMMA( or equivalent canister protocol, field blanks were
collected in SUMMA( canisters, or equivalent canisters, by the direct
canister method per the requirement presented in Attachment B1-1a(1)of
the WIPP-WAP.

B1-1a(6)	Sampling Heads 

A sample of the headspace gas is collected from within each container. 
Three methods, sampling through the filter, sampling through the drum
lid by drum punching (not implemented at RFETS), and sampling through a
pipe overpack component filter vent hole have been developed for
collecting a representative sample.  The chosen sampling method
preserves the integrity of the SWB or 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 collect samples through the filter, a side port needle, connected to
a sampling manifold, is pressed through the filter and into the
headspace beneath the container lid (e.g., a side-port needle is a
hollow needle sealed at the tip with a small opening on its side close
to the tip.)  This permits the gas to be drawn into the manifold or
directly into the canister(s).  To assure that the sample collected is
representative, 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 and SWB headspace gas sampling through the filter:

NOTE:	If, when the sample is collected, it is not known whether the
rigid liner has been vented, the drum lid is removed and the rigid liner
visually examined to determine if it has been punctured.  If the rigid
liner has been punctured, the sample is submitted for analysis and no
further samples are required.  If the rigid liner has not been
punctured, then an NCR is issued and the sample is discarded.  The
discarding of the sample is noted in the comment section of the sampling
logbook.  If the DAC for Scenario 1 is met, a new sample is then
collected through the rigid liner (i.e., a gas sampling needle,
connected to a sampling manifold, is used to pierce the rigid liner lid
and to collect the headspace gas sample from inside the rigid liner).

The lid of the drum’s 90-mil or greater rigid poly liner contains a
hole for venting to the drum headspace.  A representative sample cannot
be collected from the drum headspace until the 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 the sample is
collected by removing the drum lid, the sampling device forms 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 liner satisfies this requirement).  If
headspace gas samples are collected from the drum headspace prior to
venting the rigid poly liner, the sample is not acceptable and a
nonconformance report shall be prepared, submitted, and resolved. 
Nonconformance procedures are outlined in Section B3-13.  A new sample
is then collected through the rigid liner.

For sample collection, the drum’s or SWB’s filters are sealed,
preventing outside air from entering the drum and diluting and/or
contaminating the sample.

B1-1a(6)(i)	Sampling Through the Filter (continued)

The sampling head for collecting container 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 housing of the filter allows insertion of the sampling needle
through the filter element or a sampling port with septum that bypasses
the filter element into the container headspace.

The side-port needle is used to reduce the potential for plugging.

The purge assembly is compatible with the side-port needle.

Sampling Through the Filter and Rigid Liner

To ensure representative samples are collected from containers with
rigid liners, sampling through the filter and rigid liner may be
conducted if the DAC for Scenario 1 is met.  The requirements for
sampling through the filter are met with the addition of the following
requirements that are pertinent to headspace gas sampling through the
filter and rigid liner:

A sample is taken through the rigid liner by using a longer needle that
will go through the filter and then liner.

When the needle is removed the filter is removed and a hole is drilled
in the liner.  Then a new filter is installed.

B1-1a (6)(ii)	Sampling Through the Drum Lid By Drum Punching

The following method has never been implemented at RFETS, and is
included for consistency with the WIPP-WAP.  Sampling through the drum
lid at the time of drum punching or thereafter may be performed as an
alternative to sampling through the drum’s filter if an airtight seal
can be maintained.  To sample the drum headspace gas through the drum
lid at the time of drum punching or thereafter, the lid is breached
using an appropriate punch (e.g., punch, self-tapping screw).  The punch
forms an airtight seal between the drum lid and the manifold or direct
canister sampling equipment.  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 (EPA 1988) 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 sampling system that come into contact with sample
gases are purged with humidified zero air, nitrogen, or helium prior to
sample collection.

Equipment blanks and field reference standards are collected through all
the components of the punch that contact the headspace gas sample.

Pressure is applied to the punch until the drum lid has been breached.

Provisions are made to relieve excessive drum pressure increases during
drum-punch operations; potential pressure increases may occur during
sealing of the drum punch to the drum lid.

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

During sampling, the drum’s filter, if present, is sealed to prevent
outside air from entering the drum.

While sampling through the drum lid using manifold sampling, a
flow-indicating device or pressure regulator to verify the flow of gases
is pneumatically connected to the drum punch sampling assembly and
operated in the same manner as the flow-indicating device described
above in Section B1-1a(4).

Equipment is used in such a manner as to secure the drum-punch sampling
system to the drum lid.

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

B1-1a(6)(iii)	Sampling Through a Pipe Overpack Component Filter Vent
Hole

Sampling through an existing filter vent hole in a pipe overpack
component (POC) may be performed as an alternative to sampling through
the POC’s filter if an airtight seal can be maintained.  To sample the
container headspace gas through a POC filter vent hole, an appropriate
airtight seal is used.  The sampling apparatus forms an airtight seal
between the POC surface and the manifold.  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 (EPA 1988) are met in addition to the following requirements:

The seal between the POC surface and the sampling apparatus is designed
to minimize the intrusion of ambient air.

The filter is replaced as quickly as is practicable with the airtight
sampling apparatus to ensure that a representative sample can be taken. 
RFETS testing and evaluation of this operation is described in the test
plan “Evaluation of Gas Tight Seal for Collection of Headspace Gas
Samples from Pipe Overpack Components,” August 16, 2001, and the
report “Summary of Results for the Test Plan for the Evaluation of Gas
Tight Seal for Collection of Headspace Gas Samples from Pipe Overpack
Components,” August 20, 2001.

All components of the sampling system that come into contact with sample
gases are cleaned according to requirements for direct canister sampling
or manifold sampling, whichever is appropriate, prior to sample
collection.

Equipment blanks and field reference standards are collected through all
the components of the sampling system that contact the headspace gas
sample.

During sampling, openings in the POC are sealed to prevent outside air
from entering the container.

A flow-indicating device is connected to the sampling system and
operated according to the direct canister or manifold sampling
requirements, as appropriate.

B1-1b	Quality Control

For manifold and direct canister sampling systems, field QC samples are
collected on a per sampling batch basis.  A sampling batch is a suite of
samples collected consecutively using the same sampling equipment within
a specific time period.  A sampling batch consists of up to 20 samples
(excluding QC samples), all of which are collected within 14 days of the
first sample in the batch.  Holding temperatures and container
requirements for gas sample containers are provided in Table B1-1. 
Table B1-2 provides a summary of field QC sample collection requirements
(refer to L-4146, Headspace Gas Sampling of Waste Containers).  Table
B1-3 provides a summary of QC sample acceptance criteria (refer to
L-5017, HVOC Data Review and Validation (Data Generator Level)1).

B1-1b	Quality Control (continued)

On-Line Headspace Gas Sampling

For on-line integrated sampling/analysis systems, 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 on-line integrated analysis system.  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
collection requirements (refer to PRO-1676-HGAS-S&A, Headspace Gas
Sampling and Analysis Using an On-Line Integrated System; and L-4231,
Headspace Gas Sampling and Analysis Using an Automated Manifold).  Table
B1-3 provides a summary of QC sample acceptance criteria (refer to
PRO-1669-HGAS-V&V, Headspace Gas V&V (Data Generator Level); and L-4053,
Headspace Gas V & V (Data Generator Level)).

For on-line integrated sampling analysis systems, 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
shall still be 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 TWCP Site PQAO monitors and documents field QC sample results and
fills out a nonconformance report if acceptance or frequency criteria
are not met, and the TWCP Site PM ensures appropriate corrective action
is taken if acceptance criteria are not met (refer to Section B3-13 of
this document).

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 TWCP Site
PM (or designee) uses the field blank data to assess impacts of ambient
contamination, if any, on the sample results.  Field blank results
determined by gas chromatography/mass spectrometry or gas
chromatography/flame ionization 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.  An NCR is
initiated and resolved if the final reported QC sample results do not
meet the acceptance criteria.

B1-1b(2)	Equipment Blanks/Manifold Blank

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/manifold
blanks collected through the manifold are collected at a frequency of
one per sampling batch for VOC analysis or one per day, whichever is
more frequent.  If direct canister method is used, field blanks may be
used in lieu of equipment blanks.  The TWCP Site PM uses the
equipment/manifold blank data to assess impacts of potentially
contaminated sampling equipment on the sample results.  Equipment blank
results determined by gas chromatography/mass spectrometry or gas
chromatography/flame ionization detection are acceptable if the
concentration of each VOC analyte is less than or equal to three times
the MDL listed in Table B3-2.  

B1-1b(3)	Field Reference Standards

Field reference standards contain known concentrations of certain target
analytes introduced and collected through the sampling manifold.  Field
reference standards are used to assess the accuracy with which the
sampling equipment collects VOC, hydrogen and methane samples into
SUMMA( 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 contain a minimum of six of the analytes
listed in Table B3-2 at concentrations within a range of 10 to 100 ppmv.
 Field reference standards for hydrogen and methane contain
concentrations greater than or equal to the PRQLs listed in Table B3-16A
and are greater than the MDL.  

If available, 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, field reference standards collected
through the manifold are collected at a frequency of one per sampling
batch.  For headspace gas sampling using SUMMA( canisters, field
reference standards are submitted as blind samples to the analytical
laboratory and results are controlled and kept blind from the analytical
laboratory functional areas.  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

Field duplicates are separate and independent samples collected from the
same source and analyzed independently.  Field duplicates are collected
simultaneously.  Field duplicates are used to assess the precision with
which the sampling procedure collects samples into SUMMA® or equivalent
canisters.  Field duplicates will 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.  If there are no target analytes above the PRQL
detected in the duplicate samples then a second field reference standard
will be used as the duplicate.  The two field reference standards must
meet the same duplicate drum sample criteria.

B1-1c	Equipment Testing, Inspection, and Maintenance

All sampling equipment components that come into contact with headspace
sample gases are constructed of relatively inert materials such as
stainless steel or Teflon(.

To minimize the potential for cross contamination of samples, the
headspace-sampling manifold and sample canisters are cleaned and
leak-checked prior to each sampling event.  Procedures used for cleaning
and preparing the manifold and sample canisters are equivalent to
EPA’s Compendium Method TO-14 (EPA 1988) and meet the requirements
specified in the WIPP-WAP.

B1-1c(1)	Headspace Gas Sample Canister Cleaning

SUMMA® canisters are cleaned and certified for use as described in
L-4138, SUMMA® Passivated Stainless Steel Canister Cleaning and
Certification and Silco( steel passivated stainless steel canisters are
cleaned and certified for use as described in PRO-1676-HGAS-S&A,
Headspace Gas Sampling Using an On-Line Integrated System; and L-4231,
Headspace Gas Sampling and Analysis Using an Automated Manifold.  These
procedures meet the requirements specified in the WIPP-WAP.

Canisters are cleaned and certified on an equipment cleaning batch
basis.  An equipment cleaning batch is any number of canisters cleaned
together at one time using the same cleaning method.  The cleaning
system is capable of processing multiple canisters at a time.  It is
composed of an oven (optional) and vacuum manifold which uses a dry
vacuum pump (or a cryogenic trap backed by an oil sealed pump) to clean
canisters.  Prior to cleaning, a leak test is performed on all
canisters.  For a pressure leak check, a canister passes if the pressure
does not change at a rate of greater than (2 psig in 24 hours.  Any
canister that fails is checked for leaks, repaired, and reprocessed. One
canister per equipment cleaning batch is filled with humid zero air or
humid high purity nitrogen and analyzed for VOCs.  The equipment
cleaning batch of canisters is considered clean if there are no VOCs
above three times the MDLs listed in Table B3-2.  After the canisters
have been certified for leak tightness and found to be free of
background contamination, they are evacuated to 0.10 mm Hg or less for
storage.  Certification documentation for SUMMA( canisters is
maintained.

B1-1c(2)	Sampling Equipment Initial Cleaning and Leak-Check 

Surfaces of headspace gas sampling equipment components that come into
contact with headspace gas are thoroughly inspected and cleaned prior to
assembly.  The manifold and associated sampling heads shall be purged
with humidified zero air, nitrogen, or helium, and leak checked after
assembly.  This cleaning shall be repeated if the manifold and/or
associated sampling heads are contaminated to the extent that the
routine system cleaning is inadequate.

B1-1c(3)	Sampling Equipment Routine Cleaning and Leak-Check 

The manifold and associated sampling heads which are reused are cleaned
and checked for leaks in accordance with procedures which are equivalent
to EPA’s Compendium Method TO-14 (EPA 1988), and meet the requirements
specified in the WIPP-WAP.  The applicable procedure is conducted after
headspace gas samples, after field duplicate collection; after field
blank collection; after field blanks are collected through the manifold,
and after the additional cleaning required for field reference standard
collection has been completed.  The protocol for routine manifold
cleaning and leak check requires that sample canisters be attached to
the canister ports, or that the ports be capped or closed by valves, and
requires that the sampling head be attached to the purge assembly.

B1-1c(3)	Sampling Equipment Routine Cleaning and Leak-Check (continued)

VOCs are removed from the internal surfaces of the headspace sampling
manifold 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
is 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.

The equipment blank is evaluated.  If the equipment blank exceeds the
VOC limits, the sampling is terminated.  For general equipment problems
such as failing a leak check or sampling cart component failure, the
project manager has authorized the area chemist to be responsible to
correct the mechanical problems and return the equipment to service.

B1-1c(4)	Manifold Cleaning After Field Reference Standard Collection 

The sampling system is specially cleaned after a field reference
standard has been collected, because the field reference standard gases
contaminate the standard side of the headspace sampling manifold when
they are regulated through the purge assembly.  The requirement for the
“installation of a gas-tight connector between the flexible hose and
the purge assembly” for manifold cleaning can be met by sticking the
sampling head needle through a septum to connect the sampling side with
purge side of the manifold.  This configuration allows both the sample
and standard sides of the sampling system to be flushed (evacuated and
pressurized) with humidified zero air, nitrogen, or helium which should
sweep and adequately clean the system’s internal surfaces.  After
completing this protocol and prior to collecting another sample, the
routine system cleaning and leak check is also performed.

B1-1c(5)	Sampling Head Cleaning 

To prevent cross contamination, the needle or airtight seal, adapters,
and filter of the sampling heads are cleaned or replaced.  If cleaned,
cleaning is performed in accordance with EPA’s Compendium Method TO-14
(EPA 1988) prior to reuse.  As a further QC measure, the needle or
airtight seal, and filter, after cleaning or replacement, is purged with
zero air, nitrogen, or helium and capped for storage to prevent sample
contamination by VOCs potentially present in ambient air.

B1-1d	Equipment Calibration and Frequency 

The manifold pressure sensor is certified prior to initial use and then
periodically (annually or shorter frequency), using NIST traceable, or
equivalent, standards.  If necessary, the pressure indicated by the
pressure sensor 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.  Calibration gases are
certified to contain selected analytes from Table B3-2 at known
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).

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 ASTM.

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.

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 must be 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 TWCP Site PM for approval for submittal to the
CBFO.  The WIPP facility 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.

Sampling of RFETS homogeneous solids and soil/gravel waste conducted at
INEEL is described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a).

B1-2a	Method Requirements

The method 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 RFETS
laboratories conducting the analytical work will receive no more than is
required for analysis, based on the analytical methods.  Therefore,
sampling is conducted to collect samples in accordance with the
specifications presented in Table B1-4.  Samples will be collected in
accordance with the requirements of Section B1-2a(1) and sampled in
accordance with the requirements of Section B1-2a(2).  For those waste
streams defined as Summary Category Groups S3000 or S4000 in Section B,
debris that may also be present within these wastes will not be sampled.

Newly generated waste 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
Section B1-2b.

B1-2a(1)	Core Collection

In lieu of coring newly generated waste, retreivably stored waste, or
repackaged retrievably stored waste that are not amenable to coring,
other approved EPA/ASTM methods will be used to collect a representative
sample.  Containers selected from RFETS retrievably stored waste streams
amenable to coring are transferred to INEEL for sampling and analysis. 
The coring and associated solid sampling and analysis of these
containers is conducted at INEEL as described in the Attachment to the
SOW for the INEEL TWCP (DOE 2003a).

B1-2a(1)	Core Collection (continued)

Collection of homogeneous solids and soil/gravel samples meet the
requirements of Section B1-4b of this document.  Representative samples
are collected by trained personnel using standard operating procedures
in the quantities specified in Table B1-4 of this document.  For newly
generated wastes, retrievably stored waste, or repackaged retrievably
stored waste, alternative sample collection methods, as defined in the
Sampling Plans, are used rather than coring when coring is not an
effective sampling method for the particular waste stream.  

Samples of homogeneous solids and soil/gravel are collected for SVOCs,
and metals, as applicable.  These samples are collected from the same
location and/or in the same manner as the sample(s) collected for VOC
analysis (see Section B1-2a(2)). All surfaces of the sampling tools that
have the potential to come into contact with sample are constructed of
materials unlikely to affect the composition or concentrations of target
analytes in the waste (e.g., Teflon().

B1-2a(1)(i)	Alternative Sample Collection Methods

Alternative sample collection methods for TRU waste classified as
homogeneous solids and soil/gravel include the following:

Sampling in Accordance with the Grid Method

	Solid sampling that is appropriate for sampling using the “grid
method”, is accomplished in accordance with ASTM D4547-98, Standard
Guide for Sampling Waste and Soils for Volatile Organic Compounds (ASTM
1998), Section 7.5, Devices that Can be Used for Sampling a Cemented
(hard) Material, and Section 7.6, Devices that Can be Used for Sampling
a Noncohesive Material.  The standard practice prescribes methods for
the collection of solid waste, soils, and sediment samples for the
subsequent determination of VOCs.  RS-012-004, Grid Method - Solid
Sampling and Analysis Plan describes grid method sampling for
retrievably stored, repackaged retrievably stored, or newly generated
waste (e.g., salt, SS&C, and firebrick heel).  PRO-1569-SAP-001,
Polymerized Organic and Inorganic Liquid Process – Sampling and
Analysis Plan; and RS-012-004, Grid Method - Solid Sampling and Analysis
Plan supplemented by PRO-1265-SS-001, Building 774 and Tank T-207
Aqueous Sludge Removal and Characterization Plan; and PRO-1730-903-001,
903 Pad Soil Removal/Repack and Characterization Plan describe grid
method sampling of newly generated waste.

	Solid samples are collected to perform analyses for RCRA TCLP metals
(e.g., Salt and SS&C), or total metals (e.g., Firebrick Heel), and both
total volatile and total semi-volatile organic compounds.  Based upon
statistical calculations and control charting, if required, the total
number of containers to be sampled is identified.  The random selection
of a specific container for sampling is based on a random-number
generated calculation in accordance with PRO-945-WIPP-009, RCRA
Characterization of TRU Waste to be Disposed of at WIPP.

	To meet the sample preservation requirements stipulated in Section
B1-4b(2) of the QAPjP, samples may be temporarily stored in a
refrigeration unit after being generated and prior to transporting to
the analytical laboratory.

	Disposable, non-contaminating sampling equipment, such as chisels,
scoops and spoons, are used to eliminate the possibility of
cross-contamination between samples.

Refer to Table B-1 for a list of sample collection and sample analysis
procedures.

B1-2a(1)(i)	Alternative Sample Collection Methods  (continued)

Sampling Method in accordance with RS-012-005, Cone and Quartering
Method - Solid Sampling and Analysis Plan (e.g., used for TRM
Incinerator Ash, etc.)

	Solid sampling for retrievably stored or repackaged retrievably stored
waste, that is appropriate for sampling using the “cone and quartering
method”, is accomplished by ASTM C702-93, Standard Practice for
Reducing Samples of Aggregate to Testing Size, Method B, Quartering
(ASTM 1993). This standard practice prescribes a method for reduction of
a bulk material to an appropriate size for testing.

	Sampled material may include ash, soot, and other miscellaneous
inorganic materials.  The repackaged material from specific waste
streams follows an approved processing path, and is not subject to any
chemical, thermal, solidification, or immobilizing processing.

	Solid samples are collected to perform analyses for RCRA total metals
and both volatile and semi-volatile organic compounds.  Based upon
statistical calculations, the total number of containers to be sampled
is identified.  The random selection of a specific container for
sampling is based on a random-number generated calculation.

	To meet the sample preservation requirements stipulated in Section
B1-4b(2) of the QAPjP, samples are temporarily stored in a refrigeration
unit after being generated and prior to transporting to the analytical
laboratory.

	Disposable, non-contaminating sampling equipment, such as scoops and
spoons, are used to eliminate the possibility of cross-contamination
between samples.

	Refer to Table B-1 for a list of sample collection and sample analysis
procedures.

Sampling in Accordance with the Thin-Wall Tube Sampler Method

	Solid sampling for bulk packed 55-gallon drums of newly generated waste
(PRO-1569-SAP-001, Polymerized Organic and Inorganic Liquid Process –
Sampling and Analysis Plan), that is appropriate for sampling using the
“Thin-Wall Tube Sampler method”, is accomplished in accordance with
ASTM D5679-95a, Standard Practice for Sampling Consolidated Solids in
Drums or Similar Containers (ASTM 1995), Section 8.3, Sampling with a
Thin Wall Tube Sampler, and ASTM D6232-00, Standard Guide for Selection
of Sampling Equipment for Waste and Contaminated Media Data Collection
Activities (ASTM 2000), Section 7.5.5, Thin-Walled Tube.  These standard
practices prescribe methods for the collection of a relatively
undisturbed core of a cohesive solid waste for the subsequent
determination of VOCs.  

	Solid samples are collected to perform analyses for RCRA total metals,
and both total volatile and total semi-volatile organic compounds. 
Based upon statistical calculations and control charting requirements,
the total number of containers to be sampled is identified.  The random
selection of a specific container for sampling is based on a
random-number generated calculation in accordance with PRO-945-WIPP-009,
RCRA Characterization of TRU Waste to be Disposed of at WIPP.

	To meet the sample preservation requirements stipulated in Section
B1-4b(2) of the QAPjP, samples may be temporarily stored in a
refrigeration unit after being generated and prior to transporting to
the analytical laboratory.

	Disposable, non-contaminating sampling equipment, such as sampling
tubes, chisels, scoops and spoons, are used to eliminate the possibility
of cross-contamination between samples.

	Refer to Table B-1 for a list of sample collection and sample analysis
procedures.

B1-2a(2)	Sample Collection

Newly generated waste may be collected using methods other than coring,
as discussed above in Section B1-2a.  Newly generated waste samples are
collected as soon as possible after sampling, but the spatial and
temporal homogeneity of the waste stream dictates whether a
representative grab sample or composite sample is collected.  

B1-2b	Quality Control Requirements

Quality control (QC) requirements for homogeneous waste sampling include
collection of duplicates to determine precision, equipment blanks to
verify cleanliness of the sampling equipment and tools; and analysis of
reagent blanks to ensure reagents, such as deionized and high pressure
liquid chromatography (HPLC) water, are of sufficient quality.  Sampling
of homogeneous solids and soil/gravel comply, at a minimum, with the
quality control requirements in Sections B1-2b(1), B1-2b(2), and
B1-2b(3).

B1-2b(1)	Field Duplicates

Field duplicates as required by SW-846 are collected to determine the
combined precision of the coring and sampling procedures.  Duplicates
will be collected if alternate methods to coring are used. 

Duplicates are collected at a frequency of one per sampling batch or one
per week during 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 QC samples), all of which are collected within 14 days
of the first sample in the batch.  Duplicate samples are collected side
by side as close as feasible to one another, handled in the same manner,
visually inspected, and sampled in the same manner at the same randomly
selected sample location.  Samples collected from duplicates are not
required to be submitted blind to the analytical laboratory.

B1-2b(2)	Equipment Blanks

A batch of sampling equipment or tools (e.g., drill heads, ball mills,
sample splitters, bowls, spoons, chisel, VOC sub-samplers, etc.) are
cleaned prior to collecting the equipment sample blank.  This clean
batch of equipment and/or tools is termed the “clean equipment
batch”. Equipment blanks are collected at a frequency of one equipment
blank per “clean equipment batch”.  One item from the “clean
equipment batch” is selected at random, and the equipment blank is
collected from this randomly 

selected, fully assembled item (i.e., blank collected from at least
those portions of the sampling equipment that contact the sample).  The
equipment blank is collected in the area where the sample tools are
cleaned prior to covering with protective wrapping and storage, and the
equipment blank from the particular item is traceable to the “clean
equipment batch”.

Equipment blanks are collected from the selected item (i.e., equipment
or tool) as follows:

Sufficient clean water (e.g., deionized water, HPLC water) is poured
across the internal and external surfaces of the item, as necessary

A 40-mL sample of this water is collected in a clean sample container.

The collected water is analyzed for the analytes listed in Table B3-4
(for VOCs), Table B3-6 (for SVOCs), and Table B3-8 (for metals).

B1-2b(2)	Equipment Blanks (continued)

The equipment blank results are considered acceptable if the results
indicate no analyte at a concentration greater than three times the MDLs
listed in Table B3-4 and B3-6, or three times the PRDLs listed in Table
B3-8 for metals.  If the equipment blank is not acceptable, the
associated equipment batch must be either discarded or cleaned again,
and another equipment blank collected.  If the equipment blank results
indicate the presence of an analyte at a concentration greater than
three times the MDLs, then all of the items associated with that
equipment batch must either be discarded or cleaned again, and another
equipment blank collected.

Equipment blank results for sampling equipment and tools should be
reviewed prior to use.  A sufficient quantity of sampling equipment and
tools are maintained in storage to prevent disruption of sampling
operations in the event that an equipment blank is unacceptable.

B1-2b(3)	Sample Equipment Cleaning 

Sampling equipment and tools 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).

Reusable sampling equipment or tools (e.g., drill heads, ball mills,
sample splitters, etc) have a unique identification number.  When an
equipment blank is collected from sampling equipment or tools, the
unique identification number of the equipment/tool is referenced to
collected equipment blank.  The identification number is also referenced
to the waste container on the sampling equipment or tool was used.  This
information is recorded in the field records.  One piece of sampling
equipment or tool from each cleaning batch is tested for cleanliness in
accordance with the requirements specified above.  The results of the
equipment blank analysis are submitted to the sampling site with the
identification numbers of all sampling equipment or tools in the
“clean equipment batch”.

Cleanliness of disposable sampling equipment must be demonstrated.  This
may be accomplished in one of the following ways:

Collection and analysis of an equipment blank from a representative
sample of the applicable manufacturing lot in accordance with American
National Standard, Sampling Procedures and Tables for Inspection by
Attributes (ANSI 1993); or

Certificate of compliance of cleanliness from an Approved Subcontractor
on the Evaluated Subcontractors List.

Sample containers should be purchased pre-cleaned in accordance with
either SW-846 (EPA 1996) or Specifications and Guidance for Obtaining
Contaminate-Free Sample Containers (EPA 1992).  If sampling containers
are not purchased pre-cleaned, they are cleaned in accordance with
either SW-846 (EPA 1996) or the Specifications and Guidance for
Obtaining Contaminate-Free Sample Containers (EPA 1992).

B1-2c	Equipment Testing, Inspection, and Maintenance

Prior to initiation of activities, sampling tools and equipment are
tested and maintained 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.  Sampling
tools found to be malfunctioning are repaired or replaced prior to use. 
Clean sampling tools and equipment are sealed inside protective wrapping
and maintained in a clean storage area prior to use.  Records of
equipment maintenance and repair are maintained in the field databank.

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

Sample collection equipment in the immediate area of sample collection
are inspected prior to performing sampling 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 sampling work areas are maintained in a clean condition to minimize
cross contamination between samples.

Expendable equipment (e.g., plastic sheeting, sample pans, aluminum
foil, plastic gloves) are visually inspected for cleanliness prior to
use and properly discarded after use, or after each sample is completed,
whichever is most appropriate.

Prior to removal of the protective wrapping from sampling equipment or
sampling tools designated for use, the condition of the protective
wrapping is visually assessed.  Any torn or damaged packages must be
returned for cleaning.  Sampling equipment or tools visibly contaminated
after the packaging material has been removed are not used and instead
are returned for cleaning or are properly discarded.

Sampling equipment or tools (e.g., liner, bowls, spoons, etc.) are
visually inspected prior to use.  All sampling equipment or tools that
comes into contact with waste samples must be stored in a protective
wrapping until use.  Protective wrappings are visually assessed prior to
removal.  Sampling equipment or tools with torn packaging material are
discarded or are returned for cleaning.

Cleaned sampling equipment is 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 sub-samples are calibrated as necessary to
maintain its operation within manufacture's specifications, and after
repairs and routine maintenance.  Weights used for calibrations are
traceable to a nationally recognized standard and calibrated in
accordance with 4-9500-MLP-12001, Check Weight Calibration.  Calibration
records are maintained by the RFETS Metrology Organization.

B1-3	Radiography

Real-Time Radiography (RTR) is a technique that involves X-ray scanning
of waste containers to identify and verify waste container contents. 
This includes the following activities:

Verify Waste Matrix Code (matrix parameter categories); 

Estimate waste material parameter weights; and 

Verify the waste stream description. 

The descriptions below outline the basic functions for RTR and visual
examination (VE) that are discussed within this section.   See Sections
B-3c, B3-4 and B3-10 of this document for additional controls and
information.

RTR and/or VE are used to examine every TWCP waste container to confirm
that the physical form of the waste matches its waste stream
description. 

TWCP waste containers whose packaging configuration or contents prevent
full RTR examination of the remaining contents are subjected to VV
unless RFETS certifies that VV would provide no additional relevant
information for that container.

RTR system requirements are implemented through procedures
4-I19-NDT-00569, Real Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569; 4-W30-NDT-00664, Real Time Radiography
Testing of Transuranic and Low-Level Waste in Building 664;
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste; and 5-NDT-TC-1A, Training, Qualification and
Certification of Nondestructive Testing Personnel. 

To confirm RTR results, VE is performed on a portion of the waste
containers in accordance with PRO-1358-440-VERP, Glovebox and C-Cell
Waste Operations; PRO-1471-VE-771, Visual Examination for Confirmation
of RTR; PRO-1608-VECRTR-371, RTR Visual Examination Confirmation,
Building 371; or 4-H80-776-ASRF-007, Visual Examination for Confirmation
of RTR.

B1-3a	Methods Requirements

RTR is used to verify that the AK-assignment of a waste container to a
particular waste stream is correct; to estimate the container’s waste
material parameter weights; and to confirm, for those parameters which
can be assessed visually, that a waste container has no prohibited
items.  The physical form of the waste (waste material parameter) is
included in Table B3-1.  The RTR data are collected by trained and
qualified RTR operators, and the scan of the waste container is
recorded, including the estimated waste material parameter weights and
confirmation of the Waste Matrix Code, using an audio/videotape and RTR
data forms.  The audio/videotape and data forms are maintained as WIPP
records.

B1-3a	Methods Requirements  (continued)

RTR operating procedures provide facility specific instrument and
personnel requirements and instructions to perform the RTR analysis and
to achieve RTR objectives defined in the QAPjP.  RTR has been developed
specifically to aid in the examination and identification of
containerized waste.  The RTR system incorporates controls or equivalent
processes that allow the RTR operator to vary the voltage, thereby
controlling image quality and to provide an optimum degree of
penetration through the waste.  The RTR system incorporates provisions
for the waste container to be scanned while the RTR operator views the
image on a TV screen.  An audio/videotape is made of the scan of the
waste container, and the audio/videotape is maintained as a
non-permanent WIPP record.  The RTR system consists of:

An x-ray producing device

Imaging system (fluorescent screen & low-light TV camera)

Enclosure for radiation protection 

Waste container handling system

An audio/videotape recording system

Operator control and data acquisition station

An inventory sorted by waste material parameter for waste items,
residual materials, and packaging materials has been compiled into
look-up tables, including standard weight tables.  The tables, which are
used for estimating and sorting the inventory of waste material
parameters weights, are maintained in RTR procedures 4-W30-NDT-00664,
Real-Time Radiography Testing of Transuranic and Low-Level Waste in
Building 664; 4-I19-NDT-00569, Real Time Radiography Testing of
Transuranic and Low-Level Waste in Building 569; and
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste.

TWCP waste containers whose packaging configuration or contents prevent
full RTR examination of the remaining contents are subjected to VV
unless RFETS certifies that VV would provide no additional relevant
information for that container.  If RTR indicates that the waste does
not match the waste stream description and/or a prohibited nonconforming
item is discovered in the waste container, a waste nonconformance report
(WNCR) is initiated in accordance with procedure PRO-U76-WC-4030,
Control of Waste Nonconformances.

For containers which contain classified shapes and undergo radiography,
the radiography tape is considered classified.  The radiography data
forms are reviewed for classification to ensure they do not contain
classified information.

B1-3b	Quality Control

Operator training and experience are the most important considerations
for assuring quality controls in regard to the operation of the RTR
system and for interpretation and disposition of RTR results.  Only
trained and qualified personnel are allowed to operate RTR equipment. 
The site-specific position/title for RTR operator is Nondestructive
Testing (NDT) Technician.

Standardized training and qualification requirements for RTR operators
are based upon existing industry standard training requirements and
comply with the training and qualification requirements of the WIPP-WAP;
the TWCP TIP; and 5-NDT-TC-1A, Training, Qualification and Certification
of Nondestructive Testing Personnel.

Qualification of RTR operators encompasses the following:

Pass a comprehensive exam that addresses all of the RTR operations,
documentation, characterization and procedural elements stipulated in
the WAP.

Successful completion of practical capability demonstration in the
presence of an experienced, OJT qualified operator, the RFETS RTR
subject matter expert (SME).  The RFETS RTR SME is a certified Level III
NDT Technician and a certified OJT Trainer.

Requalification of RTR operators is based upon evidence of continued
satisfactory performance (primarily audio/videotape reviews) and is
accomplished at least every two years.  Unsatisfactory RTR operator
performance results in disqualification.  Retraining and demonstration
of satisfactory performance are required before a disqualified RTR
operator is allowed to resume the operation of the RTR system.

RFETS ensures proper training and experience with both formal and
on-the-job (OJT) training.  RTR operators are trained in specific waste
generating practices.  Typical packaging configurations expected for
each Waste Matrix Code that are representative of the waste stream are
used for training and qualification of RTR operators.  The OJT training
is performed by an experienced, OJT qualified RTR operator prior to
qualification of the trainee.  Results of RTR operator qualifications
are documented by the RTR SME in the individual’s Site Training Record
as well as in the TWCP record files. 

The elements of the RTR training program include formal and OJT, as
presented below.  Training courses that provide these elements are
listed in 5-NDT-TC-1A, Training, Qualification and Certification of
Nondestructive Testing Personnel.  The completion of OJT through
operator qualification and scans of test drums is also detailed in
5-NDT-TC-1A, Training, Qualification and Certification of Nondestructive
Testing Personnel.

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

RTR operators are instructed in the specific waste generating practices,
typical packaging configurations, and the associated waste material
parameters that are expected to be found in each Waste Matrix Code.  In
addition, RTR operators are trained on the types of waste that are
generated, stored, and/or characterized at RFETS.

The RTR training program for TWCP is site-specific.  Training
requirements for RTR operators are specified in the TWCP TIP and
5-NDT-TC-1A, Training, Qualification and Certification of Nondestructive
Testing Personnel.  These procedures incorporate controls and
requirements for operators to be trained on the types of waste streams
that are generated, stored and/or characterized for TWCP.  Additional
controls for training and qualification are contained in procedures
4-W30-NDT-00664, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 664; 4-I19-NDT-00569, Real Time Radiography
Testing of Transuranic and Low-Level Waste in Building 569; and
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste.  RTR operating and training procedures listed above
incorporate the RTR QC requirements specified in the WAP.

B1-3b(2)	On-the-Job Training  (continued)

Test drum(s) representative of the Waste Matrix Codes for the WSPF are
examined and successfully identified as part of the RTR operator
qualification process on a biannual basis by each RTR operator.  The
test drums contain varied container sizes, which are filled with items
representing the applicable waste matrix codes, including the required
items.  The test drums are divided into layers with varying packing
densities that are representative of the waste streams.  The test drums
are scanned by each RTR operator, and the resulting audio/videotapes are
reviewed by the RTR SME to ensure that operators’ interpretations
remain consistent and accurate.  Test drum(s) and use of test drum scans
in the qualification of RTR operators are addressed in 5-NDT-TC-1A,
Training, Qualification and Certification of Nondestructive Testing
Personnel.

Requalification of RTR operators is based upon evidence of continued
satisfactory performance and is accomplished at least every two years. 
This involves qualitative and semi-quantitative evaluations of visual
displays.  Unsatisfactory performance results in RTR operator
disqualification.  For the RTR operator, unsatisfactory performance is
defined as misidentification of a prohibited item in a training drum or
a score of less than 80% on the comprehensive exam.  For an RTR operator
who is disqualified, retraining and demonstration of satisfactory
performance is required before the operator is again allowed to operate
the RTR system.  Refer to 5-NDT-TC-1A, Training, Qualification and
Certification of Nondestructive Testing Personnel for the specific
controls for qualification and requalification of RTR operators.

Test drums containing items common to the waste stream and the following
items, are used to train and qualify RTR operators.  Successful
identification of these items by the RTR operator is part of the
qualification process:

A punctured aerosol can

Pigtails on ploy 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

B1-3b(2)	On-the-Job Training  (continued)

Independent replicate scans and replicate observations of the
audio/videotape output of RTR are performed under uniform conditions in
accordance with RTR procedures 4-W30-NDT-00664, Real-Time Radiography
Testing of Transuranic and Low-Level Waste in Building 664;
4-I19-NDT-00569, Real Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569; and PRO-1520-Mobile-RTR, Mobile
Real-Time Radiography Testing of Transuranic and Low-Level Waste.  A
testing batch consists of a maximum of 20 waste containers.  Independent
replicate scans are performed on one waste container per testing batch.
A minimum of one independent observation (other than the independent
replicate scan) is made once per testing batch by a qualified RTR
operator other than the individual who performed the first exam.  The
results of this verification are available to the RTR operator.

RTR oversight functions are accomplished by qualified RTR personnel
other than the operator who dispositioned the waste container.  This
includes periodic audio/videotape reviews of accepted waste containers. 
These periodic reviews are performed by qualified RTR personnel other
than the operator who accepted the original container.  The results of
this independent verification are available to the RTR operator.  The
TWCP Site PQAO is responsible for monitoring the quality of the RTR data
and calling for corrective action, when necessary.

B1-3b(2)(i)	System Testing, Inspection, and Maintenance Requirements

All equipment used during RTR is tested, inspected, and maintained in
accordance with site-specific procedures.  RTR operating procedures
4-W30-NDT-00664, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 664; 4-I19-NDT-00569, Real Time Radiography
Testing of Transuranic and Low-Level Waste in Building 5691; and
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste, document the specific requirements for equipment
testing and inspection.

B1-3b(2)(ii)	System Verification and Frequency

Imaging system characteristics are verified through the use of an RTR
test pattern performed at the beginning and end of each work shift when
the RTR system is operating.  A test pattern is installed and observed
to ensure that the RTR system has adequate video quality.  The pedestal
and contrast controls are adjusted to obtain optimum contrast on the
screen.  Lines of resolution required are specified in the
building-specific RTR operating procedure.

B1-3b(3)	Visual Examination (to Confirm RTR)

As an additional QC check, or in lieu of radiography, the RTR results of
the waste container contents are confirmed directly by performing VE on
a statistically determined subpopulation of waste containers (refer to
Figure B1-6, Overall Programmatic Approach to Visual Examination of the
Waste).  This confirmation includes the Waste Matrix Code and waste
material parameter weights in accordance with PRO-1358-440-VERP,
Glovebox and C-Cell Waste Operations; PRO-1471-VE-771, Visual
Examination for Confirmation of RTR; PRO-1608-VECRTR-371, RTR Visual
Examination Confirmation, Building 371; or 4-H80-776-ASRF-007, Visual
Examination for Confirmation of RTR.  The confirmation is performed
through a comparison of RTR and VE 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.
 With the exception of items or conditions that could pose a hazard to
visual examination personnel, the RTR results are not made available
until after VE is complete.    The VE results are validated at the
project level in accordance with PRO-940-WIPP-010, WIPP TRU Waste
Characterization Project Level Data Review and Reporting, and the VE
results are transmitted to the radiography facility.

The number of waste containers randomly selected for VE for the
confirmation of RTR is based on the miscertification observed in waste
containers visually inspected over a 12-month period.  A new
miscertification rate is determined each year and this rate is used to
calculate the number of waste containers randomly selected for VE in the
upcoming 12-month period.  The selection of waste containers for VE for
the confirmation of RTR is conducted in accordance with Section B2-1,
Approach for Statistically Selecting Waste Containers for Visual
Examination. 

The Visual Examination Expert (VEE) is only required for the VE that is
used in lieu of radiography, or to confirm RTR results of waste
container contents.  The VEE’s decision-making process is based on
training and expertise.  The TWCP Site PM designates the VEE based on
qualifications, training, and RFETS process and acceptable knowledge. 
The designated VEE personnel meet the qualification and training
requirements for the Visual Examination position, Technical Support
(refer to the TWCP TIP, Appendix 1, TWCP Project Training Matrix). 
Alternates may be designated by the TWCP Site PM, pursuant to
PRO-1358-440-VERP, Glovebox and C-Cell Waste Operations, or
4-H80-776-ASRF-007, Visual Examination for Confirmation of RTR3, Section
3, and alternates must also meet the qualification and training
requirements for the VEE position, Visual Examination – Technical
Support.

If the identification of waste items, residual materials, packaging
materials, and/or physical form of waste (waste material parameter)
cannot be ascertained through the unopened bag/package, the VEE will
make the decision as to whether the inner bags will or will not be
opened.  VEE decisions are documented on the VE data forms.  The VEE
will recommend a change if materials found in the waste packages are
different than provided by the TRUCON code.  Inner bags/packages that
require opening are examined and their contents are sorted and recorded.
 An inventory of loose waste items, residual materials, packaging
materials, and/or physical form of waste (waste material parameter) not
contained in inner bags/packages are recorded, and the waste is sorted
and weighed.  If liquids are encountered at any time during the VE, a
description of the waste location, the packaging, and the estimated
liquid volume is recorded.  Changes and nonconforming items will be
documented using procedure PRO-U76-WC-4030, Control of Waste
Nonconformances.

B1-3b(3)	Visual Examination  (to Confirm RTR) (continued)

The VE for the confirmation of RTR is conducted on a subpopulation of
waste containers to describe all contents of the waste container and to
include either estimated or measured weights of the contents.  The
description clearly identifies all discernible waste items, residual
materials, packaging materials, or waste material parameters.  VEEs, who
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 acceptable knowledge is used to identify the waste matrix
code and estimated waste material parameter weights.  If acceptable
knowledge 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.  In addition, VE (to Confirm RTR) results are documented on
audio/videotape (refer to PRO-1358-440-VERP, Glovebox and C-Cell Waste
Operations; PRO-1471-VE-771, Visual Examination for Confirmation of
RTR); PRO-1608-VECRTR-371, RTR Visual Examination Confirmation, Building
371; or 4-H80-776-ASRF-007, Visual Examination for Confirmation of RTR.

Visual examination video tapes of containers which contain classified
shapes are considered classified information.  VE data forms are
reviewed for classification to ensure they do not contain classified
information.

VE consist of a semi-quantitative and/or qualitative evaluation of the
waste container contents and is recorded on audio/videotape.  The
specific requirements of VE are described in this document and in the
referenced procedures.  There is no equivalent VE method found in EPA
sampling and analysis guidance documents.

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 RFETS.  The OJT and apprenticeship are
conducted by an operator experienced and qualified in VE prior to
qualification of the candidate.  An SME, Supervisor, or VEE, all
qualified operators and experienced in VE, perform this training
function. 

The elements of the VE training program include formal and OJT, as
presented below.  VE training is site-specific and includes the various
waste configurations generated/stored at RFETS.  This training program
is specified in the TWCP TIP; PRO-1358-440-VERP, Glovebox and C-Cell
Waste Operations; PRO-1471-VE-771, Visual Examination for Confirmation
of RTR1; PRO-1608-VECRTR-371, RTR Visual Examination Confirmation,
Building 3712; and 4-H80-776-ASRF-007, Visual Examination for
Confirmation of RTR.3  Together these documents identify the selection,
training, and qualification requirements for the VE personnel and the
VEE.  Visual examination personnel are requalified once every two years.
 The RFETS training program contains the following required elements:

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 TWCP Site PM designates the VEE based on qualifications, training,
and RFETS process and acceptable knowledge.  The VEE is responsible for
the overall direction and implementation of the VE examination.  VE
qualification through completion of a formal qualification document
incorporates both the formal and on-the-job training elements as listed
above (refer to the TWCP TIP, Appendix 1, TWCP Training Matrix).  
Overall, the VE training and qualification program is used to assess
operator performance before actual waste characterization by VE.  With
the exception of items or conditions that could pose a hazard to VE
personnel, the audio/videotape results of the RTR evaluation of the
container shall not be available until after VE is completed.

For newly generated waste and when repackaging retrievably stored waste,
the formal and OJT training requirements for the visual verification
personnel are incorporated into a formal qualification process that is
specific for the waste generation and packaging activity.  The
qualification documents identify completed formal training on general
and site-specific training requirements for visual verification, and
also credits classroom training on the visual verification process in
activity-specific operating procedures (refer to the TWCP TIP, Appendix
1, TWCP Project Training Matrix, and Appendix 2, Residues Program).  The
qualification documents also provide documentation for OJT and
performance demonstration activities that meet the OJT requirements. 

A description of the waste container contents is recorded on a Visual
Examination Drum Log.  The description clearly identifies the Waste
Matrix Code listed in the Waste Isolation Pilot Plant Transuranic Waste
Baseline Inventory Report (DOE 1995b) and DOE Waste Treatability Group
Guidance (DOE 1995a).  In cases where bags are not opened, a brief
written description of the contents of the bags must contain an estimate
of the amount of each constituent in the bags.  The written records of
VE, when using VE for confirmation of RTR or when using VE in lieu of
RTR, must be supplemented with the audio/videotape recording.

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
L-4006, Chain-of-Custody and Sample Administration for Headspace Gas
Sample Canisters; and PRO-543-ASD-002, Initiation, Preparation, and
Implementation of Chain-of-Custody Forms for solid samples).  Sample
custody is maintained by ensuring that samples are custody sealed during
transfer to the laboratory.  After samples are accepted by the
laboratory, custody is maintained by ensuring the samples are:

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 TWCP
Site PM or until the sample is expended.

Custody of RFETS wastes samples collected and/or analyzed at INEEL is
described in the Attachment to the SOW for the INEEL TWCP (DOE 2003a). 
Samples from RFETS waste are retained until INEEL is notitifed by the
RFETS TWCP Site PM, or the sample is expended.

Sampling personnel record all information pertinent to the collection of
samples on appropriate documentation.  This documentation includes
sample logbooks, data sheets, etc.  All information is legible and
contains only facts and observations (including modifications to planned
sampling activities). Records are dated and signed by the individual who
made the entry.  The key to producing legally admissible and defensible
data is effective COC procedures and the absolute requirement that no
movement of an analytical sample is permitted without custody control.

Section B1-4a, below, presents details on the documentation associated
with the collection of gas samples and the Gas Canister COC.  Prior to
October 22, 2002 headspace gas samples were collected using both SUMMA(
or equivalent canisters and on-line integrated sampling/analysis
systems.  Following this date, all headspace gas sampling and analysis
is conducted at RFETS utilizing on-line integrated systems.  Samples are
not transported to another location when using on-line integrated
sampling/analysis systems; therefore, the sample custody requirements of
this Section do not apply.  COC information relative to headspace
sampling with SUMMA( canisters is included for historical traceability.

Section B1-4b presents details on the documentation associated with the
collection of solid and soil/gravel samples and the associated COC. 
Section B1-4c presents details on the field documentation that is
recorded at the time of sampling.

B1-4a	Gas Samples 

Gas samples are collected in accordance with Section B1-1 of this
document.

Laboratory procedure L-4146, Headspace Gas Sampling of Waste Containers,
describes how sampling conditions and sample canister conditions are
documented.  L-4006, Chain-of-Custody and Sample Administration for
Headspace Gas Sample Canisters1, describes how COC for sample canisters
is maintained and documented.

B1-4a(1)	Sequence of Activities for Gas Canisters, COC form, and Other
Sample Documents

B1-4a(1)(i)	COC  -  Immediately after sample canister cleaning

Immediately after sample canister cleaning (i.e., prior to next sampling
event), the following activities occur:

A Headspace Sample Canister COC (refer to Figure B1-1) accompanies the
“certified clean” sample canister.

The Headspace Sample Canister COC includes provisions for each of the
following:

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

	Documentation of sample numbers for each sample under custody.  The
sample number is referenced to a specific sampling event description
that identifies the sampler(s) through signature, the date and time of
sample collection, type/number of containers for each sample, sample
matrix, preservatives (if applicable), requested method of analysis,
place/address of sample collection and the waste container number.  The
Laboratory Sample Identification Number is a unique 7-digit number as
described in Section B1-4a(6)).

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

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

	Comment section.

	Documentation of discrepancies, breakage, or tampering.

B1-4a(1)(i)	COC  -  Immediately after sample canister cleaning 
(continued)

The Sample Canister Information Document (refer to Figure B1-2 for an
example) is initiated and accompanies the “certified clean” sample
canister.  The “certified clean” canister pressure is recorded, and
the final pressure is recorded for the manifold gauge and the canister
gauge.

The Sample Canister Information Document (SCID) includes provisions for
each of the following:

	Canister Identification Number (the Canister Identification Number is a
four-digit number as described in Section B1-4a(5).

	Sampler name and signature.

	Ambient temperature and pressure.

	Sample description.

	Requested analysis.

Date and time of collection.

A Sample Canister Tag (refer to Figure B1-3 for an example) with a
unique Laboratory Sample Identification Number is attached to the
“certified clean” sample canister.  The Sample Canister Tag is
removable.

The Sample Canister Tag contains the following information:

Each Sample Canister Tag has a unique seven-digit Laboratory Sample
Identification Number as described in Section B1-4a(6).  The Sample
Canister Tag Number and the Laboratory Sample Identification Number are
the same numbers.  The Laboratory Sample Identification Number is
located on one side of the tag.

Canister Identification Number (the Canister Identification Number is a
four-digit number as described in Section B1-4a(5).  The Canister
Identification Number, and the remaining information listed below, is
listed on the other side of the tag.

Sampler initials and organization.

Ambient temperature and pressure.

Sample description.

Requested analysis.

Date and time of collection.

QC designation (if applicable).

Name and signature of the individual applying the custody seal.

B1-4a(1)(ii)	COC  -  At the time of sampling

At the time of sampling, the following activities occur (laboratory
personnel collect the headspace gas samples; and therefore the headspace
gas samples are in the receipt of the laboratories at the time of sample
collection):

A custody seal is applied to the sample canister in accordance with
L-4006, Chain-of-Custody and Sample Administration for Headspace Gas
Sample Canisters.

A Headspace Sample Canister COC form is appropriately completed for each
sample. The Headspace Sample Canister COC form demonstrates sample
control from the time of sampling through sample disposal and also
documents sample integrity.

It is verified that a Sample Canister Tag (with Laboratory Sample
Identification Number) is attached to each sample canister (including QC
sample).

The following information is recorded in a bound sampling logbook:

	Sampling date

Sampling time

Container number

WIPP tag number

Canister number

Sample type

Volume removed

Batch number

RF number of pressure gauge, vacuum gauge, temperature sensor

PID span reading

	Comments (as necessary)

B1-4a(1)(iii)	COC  -  Immediately after sampling

Immediately after sampling, the following activities occur:

Sample canisters are externally smeared by Radiation Control Technicians
(RCTs);

In-line filters on sampling manifolds are utilized to survey the gross
alpha internal contents of the sample canisters; and

The COC and the Sample Canister Tag accompany the sample canister during
movement from the sampling area to the laboratory for analysis.

B1-4a(2)	COC Practices

Sample COC practices are carried out in accordance with the requirements
of the WIPP-WAP, and sample custody is maintained as described in
Section B1-4 (refer to L-4006, Chain-of-Custody and Sample
Administration for Headspace Gas Sample Canisters).

A Headspace Gas Sample Canister COC (refer to Figure B1-1 for an
example) is used to track the sample canister throughout the entire
process from cleaning through sampling, analysis, temporary storage, and
release to cleaning.  Whenever a transfer of custody takes place, the
receiving party (i.e., the party that is accepting sample custody)
inspects the COC, the SCID, the Sample Canister Tag, and all
accompanying documentation to ensure that the information is accurate
and complete.  The receiving party also inspects the samples for signs
of damage or tampering.  Any discrepancies in information or signs of
sample damage or tampering are documented by the receiving party in the
Comment Section of the COC.  When sample custody transfer takes place,
both the relinquishing and receiving parties sign and date the COC
document, and at that time the receiving party becomes the sample
custodian.

The Project Sample Coordinator ensures that all samples received by
sample receiving personnel are submitted with properly completed COCs. 
The Analytical Laboratories management ensures that proper COC for each
sample is maintained at the laboratory, and that all laboratory
personnel responsible for COC are trained and understand their
responsibilities for COC (refer to L-4006, Chain-of-Custody and Sample
Administration for Headspace Gas Sample Canisters).

Completed samples are relinquished to sample receiving personnel for
temporary storage.  After sample analysis is complete, the original COC,
reduced and raw data, and other accompanying sample documentation are
submitted to records in accordance with L-4026, Records Handling,
Storage, and Retrieval for the WIPP Project File.  Project level support
personnel utilize this reduced and raw data for preliminary and final
report data packages.

After Batch Data Report verification and approval by the TWCP Site PQAO
and the TWCP Site PM are completed, corresponding sample canisters are
submitted to the canister cleaning laboratory.  Prior to canister
cleaning, Canister Sample Tags are removed from completed samples by the
Project Sample Coordinator for submittal to records in accordance with
L-4026, Records Handling, Storage, and Retrieval for the WIPP Project
File3.

B1-4a(3)	Headspace Sample Size, and Sample Canister Holding Temperatures
and Storage Conditions

The holding temperature of canisters containing samples is 0° to 40°C.
 All storage areas that have temperature requirements are monitored by a
calibrated temperature monitoring and recording device.

Minimum volumes for headspace gas samples are presented in Table B1-1.

B1-4a(4)	WIPP Sample Identification Number

Each sample is assigned a unique 14-digit WIPP Sample Identification
Number with the following format:

ZZ	MMDDYY	RX A ZZZ

(Sample Site ID)	(Date)	(Canister ID)

ZZ is the two-digit alpha character designating the sample site (RF for
Rocky Flats), and MMDDYY are the numeric characters indicating the
sampling data (month-day-year).  The characters “RX” designate the
analysis area within the laboratory performing sample analysis, and the
character “A” designates the canister volume.  The characters
“ZZZ” characters are the last three numerical digits of the canister
identification.

B1-4a(5)	Canister Identification Number

L-4006, Chain-of-Custody and Sample Administration for Headspace Gas
Sample Canisters1, documents canister identification requirements.  Each
canister is inscribed with the site identification “Rocky Flats Plant
Mass Spectrometry Lab” and a four-digit canister identification number
consisting of one alpha and three numeric characters, in the form LZZZ. 
The alpha character represents the volume of the canister, as shown
below, and the three numeric numbers establish the serial number.

The Canister Identification Number is in the following format:

L	ZZZ

(Volume)	(Sequential Number:

	001 through 099)

A	=	100 ml

B	=	250 ml

C	=	500 ml

D	=	2.8 liter

E	=	6.0 liter

B1-4a(6)	Laboratory Sample Identification Number

Each sample is assigned a unique seven-digit Laboratory Sample
Identification Number with the following format:

YY	A	1XXX

(Year)	(Project Designation)	(Sequential

		Number)

YY is the two-digit numeric character designating the sample
identification number assignment year.  “A” is the alpha character
designating the project code (W for WIPP).  1XXX is numeric characters
that represent a unique sequential sample number.  The Sample Canister
Tag Number (i.e., the number on one side of the Sample Canister Tag) and
the Laboratory Sample Identification Number are the same number.

Section B1-4a(7), Field QC Record Form – Headspace Gas Sample, has
been deleted.

B1-4b	Homogeneous Solids and Soil/Gravel Sample Container 

Samples of homogeneous solids and soil/gravel are collected by trained
personnel, who follow standard operating procedures.  All activities
related to the sampling and analysis events are recorded on documents
such as sampling request forms, sample labels, and COC forms.  The
Analytical Laboratories procedure L-4028, Sample Administration for the
Radiological Laboratories, describes the administrative tasks for
control of laboratory samples collected and analyzed at RFETS.  

B1-4b(1)	Chain-of-Custody

Procedure PRO-543-ASD-002, Initiation and Preparation of
Chain-of-Custody Forms, provides information used to initiate
chain-of-custody for samples of homogeneous solids and soil/gravel. 
Figure B1-4 provides an example of this COC form.

A signed and dated custody seal is affixed to each sample container and
installed across the container lid and body to provide visual evidence
of tampering.  An example custody seal is provided in Figure B1-5. 
Tamper-indicating devices (TIDs) may be used on sample containers
instead of applying a signed and dated custody seal across the container
lid (i.e., TIDs and custody seals both provide visual indication of
sample custody).  The signature and date documenting sample custody is
recorded on the COC.  SOPs outline the flow of information between
parties responsible for sample acquisition, sample transfer, sample
analysis, data validation, data storage, data evaluation, and data use.

Participating laboratories have a documented sample custody program that
includes procedures for sample receiving and log-in, sample storage and
numbering, sample tracking in the laboratory, and storage of laboratory
data.  Refer to Section B1-2 and/or the project specific sampling and
analysis plans for detailed descriptions and procedures.

A COC accompanies each homogeneous solids and soil/gravel sample (refer
to Figure B1-4 for the COC).  The COCs used for RFETS sampling
activities are referenced in applicable project procedures and plans. 
Sample custody is initiated at the time of sampling, and is maintained
until the sample is released by the TWCP Site PM or until the sample is
expended.

When sample custody transfer takes place, both the relinquishing and
receiving parties sign and date the COC document.  The party accepting
sample custody inspects the COC documents, sample tags, sample canister
information documents, and any other accompanying documentation to
ensure that the information is accurate and complete.  Discrepancies in
information or signs of damage “and tampering” to sample containers
shall be documented by the receiving custodian in the Comment section of
the COC document.  Original COC and sample information documents are
maintained in the RFETS project files after sample analysis is
completed.

B1-4b(2)	Handling

Handling requirements for samples of homogeneous solids and soil/gravel
conform to the requirements specified in Table B1-4 for sample quantity,
container, preservation, and holding time.  The sample quantities
provided are the suggested minimum amounts that must be collected for
each parameter per sample.  Additional sample quantities are collected
for QC samples.  The sample preservation requirement, “cool to 4°C”
means that the samples are placed in an insulated container and packed
with frozen chemical ice.  Sufficient ice is used to ensure the samples
remain cool until analyzed or stored in a refrigerated unit. 
Temperature records of the sample are not required. 

B1-4b(3)	Homogeneous Solids and Soil/Gravel Sample Containers

A twelve-digit sample identification number is assigned to each sample
of homogeneous solids and soil/gravel collected.  The sample
identification number has the following format:  12 alpha-numeric
characters; two alpha characters to designate the sampling site (RF),
and the remaining ten characters are unique to each homogeneous solids
and soil/gravel sample collection.  A sample label is affixed to each
individual sample of homogeneous solids and soil/gravel collected (refer
to Section B-4a(3) for a summarization of sample control).  The
following information is recorded in permanent ink on each COC:

Signature of individual initiating custody control, along with date and
time

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

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

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

Comment section.

Documentation of discrepancies, breakage, or tampering.

Sample quantities and container volumes included in Table B1-4 are
suggested only, and are not required.  Sample quantities and containers
that meet analytical sample and QC requirements are stated in applicable
project procedures and plans.

All samples and reusable sampling equipment are identified with unique
identification numbers.  Sampling tools and equipment are identified
with unique equipment numbers to ensure all sampling equipment are
traceable to equipment cleaning batches.

Samples are uniquely identified to ensure the integrity of the sample. 
The sample tag can be used to identify the generator site and the date
of collection.  Sample tags are affixed to all samples and identify at a
minimum:

Sample ID number

Sampler initials and organization

Sample description

Requested analyses

Date and time of collection

QC designation (if applicable)

B1-5	Sample Packing and Shipping

On-Site sample-transfer activities conducted at RFETS are performed in
accordance with PRO-908-ASD-004, On-Site Transfer and Off-Site Shipment
of Samples and/or MAN-T91-STSM-001, Site Transportation Safety Manual
(STSM).  Sample containers are packaged and shipped in accordance with
the requirements of PRO-908-ASD-004, On-Site Transfer and Off-Site
Shipment of Samples and the STSM to meet DOT regulations.  Sample
packages contain cushioning compatible to the package to prevent
shifting of and damage to sample containers during transport.  Off-site
shipping packages contain trip blank samples to detect any VOC cross
contamination.  Sufficient Blue Ice packs, or equivalent, are added to
the shipping container to maintain preservation temperature through
laboratory receipt.

Sample custody documentation, with the signature of the current
custodian showing sample custody release, shall be placed inside the
transfer container.  A seal shall then be placed on the outside of the
transfer container, or the transfer container shall be locked, so that
the integrity of the custody of the sample inside the transfer container
is evident.  Transfer of sample custody is complete when the receiving
custodian opens the transfer container and signs the sample custody
documentation.

RFETS waste analyzed at INEEL may or may not be sampled at INEEL. 
Individual waste containers to be sampled are selected according to
Section B2-2.  Sample packaging and shipping is performed in accordance
with PRO-908-ASD-004, On-Site Transfer and Off-Site Shipment of Samples.
 Sample reciept at INEEL is conducted as described in the Attachment to
the SOW for the INEEL TWCP (DOE 2003a).



Table B1-1, Headspace Gas: SUMMA® Canisters, Canister Volumes and
Holding Temperatures

PARAMETER	HEADSPACE SAMPLE MINIMUM VOLUME (ML)	

HOLDING TEMPERATURE

Hydrogen and Methane	100	0-40 o C

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, other than SUMMA® 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

Field Duplicates

Or

On-Line Duplicates	1 per sampling batchd	1 per sampling batchd	1 per
on-line batchf



a	Analysis of field blanks and equipment blanks for VOCs (Table B3-2),
only, is 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 using an OVA.  Analysis of an on-line equipment blank is
required only if the field blank fails to meet the QAOs specified in
Table B1-3.

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.

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 PRESERVATIVEb	

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

Metals	10 grams	Cool to 4 o C	Plastic Jarg	180 Daysh



a	Quantity may be increased or decreased according to the requirements
of the analytical laboratory, as long as the QAOs are met.

b	“Cool to 4 o C” means that the samples are placed in an insulated
cooler and packed with frozen chemical ice. 

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.g., septum 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	Polyethylene or polypropylene is preferred, glass jar is allowable.

h	Holding time for mercury analysis is 28 days.

Note:  Preservation requirements in the most recent version of SW-846
may be used if appropriate.



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.



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.



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 1.9x10-6 filter H2 diffusivity, a filter of known H2 diffusivity
that is greater than or equal to 1.9x10-6 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
inches must use a DAC for a rigid liner vent hole of 0.375 inch).  If
the rigid liner vent hole diameter for a container is undocumented
during packaging (Section B-3d(1)), repackaging (Section B-3d(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 inch.

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.



TABLE B1-8, SCENARIO 3 PACKAGING CONFIGURATION GROUPS

Packaging Configuration Group	Covered S3000/S4000 Packaging
Configuration Groups	Covered S5000 Packaging ConfigurationGroups

Packaging Configuration Group 1, 55-gallon 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-gallon 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)





TABLE B1-8, SCENARIO 3 PACKAGING CONFIGURATION GROUPS (continued)

Packaging Configuration Group	Covered S3000/S4000 Packaging
Configuration Groups	Covered S5000 Packaging ConfigurationGroups

Packaging Configuration Group 3, 55-gallon drums a	1 inner bag, 1 liner
bag

1 filtered inner bag, 1 filtered liner bag

2 inner bags

2 filtered inner bags

2 liner bags (bounding case)

2 filtered liner bags	2 liner bags

2 filtered liner bags

1 inner bag, 2 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)





TABLE B1-8, SCENARIO 3 PACKAGING CONFIGURATION GROUPS (continued)

Packaging Configuration Group	Covered S3000/S4000 Packaging
Configuration Groups	Covered S5000 Packaging ConfigurationGroups

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)

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



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

1.9x10-6	131	95	37	24	4	4

3.7x10-6	111	85	36	24	4	4

3.7x10-5	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

1.9x10-6	175	138	75	60	30	11

3.7x10-6	152	126	73	59	30	11

3.7x10-5	58	57	52	47	28	8



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

1.9x10-6	199	161	96	80	46	16

3.7x10-6	175	148	93	79	46	16

3.7x10-5	72	72	67	62	42	10





TABLE B1-9, SCENARIO 3 DRUM AGE CRITERIA (in days) MATRIX FOR S5000
WASTE BY PACKAGING CONFIGURATION GROUP (continued)

Packaging Configuration Group 4

Filter H2 Diffusivity a (mol/s/mol fraction)	Headspace Sample Taken
Inside Pipe component

> 1.9x10-6	152



Packaging Configuration Group 5

Filter H2 Diffusivity a, c (mol/s/mol fraction)	Headspace Sample Taken
Inside SWB

> 7.4x10-6	15



Packaging Configuration Group 6

Filter H2 Diffusivity a, c (mol/s/mol fraction)	Headspace Sample Taken
Inside SWB

> 7.4x10-6	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 1.9x10-6 filter H2 diffusivity, a filter of known H2 diffusivity
that is greater than or equal to 1.9x10-6 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
inches must use a DAC for a rigid liner vent hole of 0.375 inch).  If
the rigid liner vent hole diameter for a container is undocumented
during packaging (Section B-3d(1)), repackaging (Section B-3d(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 inch.

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 one
filter.



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

1.9x10-6	131	95	37	24	4	4

3.7x10-6	111	85	36	24	4	4

3.7x10-5	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

1.9x10-6	213	175	108	92	56	18

3.7x10-6	188	161	105	90	56	17

3.7x10-5	80	80	75	71	49	10



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

1.9x10-6	283	243	171	154	107	34

3.7x10-6	253	225	166	151	106	31

3.7x10-5	121	121	115	110	84	13





TABLE B1-10, SCENARIO 3 DRUM AGE CRITERIA (in days) MATRIX FOR S3000 AND
S4000 WASTE BY PACKAGING CONFIGURATION GROUP (continued)

Packaging Configuration Group 4

Filter H2 Diffusivity a (mol/s/mol fraction)	Headspace Sample Taken
Inside Pipe component

> 1.9x10-6	152



Packaging Configuration Group 5

Filter H2 Diffusivity a, c (mol/s/mol fraction)	Headspace Sample Taken
Inside SWB

> 7.4x10-6	15



Packaging Configuration Group 6

Filter H2 Diffusivity a, c (mol/s/mol fraction)	Headspace Sample Taken
Inside SWB

> 7.4x10-6	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 1.9x10-6 filter H2 diffusivity, a filter of known H2 diffusivity
that is greater than or equal to 1.9x10-6 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
inches must use a DAC for a rigid liner vent hole of 0.375 inch).  If
the rigid liner vent hole diameter for a container is undocumented
during packaging (Section B-3d(1)), repackaging (Section B-3d(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 inch.

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 one
filter.



Figure B1-1, Example of the Chain-of-Custody for Headspace Gas Sample
Canisters

        (The COC, the SCID, and the Sample Canister Tag accompany the
sample canister)

(For the most current Sample Canister Tag, refer to 

L-4006, Chain-of-Custody and Sample Administration for Headspace Sample
Canisters)

Figure B1-2, Example of the Sample Canister Information Document

       (The SCID, the COC, and the Sample Canister Tag accompany the
sample canister)

(For the most current Sample Canister Tag, refer to 

L-4006, Chain-of-Custody and Sample Administration for Headspace Sample
Canisters)



Figure B1-3, Example of the Sample Canister Tag

              (The COC, the SCID, and the Sample Canister Tag accompany
the sample canister)

(For the most current Sample Canister Tag, refer to 

L-4006, Chain-of-Custody and Sample Administration for Headspace Sample
Canisters)



Figure B1-4, Example of the Chain-of-Custody/Sample Analysis Request
(WIPP)

(COC used for homogeneous solids and soil/gravel samples)

(For the most current COC, refer to PRO-543-ASD-002, Initiation,
Preparation, and 

Implementation of Chain-of-Custody Forms)



CUSTODY SEAL

DATE:	

SIGNATURE:	

Figure B1-5, Example Custody Seal

                      (Custody Seal used for homogeneous solids and
soil/gravel samples)

Figure B1-6, Overall Programmatic Approach to Visual Examination of the
Waste for Confirmation of RTR



Figure B1-7, Headspace Gas Drum Age Criteria Sampling Scenario Selection
Process

B2.	statistical methods used in sampling and analysis

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

As a Quality Control 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 RTR.

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 RTR indicates meet the Waste Acceptance
Criteria for the Waste Isolation Pilot Plant (WIPP-DOE-69) and the
Safety Analysis Report for the TRUPACT-II Shipping Package, NRC Docket
Number 71-9218, Appendix 1.3.7 - TRUPACT-II Authorized Methods for
Payload Control, but that VE indicates do not meet these criteria.

Initially, RFETS uses an eleven-percent (11%) miscertification rate to
calculate the number of waste containers to undergo VE until an
RFETS-specific miscertification rate is established.  An initial
site-specific miscertification rate is established by characterizing a
lot of no less than 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 annually 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-specific 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 Summary Category Group-specific miscertification rate
calculated to be less than 1%.

The site-specific miscertification rate is reassessed annually by
calculating a container-weighted average of all historic Summary
Category Group-specific miscertification rates.  Each Summary Category
Group-specific 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%.

The number of waste containers requiring VE (as identified in Table
B2-1) utilizes a hypergeometric approach 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.

B2-1	Approach for Statistically Selecting Waste Containers for Visual
Examination (to Confirm RTR)  (continued)

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 below. 
Compliance with the requirements for statistical selection of waste
containers for VE is achieved through the execution of site-specific
procedure PRO-945-WIPP-009, RCRA Characterization of TRU Waste to be
Disposed of at WIPP.

 ) of the true population proportion ptrue is:

 					(B2-1)

This value is only an estimate, and as a result has some uncertainty
associated with it.  This uncertainty is quantified by calculating the
upper one-sided (1 - () percent confidence limit for p, call it pUCL. 
This confidence limit gives the largest value the true proportion could
take on and still have a "reasonable" chance (e.g., an ( = .10
probability) of producing x miscertified containers in a sample of n out
of N.  This upper confidence limit is calculated as:

 						(B2-2)

where MUCL is the largest value of M such that the probability of
observing x or fewer miscertified containers in a sample of size n is
less than or equal to (.  That is, it is the largest value of M such
that the following inequality is true:

 						(B2-3)

where each term in parentheses has the usual combinatorial
interpretation.  For example:

  						(B2-4)

Each term in the sum in Equation (B2-3) is the hypergeometric
probability of observing k miscertified containers in a sample size n
from a population of size N in which there are M miscertified containers
(and hence the population proportion of miscertified containers is p =
M/N).  The value MUCL is obtained by substituting different values for M
into Equation (B2-3) until the largest value satisfying the inequality
is found.

Note that in Equation (B2-3), the upper confidence limit is dependent on
x, the number of miscertifications observed in the sample, as well as on
n, the sample size.  To obtain the required sample size, the values of x
that are likely to be seen also need to be considered.  Sample size that
are visually examined are determined by setting a desired upper
confidence limit value and then manipulating x and n in Equation (B2-3).

B2-2	Approach for Selecting Waste Containers for Statistical Sampling 

B2-2a	Statistical Selection of Containers for Total (or TCLP) Analysis

The statistical approach for characterizing retrievably stored
homogeneous solids and soil/gravel waste and repackaged or treated S3000
waste that RFETS demonstrates is not suitable for control charting using
sampling and analysis relies on using acceptable knowledge to segregate
waste containers into relatively homogeneous waste streams.  Using
acceptable knowledge, 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 TWCP Site PM verifies that the samples collected
from within a waste stream were selected randomly in accordance with
PRO-945-WIPP-009, RCRA Characterization of TRU Waste to be Disposed of
at WIPP.

An end use of analytical results for retrievably stored homogeneous
solids and soil/gravel is for assigning the Environmental Protection
Agency hazardous waste D-codes that apply to each mixed waste stream and
to confirm acceptable knowledge.  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 F-codes identified via acceptable knowledge, 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 F-code(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 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 following equations:

											(B2-5)

											B(2-6)

B2-2a	Statistical Selection of Containers for Total (or TCLP) Analysis 
(continued)

where x is the calculated mean and s2 is the calculated concentration
variance, n is the number of samples analyzed, xi is the concentration
determined in the ith sample, and i is an index from 1 to n.

Based upon the preliminary estimates of x and s2 for each chemical
contaminant of concern, the appropriate number of samples (n) to be
collected for each contaminant is estimated using the following
formulas:

											(B2-7)

Where:

	n0 = the initial number of samples used to calculate the preliminary
sample estimate.

	n = the calculated number of samples in the preliminary estimate.

	t2 = the 90th percentile for a t distribution with n0-1degrees of
freedom.

	RT = Regulatory Threshold of the contaminant (TC limit for toxicity
characteristic wastes, PRQL for listed wastes).

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 is then
randomly sampled and analyzed.  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 sample
results shall indicate that all sample results were valid according to
the analytical methodology.

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

B2-2a	Statistical Selection of Containers for Total (or TCLP) Analysis
(continued) 

Compliance with the requirements for statistically selecting retrievably
stored waste containers for total/TCLP analysis is achieved through the
execution of procedure PRO-945-WIPP-009, RCRA Characterization of TRU
Waste to be Disposed of at WIPP.  Document RMRS-WIPP-98-100, Acceptable
Knowledge TRU/TRM Waste Stream Summaries identifies the various
transuranic waste streams based on acceptable knowledge.

B2-2b	Statistical Selection of Containers for Headspace Gas Analysis

If a waste stream meets the conditions for representative headspace gas
sampling 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-WAP.  The value of n is determined
in accordance with the equation presented in Section B2-2b of the
WIPP-WAP.

											B(2-8)

Where:

nvoci is the number of samples needed to representatively sample the
waste stream for the VOCi from Table IV.D.1.

sevoci is the estimated standard deviation, based on the initial
10-samples, for VOCi from Table IV.D.1.

Evoci is the allowable error determined as 1 percent of the limiting
concentration for VOCi from Table IV.D.1.

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 sample
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.

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 WIPP-WAP.

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.  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 PRO-945-WIPP-009, RCRA Characterization of TRU Waste to be
Disposed of at WIPP.

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(a, n-1)
is taken from Table 9-2 of Chapter 9 of SW-846.

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.

B2-4	Control Charting for Newly Generated Waste Stream Sampling

For newly generated waste streams that RFETS 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
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 ( 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
RCRA-hazardous, 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.

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.

B2-4	Control Charting for Newly Generated Waste Stream Sampling
(continued)

Unless a waste generating process is designed to control RCRA
parameters, it is not possible to demonstrate that the waste stream has
a constant mean and constant variance, and as a result, it is not
feasible to develop meaningful control charts.  Baseline sampling and
acceptable knowledge may be used to demonstrate this lack of feasibility
(refer to WIPP Clarification Number CAO-00-029).

Control charting is not acceptable for uncontrolled processes, and
therefore wastes from such processes must be sampled using the
requirements in Section B2-2, Approach for Statistically Selecting
Retrievably Stored Waste Containers for Total (or TCLP) Analysis. 
Because control charting is not useful in controlling hazardous waste
constituents in such cases, the Site characterizes these homogeneous
wastes in accordance with Section B2-2, and documents that the control
charting was unuseable (refer to WIPP Clarification Number CAO-00-029).

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.



Figure B2-1, Statistical Approach to Sampling and Analysis of Waste
Streams of Retrievably Stored Homogeneous Solids and Soil/Gravel

B3.	Quality assurance objectives and data validation techniques for
Waste characterization sampling and analytical methods

B3-1	Validation Methods

Qualitative as well as quantitative validation of all data are 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 headspace gas, VOC, SVOC, and metals analysis.  These
quantitative data validations are performed by TWCP staff and compared
to the QAOs specified in Sections B3-2 through B3-9.  A qualitative
determination of comparability and representativeness is also performed.

Data generation level validation for RFETS waste solid sampled and
analyzed at INEEL is conducted by the INEEL TWCP as described in the
Attachment to the SOW for the INEEL TWCP (DOE 2003a).

Validation methods for RTR QAOs are presented in Section B3-10 of this
document.  VE, which occurs on a subpopulation of containers which have
already undergone RTR, is used to verify waste matrix codes and waste
material parameter weights as described in Section B1-3 and Section
B3-4.  During VE, the waste matrix code is determined and the waste
material parameter codes are estimated to verify that the container is
properly included in the appropriate waste stream.

The TWCP Site PM documents that the selected waste containers from
within a waste stream are randomly selected according to 95-WP/SAP-001,
Transuranic (TRU/TRM) Waste Sampling Plan.  Sampling personnel follow
current procedures (as described in Section B1 of this document) to
ensure that samples are representative of the waste contained in a
particular waste container or a 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.  These
objectives are described below:

B3-1a	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:

 

Where C1 and C2 are the two values obtained by analyzing the duplicate
samples.

For three or more replicate measurements, the precision expressed as the
%RSD is calculated as follows:

Where s is the standard deviation and y is the mean of the replicate
sample analyses.

B3-1a	Precision  (continued)

The standard deviation, s, is calculated as follows:

Where yi is the measured value of the ith replicate sample analysis
measurement, and n equals the number of replicate analyses.

Another aspect of precision is associated with analytical equipment
calibration.  In these instances, the percent difference (%D) between
multiple measurements of an equipment calibration standard are
calculated as follows:

Where C1 is the initial measurement and C2 is the second or other
additional measurement.

B3-1b	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:

Where Cm is the measured concentration value obtained by analyzing the
sample and Csrm is the “true” or certified concentration of the
analyte in the sample.

For measurements where matrix spikes are used, the %R is calculated as
follows:

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.

B3-1c	Method Detection Limit

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

Where                            is the t-distribution value appropriate
to a 99-percent 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.

B3-1d	Completeness

Completeness is a measure of the amount of valid data (i.e., data that
meets all QA/QC requirements) 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:

Where V is the number of valid analytical results obtained and n is the
number of samples submitted for analysis.

B3-1e	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 criteria for data
usability are provided in EPA 540/R-99/008, USEPA Contract Laboratory
Program National Functional Guidelines for Organic Data Review (EPA
1999); and EPA 540-R-01-008, USEPA Contract Laboratory Program National
Functional Guidelines for Inorganic Data Review (EPA 2002).

The criteria shall address, as appropriate, the following:

Definition or reference of criteria used to define and assign data
qualifier flags based on Quality Assurance Objective 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:

	Severe matrix effects,

	Misidentification of compounds,

	Gross exceedance of holding times,

	Failure to meet calibration or tune criteria

Criteria for assessing the usability of data that does not meet minimum
detection limit requirements.

B3-1f	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, reduced headspace gas sampling per Section
B-3a(1)(i) or B-3a(1)(ii), and homogeneous solids and soil/gravel
sampling and analysis is validated, through documentation, and this
confirms that 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 on a Program level.  The TWCP Site PM
documents that the selected waste containers from within a waste stream
were randomly selected.  Sampling personnel verify current procedures
are followed to ensure that samples are representative of the waste
contained in a particular waste container or a waste stream.

B3-1g	Nonconformance to DQOs

The analytical procedures contain specific QC requirements to ensure
that the data generated meets the DQOs.  Sections B3-5 through B3-8
provide more details on how the data from the analytical procedures is
assessed for compliance with the DQOs.  If data is generated which
doesn’t meet the DQOs, it is treated as a nonconformance.  Section
B3-13 describes the nonconformance procedure.  Failure to meet a DQO
which is first discovered at the TWCP Site PM signature release level
will be identified and reported as a nonconformance as described in
Section B3-13.  For analytical data, if a DQO is not met due to matrix
effects, the data is not considered a nonconformance.  Such data is
flagged appropriately and discussed in the case narrative of the
associated Batch Data Report.

B3-1h	Identification of Tentatively Identified Compounds

In accordance with SW-846 convention, identification of compounds
detected by gas chromatography/mass spectrometry methods that are not on
the list of target analytes shall be reported.  Both composited and
individual container headspace gas, volatile analysis (Totals), and
semi-volatile (Totals) shall be subject to tentatively identified
compound (TIC) reporting.  These TICs for GC/MS Methods are identified
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
percent.

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 a
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.

B3-1h	Identification of Tentatively Identified Compounds  (continued)

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 listed 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 contains 2 to 5
individual container samples shall be reported in the analytical batch
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 to 10
individual container samples shall be reported in the analytical batch
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
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.

TICs that meet the SW-846 identification criteria, are reported in 25
percent of all waste containers sampled from a given waste stream, and
that appear in the 20.4.1.200 NMAC (incorporating 40 CFR §261) Appendix
VIII list, will be compared to acceptable knowledge data 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 percent 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
degredation from acceptable knowledge 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 non-toxic F003 constituents, RFETS 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 subsequent samples collected from that
waste stream will be analyzed for constituents on the expanded list. 

Method 8260B and Method 8270C state the following:  “only after visual
comparison of sample spectra with the nearest library searches may the
analyst assign a tentative identification.  Use the following guidelines
for making tentative identification…”  A visual comparison of sample
spectra allows the analyst to override potential spurious matches,
occasionally made by otherwise reliable criteria and/or algorithms.

B3-1h	Identification of Tentatively Identified Compounds  (continued)

The TIC identification procedure is outlined below:

An initial TIC report, generated by the instrument software, provides
background subtracted spectra for all compounds with peak areas greater
than 10% of the nearest internal standard.  The report lists the top
five library matches for each TIC found by the searching algorithm. 
Generally, it is only necessary to evaluate the top hit, but it is
acceptable to evaluate as many of the compounds in the library search as
deemed necessary by the chemist to fully characterize the spectrum.

For WIPP evaluations, the TICs may be limited to the available spectra
for compounds that appear in the 20.4.1.200 NMAC (incorporating 40 CFR
Part 261) Appendix VIII list.

The chemist evaluates the compounds that provide the best library match
for each of the TIC’s found using the following criteria.

All ions that have a relative abundance of 10% or greater in the
reference spectrum (major ions) must be present in the sample spectrum. 
The relative abundance scale of the spectrum may be used to evaluate
this criterion.  It is not necessary to print out the tabulated spectrum
to find the major ions.

The relative abundance of the major ions in the sample spectrum should
be within ( 20% of the relative abundance of the corresponding ions in
the reference spectrum.  The chemist will use judgment and visual
inspection of the spectra to determine if the relative abundance of the
ions from the sample and reference spectra are in agreement.

If a molecular ion is present in the reference spectrum it must be
present in the sample spectrum.

Any major ions that are present in the sample spectrum but not present
in the reference spectrum should be carefully evaluated for the presence
of a co-eluting compound or general chemical noise.  Special attention
should be given to ions at higher masses as these are more important for
compound identification than low mass ions.  High mass ions that are not
due to co-eluting compounds or chemical background should be considered
even if they are present with a relative abundance of less than 10%.

Any major ions that are present in the reference spectrum but not in the
sample spectrum should be carefully evaluated to assure that the ion was
not removed from the spectrum by the background subtraction algorithm.

If, after careful inspection by the chemist, the criteria from 2.1
through 2.5 have been satisfied then the compound is reported as a TIC.

If, after careful inspection by the chemist, one or more of the criteria
specified in sections 2.1 through 2.5 have not been satisfied, but the
sample spectrum is similar to the reference spectrum then the compound
is NOT reported as a TIC.

If, after careful inspection by the chemist, the criteria from 2.1
through 2.5 have not been satisfied then the compound is NOT reported as
a TIC.

IF a positive match cannot be established based on the above criteria,
the component in the sample spectrum is reported as an unknown.

B3-2	Headspace Gas Sampling

B3-2a	Quality Assurance Objectives

Headspace gas sampling will occur from the headspace within each
container of TRU mixed waste or randomly selected containers from waste
streams that meet the conditions for reduced headspace gas sampling
listed in Section B-3a(1).  Headspace gas samples are collected
following procedures PRO-1676-HGAS-S&A, Headspace Gas Sampling and
Analysis Using an On-Line Integrated System; L-4231, Headspace Gas
Sampling and Analysis Using an Automated Manifold; and L-4146, Headspace
Gas Sampling of Waste Containers.

Precision and accuracy of container headspace gas sampling operations
are assessed by analyzing field QC headspace samples, which consist of
field blanks, field duplicates, equipment blanks, and field reference
standards (refer to PRO-1669-HGAS-V&V, Headspace Gas V&V (Data Generator
Level); L-4053, Headspace Gas V & V (Data Generator Level); and L-5017,
HVOC Data Review and Validation (Data Generator Level)2).  If the QAOs
described in this section are not met, a nonconformance report is
prepared, submitted and resolved.  Table B1-2 summarizes the field QC
sample collection requirements and Table B1-3 summarizes the QC sample
acceptance criteria.

B3-2b	Precision

The precision of headspace gas sampling and analysis is assessed by
simultaneous collection of field duplicates for manifold sampling
operations.  The RPD is calculated for each field sample/duplicate pair
and compared to the criterion of 25%.  If the RPD exceeds the criterion
and the analyte concentration exceeds its PRQL, remedial actions must be
taken.  If the problem cannot be resolved, a nonconformance must be
written for any affected samples.  If there are no target analytes above
the PRQL detected in the duplicate samples then a second field reference
standard will be used as the duplicate.  The two field reference
standards must meet the same duplicate drum sample criteria.

B3-2c	Accuracy

Field reference standards are collected using the headspace sampling
equipment to assess the accuracy of the headspace sampling operations at
a frequency of one field reference standard per sampling batch.  The %R
for each analyte in the field reference sample will be calculated and
compared to the acceptance criteria of 70 – 130%, inclusive.  If a %R
is outside of the criteria, remedial actions must be taken.  If the
problem cannot be resolved, a nonconformance must be written for any
affected samples.

Field and equipment blanks are collected using the headspace sampling
equipment to assess the accuracy of the headspace sampling operations
with respect to contamination.  For the equipment blank, a clean gas
canister is selected from a batch of canisters that were cleaned at the
same time, the canister is filled with blank gas and then analyzed for
cleanliness.  For both field blanks and equipment blanks, the
concentration of each target analyte must be less than or equal to three
times the MDL.  If the concentration of any target compound is outside
of the criteria, remedial actions must be taken.  If the problem cannot
be resolved, a nonconformance must be written for any affected samples.

B3-2d	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 containers
for each waste stream.  A valid sample is defined as a sample collected
in accordance with approved sampling methods and the container was
properly prepared for sampling (refer to Section B3-10 for data review,
validation, and verification).  The amount and type of data that may be
lost during the headspace gas sampling operation cannot be predicted in
advance. The TWCP Site PQAO evaluates the importance of any lost or
contaminated headspace gas samples and takes corrective action as
appropriate.  The project level office calculates the QAO for
completeness on a waste stream basis (i.e., the waste stream basis
calculation is not performed at the data generation level).

B3-2e	Comparability

Consistent use and application of uniform procedures and equipment as
specified in Section B1 of this document, and application of data
usability criteria [refer to EPA 540/R-099/008, USEPA Contract
Laboratory Program National Functional Guidelines for Organic Data
Review (EPA 1999); and EPA 540-R-01-008, USEPA Contract Laboratory
Program National Functional Guidelines for Inorganic Data Review (EPA
2002)] should ensure that headspace gas sampling operations are
comparable when sampling headspace at the different sampling facilities.
 RFETS takes corrective actions if uniform procedures, equipment, or
operations are not followed without approved and justified deviations. 
In addition, laboratories analyzing samples successfully participate in
the Performance Demonstration Program (PDP).

B3-2f	Representativeness

Specific headspace gas sampling steps to ensure samples are
representative include:

Selection of the correct DAC Scenario and waste packaging configuration
and meeting DAC equilibrium times.

A 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 percent of the headspace when the headspace
can be determined).

Careful and documented pressure regulation of all activities specified
in Section B1-1 of this document.

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 first use, or as necessary according to
manufacturer’s specifications.

Failure to perform the checks at the prescribed frequencies will result
in corrective actions.  Procedures include specific steps and
requirements to ensure the representativeness of sampling.

B3-3	Sampling of Homogeneous Solids and Soils/Gravel

B3-3a	Quality Assurance Objectives

This section presents quality assurance objectives to ensure sampling is
conducted in a representative manner on a waste stream basis for
containers containing homogeneous solids and soil/gravel.  Samples are
randomly collected in both the horizontal and vertical planes of each
waste container.  For waste containers that contain homogeneous waste in
smaller containers within the waste container, one randomly chosen
smaller container must be sampled from each drum.

Quality assurance objectives for RFETS waste sampled at INEEL are
described in the Attachment to the SOW for the INEEL TWCP (DOE 2003a).

B3-3b	Precision

Sampling precision is determined by collecting and sampling duplicates,
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), which are collected
within 14 days of the first sample in the batch.  The Relative Percent
Difference (RPD) between co-located core samples will be calculated and
reported at the generation level and verified by the TWCP Site PQAO.

For RFETS waste sampled at INEEL the RPD of co-located core samples is
calculated and reported by the RFETS TWCP Site PQAO.

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 co-located cores or samples), control
charts of the RPD are 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 are 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 are updated using all available data.  The RPD and F-Test
calculations are performed in accordance with PRO-604-RC-001, Field
Sample QC Data Calculation, Review, and Validation Batch Reports.

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

B3-3c	Accuracy

Sampling accuracy using standard reference materials will not be
measured.  Because 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.

Sampling accuracy as a function of sampling cross-contamination is
measured.  Equipment blanks are collected at a frequency of once per
equipment cleaning batch.  Corrective actions are 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 are collected from the following equipment types:

Fully assembled coring tools.

Liners cleaned separately from coring tools.

Miscellaneous sampling equipment that is reused (e.g., bowls, spoons,
chisels).

B3-3d	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 that is collected from a randomly
selected drum using randomly selected horizontal and vertical planes in
accordance with approved sampling methods.  RFETS must achieve a minimum
of 90% completeness.

B3-3e	Comparability

Consistent use and application of uniform procedures, sampling
equipment, and measurement units, as specified in Section B1 of this
document, should ensure that sampling operations are comparable.  The
analysis results of duplicates as required for alternative methods are
also examined to determine comparability.  Consistent application of
data usability criteria [refer to EPA 540/R-99/008, USEPA Contract
Laboratory Program National Functional Guidelines for Organic Data
Review (EPA 1999); and EPA 540-R-01-008, USEPA Contract Laboratory
Program National Functional Guidelines for Inorganic Data Review (EPA
2002)] should also ensure comparability.  In addition, the laboratories
analyzing the samples successfully participate in the PDP.

B3-3f	Representativeness

Procedures and sampling plans provide specific steps to ensure the
representativeness of samples including:

Sampling equipment is cleaned prior to sampling.

Sample tool selection is designed to minimize alteration of the in-place
characteristics.

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

B3-4	Radiography

B3-4a	Quality Assurance Objectives

The QAOs for Real-Time Radiography (RTR) are detailed in this section. 
The objective of RTR for the TWCP is to verify the Waste Matrix Code, to
identify prohibited items for each waste container, and to estimate each
waste material parameter weight.  All activities required to achieve
these objectives are described or incorporated by reference in this
document.

Data to meet these objectives are provided by trained and qualified RTR
operators.  The RTR operators scan the waste containers and record the
results on audio/videotapes and RTR data forms.  The precision,
accuracy, completeness, and comparability objectives for RTR data are
described in the following sections.

In the event QAOs are not met, corrective action will be taken in
accordance with procedure 1-A65-ADM-15.01, Control of Nonconforming
Items.

B3-4b	Precision

The qualitative determinations made during RTR do not lend themselves to
the statistical evaluation of precision.  Comparison of data derived
from RTR and VE (to Confirm RTR) on some containers at RFETS (and INEEL)
indicate that RTR operators can provide estimated inventories and waste
material parameter weights of waste items in a waste container (EG&G
1993).  The TWCP Site PQAO calculates and reports the relative percent
difference between the estimated waste material parameter weights (by
RTR) and these same parameters as determined by VE (to Confirm RTR).

Additionally, the precision of RTR is verified prior to use by tuning
precisely enough by viewing an image test pattern to demonstrate
compliance with QAOs.

B3-4c	Accuracy

The programmatic accuracy with which the waste material parameter
weights can be determined is documented through the VE (to Confirm RTR)
of a randomly selected statistical subpopulation of containers (See
Section B2-1).  The percentage of waste containers that require a new
Waste Matrix Code or are found to contain prohibited items after VE (to
Confirm RTR) is reported as a measure of RTR accuracy.  The TWCP Site
PQAO 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 (to Confirm RTR) as a
measure of RTR accuracy.  The miscertification rate calculated by the
TWCP Site PQAO is used to determine the number of containers subject to
VE (to Confirm RTR).

B3-4d	Completeness

An audio/videotape of the RTR examination and an RTR data form,
validated according to the requirements in Section B3-10, is obtained
for 100% of the retrievably stored waste containers in the TWCP for all
waste containers subject to RTR.  All audio/videotape and RTR data forms
are subject to validation as discussed in B3-10.

B3-4e	Comparability

The use of standardized radiography procedures and operator
qualification training enhances comparability of RTR data.  Operator
training requirements are outlined in Section B1-3b.  RTR operators
comply with the training and qualification requirements of the TWCP TIP,
and 5-NDT-TC-1A, Training, Qualification and Certification of
Nondestructive Testing Personnel.  Procedures 4-W30-NDT-00664, Real-Time
Radiography Testing of Transuranic and Low-Level Waste in Building 664;
4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569; and PRO-1520-Mobile-RTR, Mobile
Real-Time Radiography Testing of Transuranic and Low-Level Waste, are
used in implementation of the RTR program.

B3-5	Gas Volatile Organic Compound Analysis

B3-5a	Quality Assurance Objectives

The QAOs for the TWCP are listed in Table B3-2.  The specified QAOs
represent the required quality of data necessary to draw valid
conclusions regarding the TWCP objectives.  TWCP-required limits, such
as the PRQL associated with VOC analysis, are specified to ensure that
the analytical data collected satisfy the requirements of all data
users.  Key data quality indicators for headspace measurements are
defined below for Gas VOC analysis, and the methods to quantitatively
and qualitatively assess these indicators are discussed in Section B3 of
this document.  Table B-1 contains a synopsis of the site-specific
procedures used for gas volatile sampling and analysis.

B3-5b	Precision

Precision is assessed by analyzing laboratory duplicates, replicate
analyses of laboratory control samples, and PDP blind-audit samples. 
The results of QC samples are compared to the criteria listed in Tables
B3-2 and B3-3.  These QC measurements are used to demonstrate acceptable
method performance and to trigger corrective action when control limits
are exceeded.

With every sample batch, a laboratory duplicate is analyzed.  The
precision within a sample batch is assessed by calculating a relative
percent difference (%RPD) between the sample and the duplicate  results.
 For target compounds with concentrations exceeding their PRQL, the %RPD
must comply with the criteria in Table B3-2.  If the %RPD is not within
the criteria, corrective action is taken.

Headspace Analytical Services also analyzes PDP blind audit samples.  If
notified that the precision of the PDP analyses is not acceptable,
corrective action will be taken.  Further analyses cannot be performed
until acceptable precision is demonstrated through additional replicate
analyses of a laboratory control sample, or acceptable analysis of
additional PDP samples.

B3-5c	Accuracy

Accuracy as %R is assessed for the headspace operations by analyzing PDP
blind-audit samples and laboratory control samples.  The results from
these QC measurements compared to the criteria listed in listed in Table
B3-2 and Table B3-3.  These QC measurements are used to demonstrate
acceptable method performance and to trigger corrective action when
control limits are exceeded.

The accuracy within a sample batch is assessed by calculating the %R for
the Laboratory Control Sample (LCS), which is analyzed with each batch
of samples.  The %R must comply with the criteria in Table B3-2.  If the
%R is not within the criteria, corrective action is taken.  Samples
associated with the poor LCS must be re-analyzed when the problem is
corrected, if the usability of the results was impacted by the poor LCS
recovery.

Headspace Analytical Services also analyzes PDP blind audit samples.  If
notified that the accuracy of the PDP analyses is not acceptable,
corrective action will be taken.  Further analyses cannot be performed
until acceptable accuracy is demonstrated through additional replicate
analyses of a laboratory control sample, or acceptable analysis of
additional PDP samples.

B3-5d	Calibration

GC/MS Tunes, initial calibrations, and continuing calibration are
performed as specified in procedures and evaluated to the criteria
specified in Table B3-3.  These procedures follow the guidance provided
in SW-846 Method 8260 and TO-14.  They include acceptance criteria and
corrective action to demonstrate that the calibration for an analytical
run is acceptable.  These criteria will be used to demonstrate
acceptable calibration and to trigger corrective action when control
limits are exceeded

B3-5e	Method Detection Limit

MDLs are expressed in ng for gas VOCs.  The method for determining the
MDLs is specified in procedures.  It is based upon the guidance provided
in B3-1.  MDLs will be determined prior to any samples being analyzed
and semi-annually thereafter.  The measured MDLs will be compared to the
required MDLs listed in Table B3-2.  If the MDLs are not met, corrective
action will be performed and the MDLs re-determined.  Analyses will not
proceed until the MDL criteria are met.

B3-5f	Program Required Quantitation Limit

Headspace Analytical Services meets the PRQL requirement by following
the analytical procedures.  At least one of the calibration standards is
set at a concentration less than the PRQLs listed in Table B3-2.  The
concentration of target analytes in the calibration standards is listed
in procedures.

B3-5g	Completeness 

Analytical 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.  Headspace procedures include strict QC controls
to ensure that valid results are obtained for all sample analyses.  The
QC controls are described in the headspace procedures and completeness
is checked and compared to the criteria listed in Table B3-2.  A
composite sample is treated as one sample for the purpose of
completeness, because only one sample is run through the analytical
instrument.  If the observed completeness is not compliant, corrective
action is taken.  Headspace Analytical Services will attempt to resolve
the problem causing the non-compliance.  If not possible, a
nonconformance will be written.

B3-5h	Comparability 

Consistent use and application of uniform procedures (e.g., standardized
methods traceable standards, etc.) as specified in Section B1 of this
document, and application of data usability criteria [refer to EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999); and EPA 540-R-01-008,
USEPA Contract Laboratory Program National Functional Guidelines for
Inorganic Data Review (EPA 2002)] should ensure that analytical data are
comparable between different analytical facilities.  Headspace
Analalytical Services achieves comparability by following standardized
methods;

The analysis is performed by following headspace procedures.  These
procedures are based primarily upon SW-846 Method 8260, and meets the QC
requirements specified in Table B3-3 of this document.

Data package verification and validation is performed by following
procedure PRO-1669-HGAS-V&V, L-4053, or L-5017 which follow the process
outlined in B3-10 of the WAP.  Completeness is checked and compared
against the QAOs listed in Table B3-2.

Using traceable standards; As part of the headspace procedures Headspace
Analytical Services uses certified, traceable standards to prepare all
QC standards and solutions.  The source of standards is documented and
the certificates of analysis maintained in the certified standards
notebook.

Successful participation in the PDP.

B3-5i	Representativeness 

For VOC analyses, representativeness for VOC samples is achieved by
collecting sufficient numbers of samples using a sampling manifold. 
Sample collection is described in Section B1-1 of this document.

B3-5j	Method Performance Samples (MPS)

MPS are expressed in ng for gas VOCs.  The procedure for determining the
MPS is specified in L-4231, Headspace Gas Sampling and Analysis Using an
Automated Manifold; and PR0-1676-HGAS-S&A, Headspace Gas Sampling and
Analysis Using an On-Line Integrated System.  It is based upon the
guidance provided in Section B3-1.  MPS will be determined prior to any
samples being analyzed by L-42313 and PRO-1676-HGAS-S&A, and
semi-annually thereafter.  The measured MPS will be compared to the
required MPS listed in Table B3-2.  If the MPS are not met, corrective
action will be performed and the MPS re-determined.  Analyses will not
proceed until the MPS criteria are met.

B3-6	Total Volatile Organic Compound Analysis 

B3-6a	Quality Assurance Objectives

The QAOs for the TWCP are listed in Table B3-4.  The specified QAOs
represent the required quality of data necessary to draw valid
conclusions regarding TWCP objectives.  Program-required limits, such as
the PRQLs associated with VOC analysis, are specified to ensure that the
analytical data collected satisfy the requirements of all data users. 
Key data quality indicators for laboratory measurements are defined
below.  The methods to quantitatively and qualitatively assess these
indicators are discussed in Section B3 of this document.  Table B-1
contains a synopsis of the site-specific procedures used for total
volatile organic compound analysis.

Procedures implemented to ensure total volatile organic compound
analysis conducted at INEEL meets quality assurance objectives are
described in the Attachment to the SOW for the INEEL TWCP (DOE 2003a).

B3-6b	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 QC samples are
compared to the criteria listed in Tables B3-4 and B3-5.  These QC
measurements are used to demonstrate acceptable method performance and
to trigger corrective action when control limits are exceeded.

Initially, precision is assessed prior to using the analytical procedure
L-4165, GC/MS Determination of Volatile Organic Compounds (Solids,
Liquids, and TCLP Extracts) (referred to in this section as L-4165) for
WIPP samples by analyzing a minimum of 7 replicate method performance
samples.  The percent Relative Standard Deviation (%RSD) is calculated
for the replicate analyses and compared to the precision criteria in
Table B3-4.  The %RSD must comply with the criteria before the procedure
can be used to analyze WIPP samples.  These initial analyses fulfill the
requirement for “Method Performance Samples” listed in Table B3-5.

With every sample batch, a MS/MSD sample pair is analyzed.  The
precision within a sample batch is assessed by calculating a relative
percent difference (%RPD) between the MS and MSD results.  The %RPD must
comply with the criteria in Table B3-4.  If the %RPD is not within the
criteria, corrective action is taken.  If the poor precision is traced
to the sample matrix, sample data is flagged with a “Z”, as directed
in WAP Section B3-10 (a nonconformance report is not required when the
problem is traced to the matrix, as specified in Table B3-5).

As stated in Table B3-5, a separate laboratory duplicate analysis is not
required when a MS/MSD pair is analyzed; hence laboratory duplicates are
not used to assess precision.

Replicate low-level method performance samples are analyzed
semi-annually to update MDLs.  The %RSD for the analyses is calculated. 
The %RSD must comply with the criteria in Table B3-4.  If the precision
is not acceptable, the cause of the poor precision must be determined
and corrective action performed.  Further analyses cannot be performed
until acceptable precision is demonstrated through additional replicate
analyses of method performance samples (a minimum of four analyses). 
These analyses fulfill the requirement for “Method Performance
Samples” listed in Table B3-5.

The laboratory also analyzes PDP blind audit samples.  If notified that
the precision of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
precision is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

B3-6c	Accuracy 

Accuracy as %R is assessed for the laboratory operations by analyzing
laboratory control samples, matrix spikes, surrogate compounds, and PDP
blind-audit samples.  The results from these measurements for matrix
spikes samples are compared to the %R criteria listed in Table B3-4. 
Results for surrogates and internal standards are evaluated as specified
in SW-846 or Table B3-5.  These QC measurements are used to demonstrate
acceptable method performance and to trigger corrective action when
control limits are exceeded.

Initially, accuracy is assessed prior to using the analytical procedure
L-4165 for WIPP samples by analyzing a minimum of seven replicate method
performance samples.  The average percent recovery (%R) is calculated
for the replicate analyses and compared to the accuracy criteria in
Table B3-4.  The %R must comply with the criteria before the procedure
can be used to analyze WIPP samples.  These initial analyses fulfill the
requirement for “Method Performance Samples” listed in Table B3-5.

With every sample batch, a MS/MSD sample pair is analyzed.  Additionally
System Monitoring Compounds (SMC) are added to every sample.  The
accuracy within a sample batch is assessed by calculating the %R for the
MS and MSD results, and the accuracy within a sample is assessed by
calculating the %R for the SMC compounds.  The %R must comply with the
criteria in Table B3-4.  If a %R is not within the criteria, corrective
action is taken.  If the poor accuracy is traced to the sample matrix,
sample data is flagged with a “Z”, as directed in WAP Section B3-10
(a nonconformance report is not required when the problem is traced to
the matrix, as specified in Table B3-5).

The accuracy within a sample batch is also assessed by calculating the
%R for the LCS, which is analyzed with each batch of samples.  The %R
must comply with the criteria in Table B3-4.  If the %R is not within
the criteria, corrective action is taken.  Samples associated with the
poor LCS must be re-analyzed when the problem is corrected, if the
usability of the results was impacted by the poor LCS recovery.

Replicate low-level method performance samples are analyzed
semi-annually to update MDLs.  The average %R for the analyses is
calculated.  The %R must comply with the criteria in Table B3-4.  If the
accuracy is not acceptable, the cause of the poor accuracy must be
determined and corrective action performed.  Further analyses cannot be
performed until acceptable accuracy is demonstrated through additional
replicate analyses of method performance samples (a minimum of four
analyses).  These analyses fulfill the requirement for “Method
Performance Samples” listed in Table B3-5.

The laboratory also analyzes PDP blind audit samples.  If notified that
the accuracy of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
accuracy is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

Laboratory  blanks shall be assessed to determine possible laboratory
contamination and are evaluated as specified in Table B3-5.  These QC
measurements will be used to demonstrate acceptable levels of laboratory
contamination and to trigger corrective action when control limits are
exceeded.

B3-6d	Calibration 

GC/MS Tunes, initial calibrations, and continuing calibration are
performed as specified in L-4165.  L-41651 follows the guidance provided
in SW-846 Method 8260.  It includes acceptance criteria and corrective
action to demonstrate that the calibration for an analytical run is
acceptable as specified in Table B3-5 and SW-846.

B3-6e	Method Detection Limit 

MDLs are expressed in mg/kg for VOCs.  The procedure for determining the
MDLs is specified in L-41651, Section 5.10.  It is based upon the
guidance provided in SW-846.  MDLs will be determined prior to any
samples being analyzed by L-41651.  The measured MDLs will be compared
to the required MDLs listed in Table B3-4.  If the MDLs are not met,
corrective action will be performed and the MDLs re-determined. 
Analyses will not proceed until the MDL criteria are met.

B3-6f	Program Required Quantitation Limit 

The laboratory meets the PRQL requirement by following the analytical
procedure L-41651.  At least one of the calibration standards is set at
a concentration less than the PRQLs listed in Table B3-4.  The
concentration of target analytes in the calibration standards is listed
in Section 4 of L-41651.  The concentration of the continuing
calibration standard is also less than the PRQL, as specified in the
same section.

B3-6g	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.  Valid results are defined as results that meet
the data useability criteria based upon application of the Quality
Control Criteria specified in Tables B3-4 and B3-5 and meet the
calibration, detection limit, representativeness, and comparability
criteria within this section.  Laboratory procedure L-41651 includes
strict QC controls to ensure that valid results are obtained for all
sample analyses.  The QC controls are described in the laboratory
procedure.  During the validation of Batch Data Reports by procedure
L-4038, WIPP Data Review and Validation for Volatile Organic Compounds1
(referred to in this section as L-4038), completeness is checked and
compared to the criteria listed in Table B3-4.  If the observed
completeness is not compliant, corrective action is taken.  The
laboratory will attempt to resolve the problem causing the
non-compliance.  If not possible, a nonconformance will be written.

For RFETS waste analyzed at INEEL, laboratory completeness is evaluated
by the RFETS TWCP Site PQAO.  If the observed completeness is not
compliant, corrective action is taken.

B3-6h	Comparability

Consistent use and application of uniform procedures (e.g., standardized
methods traceable standards, etc.) as specified in Section B1 of this
document, and application of data usability criteria [refer to EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999); and EPA 540-R-01-008,
USEPA Contract Laboratory Program National Functional Guidelines for
Inorganic Data Review (EPA 2002)] should ensure that analytical data are
comparable between different analytical facilities.

The laboratory achieves comparability by following standardized methods:

The laboratory sample preparation and analysis is performed by following
procedures L-4165.  This procedure is based upon SW-846 Methods 5030 and
8260 and meets the QC requirements listed in Table B3-5.  The most
recent promulgated version of SW-846 may be used.  Changes to SW-846
methodology that result in the elimination of sample preparation or
analytical methods in use at RFETS are addressed as a corrective action
to address the comparability of data before and after the SW-846
modification.

Batch Data Report verification and validation is performed by following
procedure L-40381, which follows the process outlined in B3-10 of the
WAP.  Completeness is checked and compared against the QAOs listed in
Table B3-4.

Using traceable standards;  As part of the procedure L-41651 the
laboratory uses certified, traceable standards to prepare all QC
standards and solutions.  The source of standards is documented and the
certificates of analysis maintained in the certified standards notebook.

Successful participation in the PDP.

B3-6i	Representativeness

Representativeness for VOC analysis is achieved by collecting unbiased
samples in accordance with Section B1.

B3-7	Total Semivolatile Organic Compound Analysis

B3-7a	Quality Assurance Objectives

The QAOs for the TWCP are listed in Table B3-6.  The specified QAOs
represent the required quality of data necessary to draw valid
conclusions regarding TWCP objectives.  Program-required limits, such as
the PRQLs associated with SVOC analysis, are specified to ensure that
the analytical data collected satisfy the requirements of all data
users.  Key data quality indicators for laboratory measurements are
defined below.  The methods to quantitatively and qualitatively assess
these indicators are discussed in Section B3 of this document.  Table
B-1 contains a synopsis of the site-specific procedures used for total
semivolatile organic compound analysis.

Procedures implemented to ensure total semivolatile organic compound
analysis conducted at INEEL meets quality assurance objectives are
described in the Attachment to the SOW for the INEEL TWCP (DOE 2003a).

B3-7b	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 QC samples are
compared to the criteria listed in Tables B3-6 and B3-7.  These QC
measurements are used to demonstrate acceptable method performance and
to trigger corrective action when control limits are exceeded.

Initially, precision is assessed prior to using the analytical procedure
L-4215, GC/MS Determination of Total SVOCs for WIPP (referred to in this
section as L-4215) for WIPP samples by analyzing a minimum of 7
replicate method performance samples.  The percent Relative Standard
Deviation (%RSD) is calculated for the replicate analyses and compared
to the precision criteria in Table B3-6.  The %RSD must comply with the
criteria before the procedure can be used to analyze WIPP samples. 
These initial analyses fulfill the requirement for “Method Performance
Samples” listed in Table B3-7.

With every sample batch, a MS/MSD sample pair is analyzed.  The
precision within a sample batch is assessed by calculating a relative
percent difference (%RPD) between the MS and MSD results.  The %RPD must
comply with the criteria in Table B3-6.  If the %RPD is not within the
criteria, corrective action is taken.  If the poor precision is traced
to the sample matrix, sample data is flagged with a “Z”, as directed
in WAP Section B3-10 (a nonconformance report is not required when the
problem is traced to the matrix, as specified in Table B3-7).

As stated in Table B3-7, a separate laboratory duplicate analysis is not
required when a MS/MSD pair is analyzed; hence laboratory duplicates are
not used to assess precision.

Replicate low-level method performance samples are analyzed
semi-annually to update MDLs.  The %RSD for the analyses is calculated. 
The %RSD must comply with the criteria in Table B3-6.  If the precision
is not acceptable, the cause of the poor precision must be determined
and corrective action performed.  Further analyses cannot be performed
until acceptable precision is demonstrated through additional replicate
analyses of method performance samples (a minimum of four analyses). 
These analyses fulfill the requirement for “Method Performance
Samples” listed in Table B3-7.

The laboratory also analyzes PDP blind audit samples.  If notified that
the precision of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
precision is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

B3-7c	Accuracy

Accuracy as %R is assessed for the laboratory operations by analyzing
laboratory control samples, matrix spikes, surrogate compounds, and PDP
blind-audit samples.  The results from these measurements for matrix
spikes samples are compared to the %R criteria listed in Table B3-6. 
Results for surrogates and internal standards are evaluated as specified
in SW-846 method (EPA 1996) or Table B3-7.  These QC measurements are
used to demonstrate acceptable method performance and to trigger
corrective action when control limits are exceeded.

Initially, accuracy is assessed prior to using the analytical procedure
L-4215 for WIPP samples by analyzing a minimum of seven replicate method
performance samples.  The average percent recovery (%R) is calculated
for the replicate analyses and compared to the accuracy criteria in
Table B3-6.  The %R must comply with the criteria before the procedure
can be used to analyze WIPP samples.  These initial analyses fulfill the
requirement for “Method Performance Samples” listed in Table B3-7.

With every sample batch, a MS/MSD sample pair is analyzed.  Additionally
System Monitoring Compounds (SMC) are added to every sample.  The
accuracy within a sample batch is assessed by calculating the %R for the
MS and MSD results, and the accuracy within a sample is assessed by
calculating the %R for the SMC compounds.  The %R must comply with the
criteria in Table B3-6.  If a %R is not within the criteria, corrective
action is taken.  If the poor accuracy is traced to the sample matrix,
sample data is flagged with a “Z”, as directed in WAP Section B3-10
(a nonconformance report is not required when the problem is traced to
the matrix, as specified in Table B3-7).

The accuracy within a sample batch is also assessed by calculating the
%R for the LCS, which is analyzed with each batch of samples.  The %R
must comply with the criteria in Table B3-6.  If the %R is not within
the criteria, corrective action is taken.  Samples associated with the
poor LCS must be re-analyzed when the problem is corrected, if the
usability of the results was impacted by the poor LCS recovery.

Replicate low-level method performance samples are analyzed
semi-annually to update MDLs.  The average %R for the analyses is
calculated.  The %R must comply with the criteria in Table B3-6.  If the
accuracy is not acceptable, the cause of the poor accuracy must be
determined and corrective action performed.  Further analyses cannot be
performed until acceptable accuracy is demonstrated through additional
replicate analyses of method performance samples (a minimum of four
analyses).  These analyses fulfill the requirement for “Method
Performance Samples” listed in Table B3-7.

The laboratory also analyzes PDP blind audit samples.  If notified that
the accuracy of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
accuracy is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

Laboratory blanks shall be assessed to determine possible laboratory
contamination and are evaluated as specified in Table B3-7.  These QC
measurements will be used to demonstrate acceptable levels of laboratory
contamination and to trigger corrective action when control limits are
exceeded.

B3-7d	Calibration

GC/MS tunes, initial calibrations, and continuing calibrations are
performed and evaluated using the procedures and criteria specified in
Table B3-6 and Table B3-7.  These criteria are used to demonstrate
acceptable calibration and to trigger corrective action when control
limits are exceeded.

GC/MS tunes, initial calibrations, and continuing calibration are
performed as specified in L-4215 (SVOCs).  L-42151 follows the guidance
provided in SW-846 Method 8270and includes acceptance criteria and
corrective actions to demonstrate that the calibration for an analytical
run is acceptable.

B3-7e	Method Detection Limit

MDLs are expressed in mg/kg for SVOCs.  MDLs are calculated based upon
the guidance provided in SW-846.  Low-level method performance samples
are prepared and analyzed as directed in L-4214, Extraction of Total
SVOCs for GC/MS Analysis for WIPP1; and L-42151.  The data is reduced
and MDLs are calculated using SQA-validated software (SVOC-01-A1).  The
MDLs are determined prior to any samples being analyzed by L-42151, and
annually thereafter.  The measured MDLs will be compared to the required
MDLs listed in Table B3-6.  If the MDLs are not met, corrective action
will be performed and the MDLs re-determined.  Analyses will not proceed
until the MDL criteria are met.

B3-7f	Program Required Quantitation Limit

The laboratory meets the PRQL requirement by following the analytical
procedure L-42151.  At least one of the calibration standards is set at
a concentration less than the PRQLs listed in Table B3-6.  The
concentration of target analytes in the calibration standards is listed
in Section 4 of L-42151.  The concentration of the continuing
calibration standard is also less than the PRQL, as specified in the
same section.

B3-7g	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.  Valid results are defined as results that meet
the data useability criteria based upon application of the Quality
Control Criteria specified in Tables B3-6 and B3-7 and meet the
detection limit, calibration, representativeness, and comparability
criteria within this section.  The laboratory procedure L-42151 includes
strict QC controls to ensure that valid results are obtained for all
sample analyses.  The QC controls are described in the laboratory
procedure.  During the validation of Batch Data Reports by procedure
L-4039, WIPP Data Review and Validation for Semivolatile Organic
Compounds in Solid Samples1 (referred to in this section as L-4039)
completeness is checked and compared to the criteria listed in Table
B3-6.  If the observed completeness is not compliant, corrective action
is taken.  The laboratory will attempt to resolve the problem causing
the non-compliance.  If not possible, a nonconformance will be written.

For RFETS waste analyzed at INEEL, laboratory completeness is evaluated
by the RFETS TWCP Site PQAO. If the observed completeness is not
compliant, corrective action is taken.

B3-7h	Comparability

Consistent use and application of uniform procedures (e.g., standardized
methods traceable standards, etc.) as specified in Section B1 of this
document, and application of data usability criteria [refer to EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999); and EPA 540-R-01-008,
USEPA Contract Laboratory Program National Functional Guidelines for
Inorganic Data Review (EPA 2002)] should ensure that analytical data are
comparable between different analytical facilities.

The laboratory achieves comparability by following standardized methods:

The laboratory analysis is performed by following procedures L-4214
(preparation); and L-42151 (analysis).  These procedure are based upon
SW-846 Methods 3540, 8270, and Method 8082, and meets the QC
requirements listed in Table B3-7.  The most recent promulgated version
of SW-846 may be used.  Changes to SW-846 methodology that result in the
elimination of sample preparation or analytical methods in use at RFETS
are addressed as a corrective action to address the comparability of
data before and after the SW-846 modification.

Batch Data Report verification and validation is performed by following
procedure L-40391 which follows the process outlined in B3-10 of the
WAP.  Completeness is checked and compared against the QAOs listed in
Table B3-6.

Using traceable standards;  As part of the procedure L-42151 the
laboratory uses certified, traceable standards to prepare all QC
standards and solutions.  The source of standards is documented and the
certificates of analysis maintained in the certified standards notebook.

Successful participation in the PDP.

B3-7i	Representativeness

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

B3-8	Total or TCLP Metal Analysis

B3-8a	Quality Assurance Objectives

The QAOs for the TWCP are listed in Table B3-8.  The specified QAOs
represent the required quality of data necessary to draw valid
conclusions regarding TWCP objectives.  QC measurements are used to
demonstrate acceptable method performance and to trigger corrective
action when control limits are exceeded.  A summary of Quality Control
Samples and the associated acceptance criteria are provided in Table
B3-9.  Table B-1 contains a synopsis of the site-specific procedures
used for total metals analysis.  The site-specific processes used to
ensure that the QAOs are met and to assess the data quality indicators
for compliance with the QAOs are discussed below.

Procedures implemented to ensure total metals analysis conducted at
INEEL meets quality assurance objectives are described in the Attachment
to the SOW for the INEEL TWCP (DOE 2003a).

B3-8b	Precision

Precision is assessed through the analysis of laboratory sample
duplicates or laboratory matrix spike duplicates, replicate analyses of
laboratory control samples, and PDP blind-audit samples.  The results of
QC samples are compared to the criteria listed in Tables B3-8 and B3-9. 
These QC measurements are used to demonstrate acceptable method
performance and to trigger corrective action when control limits are
exceeded.

Initially, precision is assessed for WIPP samples by preparing and
analyzing a minimum of 7 replicate method performance samples prior to
using the metals analytical procedures L-4150, Total Metals Acid
Digestion Procedure of Solid, Liquid, and TCLP Extract Sampler; L-4151,
Waste Analysis by Atomic Absorption Spectroscopy1; L-4152, Mercury
Analysis in Waste (Cold-Vapor Technique)1; and L-4153, Trace Metals by
ICP Spectrometry (Solids, Liquids, and TCLP Extracts)1 (referred to in
this section as L-4150, L-4151, L-4152, and L-4153, respectively).  The
percent Relative Standard Deviation (%RSD) is calculated for the
replicate analyses and compared to the precision criteria in Table B3-8.
 The %RSD must comply with the criteria before the procedure can be used
to analyze WIPP samples.  These initial analyses fulfill the requirement
for “Method Performance Samples” listed in Table B3-9.

With every sample batch, a MS/MSD sample pair is analyzed.  The
precision within a sample batch is assessed by calculating a relative
percent difference (%RPD) between the MS and MSD results.  The %RPD must
comply with the criteria in Table B3-8.  If the %RPD is not within the
criteria, corrective action is taken.  If the poor precision is traced
to the sample matrix, sample data is flagged with a “Z”, as directed
in WAP Section B3-10 (a nonconformance report is not required when the
problem is traced to the matrix, as specified in Table B3-9).

As implied in Table B3-9, a separate laboratory duplicate analysis is
not required when a MS/MSD pair is analyzed; hence laboratory duplicates
are not used to assess precision.

Laboratory control samples are analyzed with each batch of samples.   On
a semi-annual basis, the precision of the procedure is assessed by
calculating a %RSD using the data from the last four laboratory control
samples analyzed.  The %RSD must comply with the criteria in Table B3-8.
 If the precision is not acceptable, the cause must be determined and
corrective action performed.  Further analyses cannot be performed until
acceptable precision is demonstrated through additional replicate
analyses of a laboratory control sample.  These analyses fulfill the
requirement for “Method Performance Samples” listed in Table B3-9.

The laboratory also analyzes PDP blind audit samples.  If notified that
the precision of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
precision is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

B3-8c	Accuracy

Accuracy is assessed through the analysis of laboratory matrix spikes,
PDP blind-audit samples, serial dilutions, interference check samples,
and laboratory control samples.  The results of QC samples are compared
to the criteria listed in Tables B3-8 and B3-9.  These QC measurements
are used to demonstrate acceptable method performance and to trigger
corrective action when control limits are exceeded.

Initially, accuracy is assessed prior to using the analytical procedures
L-4150, L-41511, L-41521, and L-41531 for WIPP samples by preparing and
analyzing a minimum of seven replicate method performance samples.  The
average percent recovery (%R) is calculated for the replicate analyses
and compared to the accuracy criteria in Table B3-8.  The %R must comply
with the criteria before the procedure can be used to analyze WIPP
samples.  These initial analyses fulfill the requirement for “Method
Performance Samples” listed in Table B3-9

With every sample batch, a MS/MSD sample pair is analyzed.  The accuracy
within a sample batch is assessed by calculating the %R for the MS and
MSD result.  The %R must comply with the criteria in Table B3-8.  If a
%R is not within the criteria, corrective action is taken.  If the poor
accuracy is traced to the sample matrix, sample data is flagged with a
“Z”, as directed in WAP Section B3-10 (a nonconformance report is
not required when the problem is traced to the matrix, as specified in
Table B3-9).

The accuracy within a sample batch is also assessed by calculating the
%R for the LCS, which is analyzed with each batch of samples.  The %R
must comply with the criteria in Table B3-8.  If the %R is not within
the criteria, corrective action is taken.  Samples associated with the
poor LCS must be re-analyzed when the problem is corrected, if the
usability of the results is impacted by the poor LCS recovery. 
Additionally, on a semi-annual basis, the accuracy of the procedure is
assessed by calculating a %R using the data from the last four
laboratory control samples analyzed.  The %R must comply with the
criteria in Table B3-8.  If the accuracy is not acceptable, the cause
must be determined and corrective action performed.  Further analyses
cannot be performed until acceptable accuracy is demonstrated through
additional replicate analyses of a laboratory control sample.  These
analyses fulfill the requirement for “Method Performance Samples”
listed in Table B3-9.

For ICPES analyses, serial dilution and interference check samples are
analyzed and the accuracy of the results assessed.  The %D between the
results from a sample and its serial dilution is calculated.  It
provides an indication of matrix effects on accuracy.  If the %D values
do not meet the criteria listed in L-41531 a matrix effect is inferred
and the data is flagged with a “Z”.  The criteria listed in L-41531
are based upon the criteria listed in SW-846, Method 6010.  A
nonconformance report 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 to the criteria listed in L-41531, which are
based upon the criteria listed in SW-846 Method 6010.  The %R values
must be acceptable.  If not, the problem must be corrected and the
affected samples re-analyzed.  If data is reported from an analytical
run with unacceptable %R values, a nonconformance report must be
prepared.

The laboratory also analyzes PDP blind audit samples.  If notified that
the accuracy of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
accuracy is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

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.

B3-8d	Calibration

Mass tunes (for ICP MS only), standards calibration, initial calibration
verifications, and continuing calibrations are performed and evaluated
using the procedures and criteria specified in Table B3-8 and Table
B3-9.  These criteria are used to demonstrate acceptable calibration and
to trigger corrective action when control limits are exceeded.

Initial and continuing calibration are performed as specified in L-4151,
L-41521, and L-41531.  These methods follow the guidance provided in
SW-846 Methods 7742, 7471, and 6010, respectively.  The methods include
acceptance criteria and corrective action to demonstrate that the
calibration for an analytical run is acceptable (Section 5 in each
site-specific L procedure).

B3-8e	Program Required Detection Limits

The IDLs for each of the target metals are determined semi-annually by
the appropriate method, as described in L-41511 (Se), L-41521 (Hg), and
L-41531 (Ag, As, Ba, Be, Cd, Cr, Ni, Pb, Sb, Se, Tl, V, Zn).  The IDLs
must be less than or equal to the PRDLs listed in Table B3-8.  If not,
the metal cannot be reported from that method.  An exception is made for
selenium determined by L-41531.  If the selenium concentration is
greater than 5 times the L-4153 IDL, it can be reported from L-4153.

B3-8f	Program Required Quantitation Limit

The laboratory meets the PRQL requirement by following the analytical
procedures L-41511, L-41521, and L-41531.  At least one of the
calibration standards is set at a concentration less than the PRQLs
listed in Table B3-8 (corrected for nominal dilution).  Procedure
L-41531 (Section 5.7) specifies that a CRDL standard be analyzed with
each analytical run, which has target concentrations set at less than
the PRQL (corrected for nominal dilution). 

B3-8g	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.  Valid results are defined as results that meet
the data useability criteria based upon application of the Quality
Control Criteria specified in Tables B3-8 and B3-9 and meet the
detection limit, calibration, representativeness, and comparability
criteria within this section.  The laboratory procedures L-41511,
L-41521, and L-41531 include strict QC controls to ensure that valid
results are obtained for all sample analyses.  The QC controls are
described in the laboratory procedure.  During the validation of Batch
Data Reports by procedure L-4035, Metals Data Verification and
Validation Data Generation Level1 (referred to in this section as
L-4035), completeness is checked and compared to the criteria listed in
Table B3-8.  If the observed completeness is not compliant, corrective
action is taken.  The laboratory will attempt to resolve the problem
causing the non-compliance.  If not possible, a nonconformance will be
written.

For RFETS waste analyzed at INEEL, laboratory completeness is evaluated
by the RFETS TWCP Site PQAO. If the observed completeness is not
compliant, corrective action is taken.

B3-8h	Comparability

Consistent use and application of uniform procedures (e.g., standardized
methods traceable standards, etc.) as specified in Section B1 of this
document, and application of data usability criteria [refer to EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999); and EPA 540-R-01-008,
USEPA Contract Laboratory Program National Functional Guidelines for
Inorganic Data Review (EPA 2002)] should ensure that analytical data are
comparable between different analytical facilities.

The laboratory achieves comparability by following standardized methods:

The laboratory sample preparation and analysis is performed by following
procedures L-4108, L-41501, L-41511, L-41521, and L-41531.  These
procedures are based upon SW-846 Methods 1131, 3050, 7742, 7741, and
6010, and meet the QC requirements listed in Table B3-8.  The most
recent promulgated version of SW-846 may be used.  Changes to SW-846
methodology that result in the elimination of sample preparation or
analytical methods in use at RFETS are addressed as a corrective action
to address the comparability of data before and after the SW-846
modification.

Batch Data Report verification and validation is performed by following
procedure L-40351, which follows the process outlined in B3-10 of the
WAP.  Completeness is checked and compared against the QAOs listed in
Table B3-9.

Using traceable standards;  As part of the procedures L-41511, L-41521,
and L-41531, the laboratory uses certified, traceable standards to
prepare all QC standards and solutions.  The source of standards is
documented and the certificates of analysis maintained in the certified
standards notebook.

Successful participation in the PDP program.

B3-8i	Representativeness

Representativeness for metals analysis is achieved by collecting
unbiased samples and the preparation of samples in the laboratory using
representative and unbiased methods.  Samples are collected as described
in Section B1-2.

B3-9	Acceptable Knowledge

Acceptable knowledge documentation provides primarily qualitative
information that cannot be assessed according to specific data quality
goals that are 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 acceptable knowledge (refer to Section B4-3 and Section B4-4). To
ensure that the acceptable knowledge process is consistently applied,
RFETS to complies with the following data quality requirements for
acceptable knowledge 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 acceptable
knowledge documentation, do not lend themselves to statistical
evaluations of precision.  However, the acceptable knowledge information
will be addressed by the independent review of acceptable knowledge
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
which require reassignment to a new Waste Matrix Code and/or designation
of different hazardous waste codes based an the reevaluation of
acceptable knowledge and sampling and analysis data will be reported as
a measure of acceptable knowledge 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 useable through the data validation process.  The
acceptable knowledge record must contain 100 percent of the required
information (Permit Attachment B4-3).  The usability of the acceptable
knowledge information will be assessed for completeness during audits.

Comparability - Data are considered comparable when one set of data can
be compared to another set of data.  Comparability is ensured through
the various sites meeting the training requirements and complying with
the minimum standards outlined for procedures that are used to implement
the acceptable knowledge process.  All sites must assign hazardous waste
codes in accordance with Permit Attachment B4-4 and provide this
information regarding its waste 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 that the process of obtaining, evaluating, and
documenting acceptable knowledge information is performed in accordance
with the minimum standards established in Permit Attachment B4.  Sites
also must assess and document the limitations of the acceptable
knowledge information used to assign hazardous waste codes (e.g.,
purpose and scope of information, date of publication, type and extent
to which waste parameters are addressed).

RFETS complies with the nonconformance notification and reporting
requirements of Section B3-1 if the results of confirmatory analytical
techniques specified in Section B are inconsistent with acceptable
knowledge documentation.

RFETS addresses quality control by tracking its performance with regard
to the use of acceptable knowledge by: 1) assessing the frequency of
inconsistencies among information, and 2) documenting the results of
acceptable knowledge confirmation through RTR, visual examination,
headspace gas analyses, and solidified waste analyses.  In addition, the
acceptable knowledge process and waste stream documentation are
evaluated through internal assessments by quality assurance
organizations and assessments by auditors external to the organization.

B3-10	Data Review, Validation, and Verification Requirements

Procedures exist for the review, validation, and verification of data at
the data generation level and the validation and verification of data at
the project level.

As described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a), the INEEL TWCP conducts the data generation level data review,
validation, and verification activities for RFETS waste solid sampled
and analyzed at INEEL.

Data review determines if raw data have been properly collected and
ensures raw data are properly reduced.  Data validation confirms that
the data reported satisfy 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 that the data have been appropriately reviewed.

Data from testing, sampling, and analytical operations is compiled at
the generation level, and reported to the TWCP Project Office as
testing, sampling, or analytical batch reports.  Batch Data Reports are
generated for data validation, verification, and quality assurance
activities.

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

A Testing Batch Data Report or equivalent includes all data pertaining
to any of the following:

	Radiography 

Visual Examination (to Confirm RTR)

Visual Verification of AK 

Radioassay [refer to the TWMM, Appendix 4]

Note:  Radioassay Batch Data Reporting requirements are specified in the
WIPP-WAC.  RFETS compliance with these requirements for NDA are
addressed in the TWMM.

A Testing Batch Data Report or equivalent includes all data for up to 20
waste containers without regard to waste matrix.  Table B3-11 lists the
information required in Testing Batch Data Reports (identified with an
“X”), and lists 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 headspace gas
or homogeneous waste samples that were collected for chemical analysis. 
Table B3-12 lists the information required in Sampling Batch Data
Reports (identified with an “X”), and lists other information that
is necessary for data validation, but is optional in Sampling Batch Data
Reports (identified with an “O”).

B3-10	Data Review, Validation, and Verification Requirements 
(continued)

An Analytical Batch Data Report or equivalent includes analytical data
from the analysis of TRU-mixed waste for up to 20 headspace gas 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 the
information required in Analytical Batch Data Reports (identified with
an “X”), and lists 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 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, re-analysis, or dilution
information pertaining to the individual samples. Raw data may also
include calibration 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.

On-line Batch Data Reports or equivalent contain the combined
information from the Sampling Batch Data Report and Analytical Batch
Data Report that is relevant to the on-line method used. An On-Line
Sampling Data Report or equivalent includes all field data pertaining to
a group of  samples collected within a 12-hour period using the same
on-line integrated analysis system.  An On-Line Analytical Batch Data
Report or equivalent includes analytical and on-line data from the
sampling and analysis of samples collected within a 12-hour period using
the same on-line integrated analysis system.

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 the data, or an unalterable electronic signature is used. 
For instrument printouts, the data generator is identified on the
printout.

All data are recorded clearly, legibly, and accurately in field and
headspace or laboratory records (bench sheets, logbooks, or qualified
electronic format), 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 may also be included (if not readily apparent); the original data
is not obliterated or otherwise disfigured so as not to be readable; and
data changes are made by the individual who originally collected the
data or an authorized supervisory representative from the same
department.

B3-10a	Data Generation Level (cont)

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

All field and headspace or laboratory records are maintained in
permanent files as specified in Table B-7 of this document.

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

All electronic and video data are stored appropriately to ensure that
waste container data, sample data, and associated QC data are
retrievable.  In the case of classified information, additional security
provisions may apply that could restrict retrievability.  The additional
security provisions are documented in RFETS procedures as outlined in
this QAPjP in accordance with 1-MAN-026, Rocky Flats Environmental
Technology Site Security Manual.

Data review, validation, and verification at the data generation level
involves scrutiny and signature release from qualified independent
technical reviewer(s), technical supervisor(s), and a QA Officer (or
designee) as specified below.  Nonconformances identified during data
validation and verification at the generation level are documented using
1-A65-ADM-15.01, Control of Nonconforming Items.  Individuals conducting
this data review, validation, and verification must use approved
checklists that address all of the items included in this section. 
Checklists contain or reference tables showing the results of sampling,
analytical or on-line batch QC samples, if applicable.  Checklists
reflect review of all QC samples and quality assurance objective
categories in accordance with criteria established 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 data must be available and reviewed by the data generation
level reviewer.

Changes to Batch Data Reports, occurring after submittal to the Waste
Records Center, which impact characterization data will require
re-evaluation.  Inconsistencies, mistakes, or omissions identified in
Batch Data Reports that do not impact characterization data do not
require re-verification by the data generation level QA Officer (or
designee). Inconsistencies, mistakes, or omissions identified in Batch
Data Reports that impact characterization data (this includes
Nonconformances with a use-as-is disposition) shall be re-evaluated by
the Technical Supervisor and data generation level QA Officer (or
designee).  Nonconformances with rework disposition issued to Batch Data
Reports shall be revalidated by an Independent Technical Reviewer,
Technical Supervisor, and data generation level QA Officer (or
designee).  Nonconformances with scrap disposition issued to Batch Data
Reports do not require data generation level revalidation.

Data generation level review, validation, and verification for RFETS
waste sampled and analyzed at INEEL is conducted as described in the
Attachment to the SOW for the INEEL TWCP (DOE 2003a).  Batch Data Report
and raw analytical data submittal to the RFETS TWCP, and changes to
Batch Data Reports, are transmitted in hard copy format.

Table B-1 provides a list of procedures used to implement the
requirements of this section.  The list is not comprehensive. 
Additional procedures are found in Section D-2, RFETS References.

B3-10a(1)	Independent Technical Review

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 documented by the
originator.

One hundred percent of the Batch Data Reports receive a documented
independent technical review.  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 in order to determine and correct negative quality
trends in the sampling or analytical process.  However, at a minimum,
the independent technical review must be performed before any waste
associated with data reviewed is shipped to the WIPP facility.  The
reviewer(s) release the data as evidenced by signature.  This signature
release ensures the following:

Data generation and reduction were conducted in a technically correct
manner in accordance with the method used (procedure with revision or
version).  Data was reported in the proper units and 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 that are not verified to within rounding or
significant difference discrepancies must be rectified prior to
completion of the independent technical review.

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, QC sample results, and copies or originals of the
gas canister sample tags.  Corrective action is taken to ensure that all
Batch Data Reports are complete and include all necessary raw data prior
to completion of the independent technical review.

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

For RFETS waste sampled and analyzed at INEEL, data useability criteria
and laboratory completeness is evaluated at the project level.

Reporting flags were assigned correctly (refer to Table B3-14).

Sample holding time and preservation requirements were met, or
exceptions documented (as applicable).

RTR tapes were reviewed (independent observation), on a waste container
basis at a minimum of once per testing batch, or once per day of
operation, whichever is less frequent [Section B1-3b(2)].  The RTR tape
will be reviewed against the reported data on the RTR form to ensure
that the data are correct and complete.

Field sampling records are complete (if applicable).  Incomplete or
incorrect field sampling records will be subject to re-submittal prior
to completion of the independent technical review.

Table B-1 provides a list of procedures used to implement the
requirements of this section.  The list is not comprehensive. 
Additional procedures are found in Section D-2, RFETS References.

B3-10a(2)	Technical Supervisor Review

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 office review.

One hundred percent of the Batch Data Reports receive technical
supervisory signature release.  The technical supervisory signature
release occurs as soon as practicably possible after the independent
technical review in order to determine and correct negative quality
trends in the sampling or analytical process.  However, at a minimum,
the technical supervisory signature release must be performed before any
waste associated with data reviewed is shipped to the WIPP facility. 
This signature release ensures the following:

The data are technically reasonable based on the technique used.

The data received independent technical review with the exception of RTR
tapes, which receive periodic technical reviews as specified above
(refer to Section B1-3b(2) of this document).

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,
equipment calibration records, QC sample results, and original or copies
of the gas sample canister tags.

Sample holding time requirements were met, or exceptions documented (if
applicable).

Field sampling records are complete (if applicable).

B3-10a(3)	QA Officer Review

The data generation level QA review ensures that the 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.

Each functional area that generates data for the TWCP (e.g., headspace,
laboratories, Radiography, etc.) designates a QA Officer.  One hundred
percent of the Batch Data Reports receive QA officer (or designee)
signature release.  The QA Officer signature release occurs as soon as
practicably possible after the technical supervisory signature release
in order to determine and correct negative quality trends in the
sampling or analytical process.  However, at a minimum, the QA Officer
signature release must be performed before any waste associated with
data reviewed is shipped to the WIPP facility. This signature release
ensures the following:

Independent technical and supervisory reviews were performed as
evidenced by the appropriate signature releases.

The QA documentation for Batch Data Reports is completed as appropriate
for the point of data generation.

Sampling and headspace or laboratory QC checks were properly performed. 
QC criteria that were not met are documented.

The applicable QAOs have been met (refer to the methods outlined in
Section B3-11).

B3-10b	Project Level

Data review, validation, and verification at this level involves
scrutiny and signature release from the TWCP Site PM (or designee) and
the TWCP Site PQAO (or designee). The procedure PRO-940-WIPP-010, Waste
Characterization Project Level Data Review and Reporting, describes this
process in detail.  Any nonconformance identified during this process
shall be documented on a nonconformance report (refer to Section B3-13).

The TWCP Site PM and TWCP Site PQAO 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 documents that the data generation
level review, validation, and verification is being performed according
to implementing procedures.

Changes to Batch Data Reports, occurring after submittal to the Waste
Records Center, which impact characterization data will require
re-evaluation.  Upon identification, all inconsistencies, mistakes, or
omissions in Batch Data Reports shall be reported to the data validation
level QA Officer (or designee).  Corrections of inconsistencies,
mistakes, or omissions to Batch Data Reports that do not impact
characterization data shall be verified by the TWCP Site PQAO (or
designee). Corrected inconsistencies, mistakes, or omissions that impact
characterization data (this includes Nonconformances with a use-as-is
disposition) shall be re-evaluated by the TWCP Site PQAO (or designee)
and the TWCP Site PM (or designee).  Nonconformances with rework
disposition issued to Batch Data Reports shall be revalidated by the
TWCP Site PQAO (or designee) and the TWCP Site PM (or designee). 
Nonconformances with scrap disposition issued to Batch Data Reports
shall be revalidated by the TWCP Site PQAO (or designee).

B3-10b(1)	TWCP Site PQAO Review

The TWCP Site PQAO review ensures that the Batch Data Reports received
from the data generation level is complete, validates and verifies that
the QC checks were done properly and meet program criteria, and ensures
that the QAOs have been met.

One hundred percent of the Batch Data Reports receive TWCP Site PQAO
signature release.  The TWCP Site PQAO signature release occurs as soon
as practicably possible in order to determine and correct negative
quality trends in the sampling or analytical process.

However, at a minimum, the TWCP Site PQAO signature release must be
performed before any waste associated with the data reviewed is shipped
to the WIPP facility.  This signature release ensures the following:

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

Sampling batch QC checks (e.g., equipment blanks, field duplicates,
field reference standards) were properly performed, and 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 Section B1-3b(2).

Analytical QC checks (e.g., laboratory duplicates, laboratory blanks,
matrix spikes, matrix spike duplicates, laboratory control samples) were
properly performed and 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 and 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.

B3-10b(2)	TWCP Site PM Review

The TWCP Site PM 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.

One hundred percent of the Batch Data Reports have a TWCP Site PM
signature release.    The TWCP Site PM signature release occurs as soon
as practicably possible after the TWCP Site PQAO signature release in
order to determine and correct negative quality trends in the sampling
or analytical process.  However, at a minimum, the TWCP Site PM
signature release must be performed before any waste associated with the
data reviewed is shipped to the WIPP facility.  This signature release
ensures the following:

The TWCP Site PM or designee determines the validity of the DAC
assignment made at the data generation level based upon an assessment of
the data collection and evaluation necessary to make the assignment.

Data generation level independent technical, technical supervisory, and
QA officer (or designee) review, validation, and verification have been
performed as evidenced by the completed review checklists and
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 correct units, with correct number of significant
figures, and with qualifying flags).

Verify that data are within established data assessment criteria and 
meet all applicable QAOs (Section B3-11).

B3-10b(3)	Preparation of theTWCP Site PQAO Summary and the TWCP Site PM
Data Validation Summary

To document the project level validation and verification described
above, the TWCP Site PQAO (or designee) prepares a TWCP Site PQAO
Summary, and the TWCP Site PM (or designee) prepares a Data Validation
Summary.  These reports are combined and incorporated into the TWCP Site
PQAO and TWCP Site PM checklists  to eliminate redundancy.  The TWCP
Site PQAO Summary includes a validation checklist for each Batch Data
Report.  Checklists for the TWCP Site PQAO Summary are sufficiently
detailed to validate all aspects of a Batch Data Report that affect data
quality.

The TWCP Site PM Data Validation Summary provides confirmation that, on
a per waste container basis as evidenced by Batch Data Report reviews,
all data have been validated in accordance with this document.  The Data
Validation Summary identifies each Batch Data Report reviewed (including
all waste container numbers), describes how the validation was performed
and whether or not problems were detected (e.g. nonconformance reports),
and includes a statement indicating that all data are acceptable. 
Summaries include release signatures.

B3-10b(4)	Preparation of the Waste Stream Characterization Package

In the event that the WIPP facility requests detailed information on a
waste stream, RFETS will provide a Waste Stream Characterization Package
prepared in accordance with PRO-484-WIPP-003, Collection, Review, and
Confirmation of Acceptable Knowledge Documentation.  The TWCP Site PM
can require each characterization area, data generation level technical
supervisor, and QA Officer to assist in the preparation and review of
the Waste Stream Characterization Package (Section B3-12b(3)) as
necessary to ensure the package will support the TWCP Site PM’s waste
characterization determinations.

B3-10b(5)	Sample Disposition

Once the data have received project level validation and verification or
when the TWCP Site PM decides the sample no longer needs to be retained,
the TWCP Site PM 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, copied, and the copies are retained in
the project files before recycling the canisters.  If the TWCP Site PM
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 cross-referenced to documentation which specifies the
purpose for sample or canister retention.

B3-11	Reconciliation with Data Quality Objectives

Reconciling the results of waste testing and analysis with the DQOs
provides a way to ensure that data is of adequate quality to support the
regulatory compliance programs.  Reconciliation with the DQOs takes
place at both the project level and the WIPP facility.  At the project
level, reconciliation is performed by the TWCP Site PM (or designee),
and submitted to the WIPP facility for review and approval.

B3-11a	Reconciliation at the Project Level

The TWCP Site PM ensures that all data generated and used in decision
making meet the DQOs provided in Section B-4a(1) of this document.  The
TWCP Site PM assesses whether data of sufficient type, quality, and
quantity have been collected.  The TWCP Site PM determines if the
variability of the data set is small enough to provide the required
confidence in the results.

The TWCP Site PM 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 TWCP Site PM
documents that random sampling of containers was performed for the
purposes of waste stream characterization.

The TWCP Site PM determines if sufficient data have been collected to
determine the following WAP-required waste parameters as applicable:

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.

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 limit.

Whether a sufficient number of waste containers were visually examined
(to Confirm RTR) to determine with a reasonable level of certainty that
the UCL90 of the average miscertification rate is less than 14%.

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

B3-11a	Reconciliation at the Project Level  (continued)

Whether all TICs were appropriately identified and reported in
accordance with the requirements of Section B3-1 prior to submittal of a
WSPF for a waste stream or waste stream lot.

Whether the overall completeness, comparability, and representativeness
QAOs were met for each of the analytical and testing procedures as
specified in Sections B3-2 through B3-9 prior to submittal of a WSPF for
a waste stream or waste stream lot.

Whether the PRQLs for all analyses were met prior to submittal of a WSPF
for a waste stream or waste stream lot.

If the TWCP Site PM determines that 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 prior to submittal of the Waste Stream Profile Form
for that waste stream, preventing disposal of TRU mixed waste at WIPP
unless the TWCP Site PM determines that the WAP-required waste
parameters listed above have been met.  For subsequent shipments, data
reconciliation is done on all containers or samples prior to shipment to
WIPP.

The statistical procedure presented in Section B2 of this document and
in 95-WP/SAP-001, Transuranic (TRU/TRM) Waste Sampling Plan, is used to
evaluate and report waste characterization data from the analysis of
homogeneous solids and soil/gravel.  The procedure, which calculates
UCL90 values, is used to assess compliance with the DQOs presented in
Section B-4a(1), as well as with RCRA regulations.  The procedure is
applied 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 of the appropriate metals and organic compounds is expressed as
toxicity characteristic leaching procedure (TCLP) values or results may
also be compared to the TC levels expressed as total values.  These
total values are the regulatory threshold limit (RTL) values, and 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 TCLP extract), assuming 100-percent analyte
dissolution.  The RTLs are presented in Table B3-15.

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 the WIPP facility.

B3-12a	Data Generation Level to the Project Level 

Data are transmitted by hard copy or electronically (hard copy is
available on demand) from the data generation level to the project level
(PDCO).  Transmitted data includes Batch Data Reports, and data review
checklists.

Data generating organizations are responsible to ensure that correct and
current characterization information is forwarded to the TWCP project
office if new or duplicate readings or tests are taken.  This
responsibility includes modifying all Batch Data Reports or WEMS
database records impacted by the changed characterization information. 
Data generating organizations are required to document the duplicate
record condition, and the actions that are required to reconcile the
affected records and databases, through specific procedural instructions
and/or a Nonconformance report. In all cases the TWCP Site PQAO shall be
notified in writing, along with the affected record or database
management organizations. The Batch Data Reports and checklists used
contain all of 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 as described in Section B3-10.  Batch Data Reports and
checklists are in approved formats as provided in RFETS procedures.

Data for RFETS waste sampled and analyzed at INEEL, including updated
and modified Batch Data Reports are transmitted from the INEEL TWCP in
hard copy format.  The Batch Data Reports and checklists contain all of
the information described in the Attachment to the SOW for the INEEL
TWCP (DOE 2003a).

After review by the TWCP Site PQAO, all Batch Data Reports are forwarded
to the TWCP Site PM.  All Batch Data Reports are assigned serial
numbers, and each page is numbered. The serial number is the same as the
testing, sampling, or analytical batch number. 

QA documentation including raw data are maintained in either testing,
sampling, and analytical facility files, or TWCP project files in
accordance with the document storage requirements presented in Section B
and Section B5 of this document. Contract waste characterization
facilities forward their testing, sampling, and analytical QA
documentation along with Batch Data Reports to the TWCP Project Office
for inclusion in TWCP central files.

B3-12b	Project Level to DOE/CBFO Level

The TWCP office prepares a WSPF for each waste stream to be certified
for shipment to WIPP based on information obtained from Batch Data
Reports.  In addition the TWCP office ensures the Characterization
Information Summary and the Waste Stream Characterization Package (when
requested by the WIPP facility) are prepared as appropriate. The TWCP
Site QAO verifies these reports are consistent with information found in
analytical batch reports. Summarized testing, sampling, and analytical
characterization data are included in 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.

B3-12b	Project Level to DOE/CBFO Level (continued)

After approval of a WSPF and the associated Characterization Information
Summary by the WIPP facility, RFETS maintains a cross-reference of
container identification numbers to each Batch Data Report.

Prior to shipment of waste to the WIPP facility, RFETS transmits data on
an individual container basis to the WIPP facility using the WIPP Waste
Information System (WWIS).  Procedures PRO-944-WIPP-008, Completion of
Waste Stream Profile Form for Waste to be Disposed of at WIPP;
4-K47-WEM-WP1210, WEMS Offsite Shipping Module; and 4-G83-WEM-WP-1209,
WEMS Waste Package Verification and Certification, describe the method
used to report data from the project level to the CBFO level.

B3-12b(1)	Waste Stream Profile Form 

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

A description of the waste stream

Applicable EPA hazardous waste codes

Applicable TRUCON codes

A listing of acceptable knowledge documentation used to identify the
waste stream

The waste characterization procedures used and the reference and date of
the procedure

Certification signature of TWCP Site PM, name, title, and date signed

B3-12b(2)	Characterization Information Summary

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.

RTR and VE summary to document that prohibited items are not present,
including waste exhibiting the characteristics of ignitability,
corrosivity, and reactivity, to confirm AK; and documentation and
justification for the use of radiography in lieu of or in combination
with VE/VV for newly generated waste (see Section B4-2b).

A complete listing of all container identification numbers used to
generate the WSPF, cross-referenced to each Batch Data Report

Compelete AK Summary including waste stream name, waste stream number,
point of generation, waste stream volume (current and projected),
generation dates, TRUCON codes, Summary Category Group, Waste Matrix
Code(s) and Waste Matrix Code Group, other TWBIR information, waste
stream description, areas of operation, generating processes, RCRA
determinations, radionuclide information, all references used to
generate the AK summary, and any other information required by Section
B4-2b.

Certification through AK or testing and/or analysis that any waste
assigned the hazardous waste number U134 (hydrofluoric acid) no longer
exhibits the characteristic of corrosivity.  This is confirmed by
assuring that no liquid is present in U134 waste.

B3-12b(3)	Waste Stream Characterization Package

The Waste Stream Characterization Package consists of the following:

WSPF (Section B3-12b(1))

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

Complete AK summary (Section B3-12b(2))

Batch Data Reports supporting the confirmation of AK as well as other
Batch Data Reports requested by the WIPP facility

Raw analytical data requested by the WIPP facility

B3-12c	WIPP Waste Information System (WWIS) 

The WWIS Data Fields (Table B-8) contain all of the data, the field
format and the limits associated with the data as established by Section
B-1c of this document.  These data are subject to edit and limit checks
that are performed automatically by the database as defined in the WIPP
Waste Information System User’s Manual for Use by Shippers/Generators
(DOE 2001).  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 any
associated TICs, for every waste container associated with the composite
sample.  RFETS coordinates the data transmission with the WIPP facility.

B3-13	Nonconformances and Corrective Actions 

The status of TWCP work activities are monitored and controlled by the
TWCP Site PM and the TWCP Site PQAO through the RFETS quality
improvement and corrective action process.  This includes nonconformance
identification, documentation, and reporting, as well as the monitoring
of Nonconformance Reports (NCRs).

The nonconformances and corrective action processes specified in this
section describe site-specific nonconformance procedures and
communication with the WIPP facility concerning nonconformance tracking
and resolution.  RFETS complies with the nonconformance requirements
specified in Section B3-1 of this document.

B3-13a	Nonconformances 

Nonconformances are uncontrolled and unapproved deviations from an
approved plan or procedure. Nonconforming items and activities are those
that do not meet the TWCP requirements, procurement document criteria,
or approved work procedures.   RFETS personnel are responsible for
promptly reporting any nonconformance condition identified as adverse to
quality to management.  When a nonconformance related to the TWCP is
observed or detected, the TWCP Site PM and the TWCP Site PQAO are
notified, and involved management review the content of the NCRs and
assist RFETS QA and/or WC&O in processing the TWCP related NCR.

B3-13a	Nonconformances (continued)

RFETS identifies and documents nonconformances in accordance with the
QAPD as follows:

Nonconforming items are addressed in 1-A65-ADM-15.01, Control of
Nonconforming Items.  This procedure describes the methods to identify,
control, and dispose of nonconforming items (nonconforming items are
identified by marking, tagging, or segregating the items).  The
procedure also assigns responsibilities to RFETS organizations and
personnel to identify, report, control, evaluate the nonconformances,
obtain and document a disposition, determine cause, and define
corrective action for reported nonconforming items.  This procedure is
used for nonconformances identified during data generation level data
review.  This procedure refers to PRO-U76-WC-4030, Control of Waste
Nonconformances, for waste package nonconformances.

Waste nonconformances are addressed in PRO-U76-WC-4030, Control of Waste
Nonconformances.  WC&O has the responsibility for reviewing all
nonconformance reports for waste containers.  The procedure assigns
responsibilities to RFETS organizations and personnel to identify,
report, control, evaluate the nonconformances, obtain and document a
disposition, determine cause, and define corrective action for reported
nonconforming items.  This procedure is used for nonconformances
identified during data generation level data review.

Nonconformances identified during project level data review and
reporting are addressed in PRO-940-WIPP-010, WIPP TRU Waste
Characterization Project Level Data Review and Reporting.

1-V10-ADM-15.02, Stop Work Action, describes the stop work methodology
(and its applicability) when the work is not in compliance governing
quality requirements.  Under specified emergency conditions, the TWCP
Site PM or the TWCP Site PQAO, working with appropriate management may
issue stop work orders.  Requirements for the resolution and release of
stop work orders are also defined in the procedure.

Management at all levels fosters a "no-fault" attitude to encourage the
identification of nonconforming items and processes.  Nonconformances
may be detected and identified by anyone performing WAP activities,
including:

Project staff - during field operations, supervision of subcontractors,
data validation and verification, and self-assessment.

Laboratory and Headspace staff - during the preparation for and
performance of testing; calibration of equipment; QC activities; data
review, validation, and verification; and self-assessment.

QA personnel - during oversight activities or audits.

B3-13a	Nonconformances   (continued)

An NCR is prepared for each nonconformance identified.  Each NCR is
initiated by the individual(s) identifying the nonconformance.  The NCR
is processed by knowledgeable and appropriate personnel, includes or
references as appropriate, results of headspace or laboratory analysis,
QC tests, audit reports, internal memoranda, or letters.  The NCR
provides the following information:

Identification of the individual(s) identifying or originating the
nonconformance.

Description of the nonconformance.

Method(s) or suggestions for correcting the nonconformance (corrective
action).

Schedule for completing the corrective action.

An indication of the potential ramifications and overall usability of
the data, if applicable.

Any approval signatures specified in the RFETS nonconformance
procedures.

The TWCP Site PQAO oversees the NCR process.  The completion
verification of NCRs is delegated to the appropriate quality engineering
or waste inspection organization as defined in implementing procedures. 
Nonconformances are tracked and trended as described in
PRO-943-WIPP-007, TWCP Trending and Analysis of Quality-Affecting
Problems.  This process analyzes trends in NCRs month-to-month by point
or process origin and by category.  An evaluation is conducted to
determine if there are significant conditions adverse to quality; if
indicated, additional cause analysis and corrective actions are taken in
accordance with site-specific corrective action procedures.  The TWCP
Site PM ensures that proper project personnel are notified of
nonconformances by review and approval of implementing NCR procedures. 
The site-specific NCR procedures designate the organizations responsible
to approve and complete necessary corrective actions.  The TWCP Site
PQAO provides written notification to the WIPP facility of all
non-administrative nonconformances (i.e., a failure to meet a DQO) first
identified during the TWCP Site PM review level within five (5) days of
identification and validation.  The TWCP Site PQAO then provides a
nonconformance report to CBFO within thirty (30) days of identification.
 This process is described in PRO-940-WIPP-010, WIPP TRU Waste
Characterization Project Level Data Review and Reporting.  NCR
documentation is made available to the TWCP Site PM per
PRO-943-WIPP-007, TWCP Trending and Analysis of Quality-Affecting
Problems.

As described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a), the RFETS TWCP is notified of NCRs related to sampling and
analysis of RFETS waste at INEEL.  The NCRs are evaluated by the TWCP
Site PQAO.

B3-13b	Corrective Actions 

The quality systems established for corrective action and their
reporting are described in Section 3.1.3 of 1-MAN-008-WM-001,
Transuranic (TRU) Waste Management Manual.  The disposition of
nonconformances is identified and documented.  RFETS implements
corrective action and resolves the identified nonconformance prior to
the shipment of the TRU mixed waste to the WIPP facility.  Completion of
corrective actions for nonconformances is verified by the TWCP Site PQAO
or by independent RFETS QA personnel.

The TWCP Site PQAO coordinates the processing of corrective actions and
NCRs from CBFO.  This process includes:

Entering them into the Plant Action Tracking System (PATS) for tracking
(refer to 3-X31-CAP-001, Corrective Action Process).

Evaluating the extent and cause of the deficiency.

Providing a response (via the TWCP Site PM) to CBFO that addresses
remedial actions and actions to preclude recurrence.

Ensuring that corrective action plans properly address CBFO accepted
remedial actions and actions to preclude recurrence of the condition.

B3-14	Special Training Requirements and Certification

Before performing activities that affect WAP quality, all personnel
receive indoctrination into the applicable scope, purpose, and
objectives of the WAP and the specific QAOs of the assigned task.
Personnel assigned to perform activities for the 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 WAP maintain qualification
(i.e., training and certification) throughout the duration of the work
as specified in this WAP and applicable QAPjPs/procedures. Job
performance is evaluated and documented at periodic intervals, as
specified in the implementing procedures.

Personnel involved in WAP activities receive continuing training to
ensure that job proficiency is maintained.  Training includes both
education in principles and enhancement of skills.  RFETS procedures for
implementing personnel qualification and training include the TWCP TIP,
and 5-NDT-TC-1A, Training, Qualification, and Certification of
Nondestructive Testing Personnel, specifically for RTR personnel.  All
training records that specify the scope of the training, the date of
completion, and documentation of job proficiency are maintained as QA
Records in the TWCP project file.

The Headspace Analytical Services and Analytical Laboratories line
management ensures that analytical personnel are qualified to perform
the analytical method(s) for which they are responsible. The minimum
qualifications for certain specified positions for the WAP are
summarized in Table B3-10.  Section B1-3b specifies the site-specific
title of the personnel who perform the applicable radiography methods as
radiography operators.  For the analytical positions in Table B3-10, the
site-specific titles are presented for each analytical method in the
TWCP TIP, Appendix 4 – Analysis Processes.  The TWCP TIP, Section 7.8,
Records Processing Instructions, contains the requirements for
maintaining records of the qualification, training, and demonstration of
proficiency by these radiography, headspace, and laboratory personnel.

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 current resume
of the person (refer to the TWCP TIP, Section 7.1, Job Analyses and
Training Needs Assessment and Section 7.2, Personnel Selection and
Assignment). This evaluation is also performed for personnel who change
positions because of a transfer or promotion as well as personnel
assigned to short-term or temporary work assignments that may affect the
quality of the WAP.  The TWCP TIP (refer to Section 5, TWCP
Organization, Responsibilities, and Authorities; and Section 7.6,
Continuing Training) identifies the responsible person(s) for ensuring
that all personnel maintain proficiency in the work performed and
identifies any additional training that may be required.

B3-15	This section has been deleted

Section B5-2 addresses RFETS compliance with Section B3-15 of the WAP.

B3-16	Hydrogen and Methane Analysis

This section identifies the required QA elements for the analysis of
hydrogen and methane in gas samples. The site-specific QAOs for hydrogen
and methane analysis are listed in Table B3-16A.  Table B-1 contains a
synopsis of the site-specific procedures used for headspace gas sampling
and for hydrogen and methane analysis.

B3-16a	Methods Requirements 

The method used by RFETS Headspace Analytical Services and Analytical
Laboratories for the analysis of hydrogen and methane is described in
PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System; L-4231, Headspace Gas Sampling and Analysis Using an
Automated Manifold; and L-2421, Precision Gas Mass Spectrometry
Operations and Analyses (VG 30-38).  Hydrogen and methane concentrations
are reported as volume percent and calculated from the partial pressures
of hydrogen and methane in a sample.

Primary hydrogen and methane standards are purchased from the best
available source (Scott Specialty Gases or equivalent).  The
manufacturer certifies all commercial standards used in this analysis.

B3-16b	Quality Control

Qualitative and quantitative acceptance criteria for the quality control
checks are specified in PRO-1669-HGAS-V&V, Headspace Gas V&V (Data
Generator Level); L-4053, Headspace Gas V & V (Data Generator Level);
and L-5016, Data Review and Validation for Inorganic Gases for WIPP-TRU
Waste Characterization Program (TWCP) – Data Generation Level2.

The HASQAO or LPQAO is responsible for monitoring and documenting
procedural performance, including the analysis of blanks and duplicates.
 The HASQAO or LPQAO and the technical supervisor are responsible for
the implementation of corrective actions if acceptable performance is
not obtained.  A nonconformance report is required only if the final,
reported QC sample results do not meet acceptance criteria.

Headspace Analytical Services and the Analytical Laboratories operate
under a formal quality control program and maintain records to document
the quality of data generated.  All quality control elements established
by the TWCP are implemented with headspace and laboratory procedures,
including method performance samples, laboratory duplicates, laboratory
blanks, and blind audit samples.  Specific quality control samples and
frequencies are summarized in Table B3-16B

Method performance samples are used to demonstrate acceptable headspace
performance prior to the analysis of any samples.  Initially, a minimum
of seven replicate performance samples is analyzed to demonstrate
acceptable precision and accuracy, and to determine MDLs for hydrogen
and methane. 

The same procedure used to prepare gas samples for analysis is also used
to prepare the blanks.  Analyses of blanks are acceptable if analyte
concentrations are less than three times the analyte MDLs.

B3-16c	Instrument Testing, Inspection, and Maintenance Requirements

Headspace Analytical Services personnel ensure that its analytical
instruments are tested, inspected, and maintained in such a manner that
the quality assurance objectives in Table B3-16A are met.



Table B3-1, Physical form of waste (waste material parameter) 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.

Other Inorganic Materials	Non-metallic inorganic waste, including
concrete, glass, firebrick, ceramics, sand, and inorganic sorbents.

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

Rubber	Natural or man-made elastic latex materials, e.g., surgeon’s
gloves, leaded rubber gloves, etc.

Plastics (Waste Materials)	Generally man-made materials, often derived
from petroleum feedstock, e.g., 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 which are solidified with cement silicate, or
other solidification agents, e.g., waste water treatment sludge,
cemented aqueous liquids, and inorganic particulates, etc.

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

Steel (Packaging Materials)	208-liter (55-gallon) drums.

Plastics (Packaging Materials)	90 mm polyethylene drum liner and plastic
bags.

Source:	Waste Isolation Pilot Plant Transuranic Waste Baseline Inventory
Report (DOE 1995b)



Table B3-2, Gas Volatile Organic Compounds Target Analyte List and
Quality Assurance Objectives

When Using SUMMA® Canisters or On-Line Systems

COMPOUND	

CAS NUMBER	PRECISIONa (%RSD OR RPD)	

ACCURACYa (%R)	

MDLb (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 Disulfided	75-15-0	<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

Cyclohexane e	110-82-7	<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

1,2,4-Trimethylbenzene e	95-63-6	<25	70-130	10	10	90

1,3,5-Trimethylbenzene e	108-67-8	<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

a	Criteria apply to PRQL concentrations

b	Values based on delivering 10 mL  to the analytical system

c	These xylene isomers cannot be resolved by the analytical methods
employed in this program, and are reported as m,p-xylene.

d	Compound added to original target analyte list due to frequency of
detection as a Tentatively Identified Compound (TIC) in at least one
waste stream.

e	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.

MDL	=	Method Detection Limit (maximum permissible value, total number of
nanograms delivered to the analytical system per sample)

PRQL	=	Program Required Quantitation Limit

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference



Table B3-3, Summary of Laboratory Quality Control Samples and
Frequencies

for Gas Volatile Organic Compounds Analysis

 When Using SUMMA® Canisters or On-Line Systems

QC SAMPLE	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTION a, c

Method Performance Samples	Seven (7) samples initially and four (4)
semi-annually	Meet Table B3-2 QAOs	Repeat until acceptable

Laboratory Duplicates, or

On-Line Duplicates	One (1) per analytical batch  or  on-line batch.	RPD
< 25% b	Nonconformance if 

Laboratory Blanks, or

On-Line Equipment/Field Blanks	Daily prior to sample analysis for GC/MS
and GC/FID.

Otherwise daily prior to sample analysis and one (1) per analytical
batch or on-line batch.	Analyte amounts

 ( 3 x MDLs for GC/MS and GC/FID	Flag data with a “B” if analyte
amounts ( 3 x MDLs for GC/MS and GC/FID

Laboratory Control Samples, or 

On-Line Control Samples (FRS/CCV)	One (1) per analytical batch or
on-line batch.	70-130 %R	Nonconformance if 

%R ( 70 or (130

GC/MS

	BFB Tune every 12 hours	Abundance criteria for all key ions are met
Repeat until acceptable

	5-pt. Initial Calibration 

initially, and as needed	%RSD of response factor for each analyte ( 35
Repeat until acceptable

	Continuing Calibration

every 12 hours	%D for all compounds ( 30 of initial calibration	Repeat
until acceptable

GC/FID

	3-pt. Initial Calibration

initially, as needed	%RSD of response factor for each analyte ( 30 

Linear regression plots yield straight line and %R is 70-130 for each
standard analyte	Repeat until acceptable

	Continuing calibration

every 12 hours	%D for all compounds ( 30 of initial calibration; RTs ±
3 standard deviations of initial calibration	Repeat until acceptable

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 when QC samples do not meet the acceptance criteria;
nonconformance procedures are outlined in Section B3-13.

b	Applies only to concentrations greater than the PRQLs listed in Table
B3-2.

c	Data usability is assessed using the criteria presented in EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999).

BFB	=	4-Bromofluorbenzene

%D	=	Percent Difference

MDL	=	Method Detection Limit

PDP	=	Performance Demonstration Program

QAO	=	Quality Assurance Objective

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

RT	=	Retention Time



Table B3-4, Volatile Organic Compounds Target Analyte List and Quality
Assurance Objectives

COMPOUND	CAS

NUMBER	PRECISION a

( %RSD or RPD)	ACCURACY a

(%R)	MDL b

(mg/kg)	PRQL b

(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

Chloromethanef	74-87-3	<50	60-150	1	10	90

1,4-Dichlorobenzene c	106-46-7	<60	18-190	1	10	90

ortho-Dichlorobenzene c	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-Dichlorethylene	156-60-5	<50	60-150	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

Trichlorofluorormethane	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

m-xylene	108-38-3	<50	60-150	1	10	90

o-xylene	95-47-6	<50	60-150	1	10	90

p-xylene	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

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 semi-volatile organic compound.  If analyzed
as a semi-volatile compound, the QAOs of Table B3-6 apply.

d	Detected; result must be greater than zero.

e	Estimate, to be determined.

f	Compound added to original target analyte list for waste streams
RF009.01, RF005.01, and RF118.01 due to frequency of detection as a
Tentatively Identified Compound (TIC). See interoffice memorandums from
G.A. O’Leary to C.A.Turner, GAO-057-00, GAO-032-01, and GAO-070-01.

MDL	=	Method Detection Limit (maximum permissible value)

PRQL	=	Program Required Quantitation Limit; calculated from the toxicity
characteristic level for benzene assuming a 25 gram sample, 0.5 L of
extraction fluid, and 100 percent analyte extraction

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

Table B3-5, Summary of Laboratory Quality Control Samples and
Frequencies for Volatile Organic Compounds Analysis

QC 

SAMPLE	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTION a, c

Method performance 

Samples	Seven (7) samples initially and four (4) semi-annually	Meet
Table B3-4 QAOs	Repeat until acceptable

Laboratory duplicatesb	One (1) per analytical batch	Meet Table B3-4
Precision QAOs	Nonconformance if  RPDs > values in Table B3-4.

Laboratory blanks	One (1) per analytical batch	Analyte concentrations (3
x MDLs	Nonconformance if analyte concentrations > 3 x MDLs.

Matrix spikes	One (1) per analytical batch	Meet Table B3-4 accuracy QAOs
Nonconformance if %Rs are outside the range specified in Table B3-4.

Matrix spike duplicatesb	One (1) per analytical batch	Meet Table B3-4
accuracy and precision QAOs	Nonconformance if RPDs > values and %Rs
outside range specified in Table B3-4.

Laboratory control samples	One (1) per analytical batch	Meet Table B3-4
accuracy QAOs	Nonconformance if %R < 80 or > 120.

GC/MS	BFB Tune every 12 hours

5-pt. Initial Calibration

initially, and as needed

	Abundance criteria met as per method

Calibrate according to SW-846 Method requirements

%RSD for CCC ( 30,

%RSD for all other compounds ( 15%

Average response factor (RRF) used if %RSD ( 15; linear regression used
if % RSD >15; R or R2 (  0.990 if using alternative curve

System Performance Check Compound (SPCC) minimum RRF as per SW-846
Method; RRF for all other compounds ( 0.01	Repeat until acceptable

	Continuing calibration

Every 12 hours	%D ( 20 for CCC

SPCC minimum RRF as 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

GC/FID	3-pt. Initial Calibration 

initially and as needed	Correlation coefficient > 0.990 or %RSD for
response factors ( 20  for all analytes	Repeat until acceptable



	Continuing calibration

every 12 hours	%D or %Drift for all analytes ( 15 of expected values

RT ( 3 standard deviations from initial calibration	Repeat until
acceptable

Surrogate compounds	Each analytical sample	Average %R from minimum of 30
samples for a given matrix ( 3 standard deviations	Nonconformance if %R
< (average %R – 3 standard deviation) or > (average %R + 3 standard
deviation).

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 of this document when final
reported QC samples do not meet the acceptance criteria. 
Nonconformances do not apply to matrix related exceedances.

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

c	Data usability is assessed using the criteria presented in EPA
540/R-99/008, USEPA Contract Laboratory Program Functional Guidelines
for Organic Data Review (EPA 1999).

BFB	=	4-Bromofluorbenzene	%R	=	Percent Recovery	

%D	=	Percent Difference	%RSD	=	Percent Relative Standard Deviation

MDL	=	Method Detection Limit 	RPD	=	Relative Percent Difference

PDP	=	Performance Demonstration Program	RT	=	Retention Time	

QAO	=	Quality Assurance Objective



Table B3-6, Semi-Volatile Organic Compounds Target Analyte List and
Quality Assurance Objectives

COMPOUND	

CAS

NUMBER	PRECISIONa,g

(%RSD OR RPD)	

ACCURACYa,g

(%R)	

MDLb

(MG/KG)	

PRQLb

(MG/KG)	

COMPLETENESS

Acetophenonee	98-86-2	TBDf	TBDf	TBDf	40	90

Cresols	1319-77-3	<50	25 - 115	5	40	90

1,4-Dichlorobenzeneb, c	106-46-7	<86	20 - 124	5	40	90

Ortho-Dichlorobenzene c	95-50-1	<64	32 - 129	5	40	90

2,4-Dinitrophenol	51-28-5	<119	D-172d	5	40	90

2,4-Dinitrotoluene	121-14-2	<46	39 - 139	0.3	2.6	90

Hexachlorobenzene	118-74-1	<319	D-152d	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

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 volatile organic compound.

d	Detected; result must be greater than zero.

e	Compound added to original target analyte list for waste stream
RF118.01 due to frequency of detection as a Tentatively Identified
Compound (TIC). See interoffice memorandum from G.A. O’Leary to
C.A.Turner, GAO-069-01.

f	Data is currently insufficient for calculating QAOs for precision,
accuracy, and MDL for this compound.  

g	Criteria apply to PRQL concentrations.

CAS	=	Chemical Abstract Service

MDL	=	Method detection limit (maximum permissible value)

PRQL	=	Program required quantitation limit; calculated from the toxicity
characteristic level for nitrobenzene assuming a 100-gram (g) sample,
0.5 gal (2 liter [L]) of extraction fluid, and 100 percent analyte
extraction (milligrams per kilogram)

%R	=	Percent Recovery

%RSD	=	Percent relative standard deviation

RPD	=	Relative percent difference



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, c

Method Performance Samples	Seven (7) samples initially and four (4)
semi-annually	Meet Table B3-6 QAOs	Repeat until acceptable

Laboratory duplicates b	One (1) per analytical batch	Meet Table B3-6
precision QAOs	Nonconformance if RPDs > values in Table B3-6.

Laboratory blanks	One (1) per analytical batch	Analyte concentrations

(  3 x MDLs	Nonconformance if analyte concentrations ( 3 x MDLs.

Matrix spikes	One (1) per analytical batch	Meet Table B3-6 accuracy QAOs
Nonconformance if RPDs > values and %Rs outside range specified in Table

B3-6.







	GC/MS Calibration	DFTPP Tune every 12 hours

5-pt. Initial Calibration

initially, and as needed

	Abundance criteria met as per method

Calibrate according to SW-846 Method requirements

%RSD for CCC ( 30,

%RSD for all other compounds ( 15%

Average response factor (RRF) used if %RSD ( 15, use linear regression
if % RSD >15; R or R2 (  0.990 if using alternative curve

System Performance Check Compound (SPCC) minimum RRF as per SW-846
Method; RRF for all other compounds ( 0.01	Repeat until acceptable

	Continuing calibration

Every 12 hours	%D ( 20 for CCC

SPCC minimum RRF as 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

GC/ECD	5-pt. Calibration 

initially and as needed	Correlation coefficient > 0.990 or %RSD for
response factors ( 20  for all analytes	Repeat until acceptable



	Continuing calibration

every 12 hours	%D or %Drift for all analytes ( 15 of expected values

RT ( 3 standard deviations from initial calibration	Repeat until
acceptable



Table B3-7, Summary of Laboratory Quality Control Samples and
Frequencies for Semi-Volatile Organic Compounds Analysis (continued)

QC 

SAMPLE	MINIMUM 

FREQUENCY	

ACCEPTANCE CRITERIA	CORRECTIVE 

ACTION a, c

Matrix spikes duplicates	One (1) per analytical batch	Meet Table B3-6
accuracy and precision QAOs	Nonconformance if RPDs and %Rs > values in
Table B3-6.

Laboratory control samples	One (1) per analytical batch	Meet Table B3-6
accuracy QAOs	Nonconformance if %R < 80 or > 120.

Surrogate compounds	Each analytical sample	Average %R from minimum of 30
samples for a given matrix ± 3 standard deviations	Nonconformance if %R
< (average %R – 3 standard deviations) or > (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 is taken per Section B3-13 of this document when
final reported QC samples do not meet the acceptance criteria. 
Nonconformances do not apply to matrix related exceedances.

b	May be satisfied using matrix spike duplicate; acceptance criteria
applies only to concentrations greater than the PRQLs listed in Table
B3-6.

c	Data usability is assessed using the criteria presented in EPA
540/R-99/088, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999).

%D	=	Percent Difference

DFTPP	=	decafluorotriphenylphosphine

MDL	=	Method Detection Limit

PDP	=	Performance Demonstrate Program

QAO	=	Quality Assurance Objective

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

RT	=	Retention Time



Table B3-8, Metals Target Analyte List and Quality Assurance Objectives

ANALYTE	CAS NUMBER	PRECISION

(% RSD OR RPD)a	ACCURACY (%R)b	PRDLc

(µG/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	2,000	2,000	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, and ( 100 x IDL for ICP-MS
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 which has established
statistical control limits is used, then the established control limits
for that material should be used for accuracy requirements.

c	PRDL set such that it is a factor of 10 below the PRQL for 100% solid
samples, assuming a 100x dilution during digestion.

d	TCLP PRQL values are reported in units of mg/l and limits are reduced
by a factor of 20.

CAS	=	Chemical Abstract Service

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

%R	=	Percent Recovery

PRDL	=	Program Required Detection Limit (i.e., maximum permissible value
for IDL)

PRQL	=	Program Required Quantitation Limit



Table B3-9, Summary of Laboratory QC Samples and Frequencies for Metals
Analysis

QC SAMPLES	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTIONS a, d


Method performance samples	Seven (7) samples, initially, and four (4)
semi-annually	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 x blank value and 

( 0.5 x PRQL

Matrix spikes	One (1) per analytical batch	Meet Table B3-8 accuracy QAOs
Nonconformance if %R is 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 %R
outside range specified in Table B3-8.

ICP-MS Tune (ICP-MS Only)	Daily	4 Replicate %RSD ( 50; 

mass calibration ( 0.9 amu; resolution ( 1.0 amu full width at 10% peak
height	Nonconformance if %RSD ( 5, mass calibration ( 0.9 amu;
resolution ( 1.0 amu

Initial Calibration

1 blank, 1 standard  for ICP, ICP-MS

1 blank, 3 standard for GFAA, FLAA

1 blank, 5 standard for 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 %R for continuing calibration verification solution.

(80-120% for CVAA, GFAA, HAA, FLAA)	Correct problem and recalibrate;
rerun last 10 samples

Internal Standard Area Verification (ICP-MS)	Every Sample	Meet SW-846
Method 6020 Criteria	Nonconformance if not reanalyzed at 5X dilution
until criteria are met

Serial dilution (ICP, ICP-MS)c	One (1) per analytical batch	5x dilution
must be ( 10 % D of initial value for sample ( 50 x IDL	Flag Data with a
“Z” if  ( 10% D and ( 50 x IDL

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
interferants found in sample 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 effected 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 exceedances.

b	Applies only to concentrations greater than PRQLs listed in Table
B3-8.

c	The SW-846 requirements apply to CVAA and HVAA serial dilution
acceptance criteria.

d	Data usability is assessed using the criteria presented in EPA
540-R-01-008, USEPA Contract Laboratory Program National Functional
Guidelines for Inorganic Data Review (EPA 2002).

IDL 	=	Instrument Detection Limit

PDP 	=	Performance Demonstration Program

PRQL	=	Program Required Quantitation Limit

%R 	=	Percent Recovery

RPD	=	Relative Percent Difference

TABLE B3-10, MINIMUM TRAINING AND QUALIFICATIONS REQUIREMENTS

PERSONNEL	

REQUIREMENTS a



Radiography Operators c

	Site-specific training based on Waste Matrix Codes and waste material
parameters; requalification every 2 years



Gas Chromatography Technical Supervisors b

Gas Chromatography Operators c

	B.S. or equivalent experience and 6 months previous applicable
experience

Gas Chromatography/Mass Spectrometry Operators c

Mass Spectrometry Operators c

	B.S. or equivalent experience and 1 year independent spectral
interpretation or demonstrated expertise



Gas Chromatography/Mass Spectrometry Technical Supervisors b

Mass Spectrometry Technical Supervisors b

Atomic Absorption Spectroscopy Technical Supervisors b

Atomic Absorption Spectroscopy Operators c

Atomic Mass Spectrometry Operators c

Atomic Emission Spectroscopy Operators c

	B.S. or equivalent experience and 1 year applicable experience

Atomic Mass Spectrometry Technical Supervisors b	B.S. and specialized
training in Atomic Mass Spectrometry and 2 years applicable experience



Atomic Emission Spectroscopy Technical Supervisors b	B.S. and
specialized training in Atomic Emission Spectroscopy and 2 years
applicable experience.





a	Based on requirements contained in USEPA 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 analytical technique. 
Refer to the TWCP TIP, Appendix 4, Analysis Processes, for the
qualification requirements for this functional position.  Also refer to
Section A-5a(2)(i) Headspace Analytical Services Manager, or A-5g(1),
Analytical Laboratories Manager, for one of the site-specific titles for
this functional position.  Although the Headspace Analytical Services
Manager or Analytical Laboratories Manager often performs the functional
role of Technical Supervisor during the data generation level review,
other qualified personnel (i.e., as specified in the TWCP TIP) may
perform the role of Technical Supervisor.

c	Operators are those persons responsible for the actual operation of
analytical equipment.

As discussed in Section B1-3b, the RFETS-specific position title for RTR
Operator is Nondestructive Testing (NDT) Technician.  The qualification
requirements for this position are presented in the TWCP TIP, Appendix
3, Measurement Systems, Non-Destructive Testing (NDT); and in
5-NDT-TC-1A, Training, Qualification and Certification of Nondestructive
Testing personnel.

The RFETS-specific position title for an analytical operator is
Chemist/Operator.  The qualification requirements for specific
analytical Chemist/Operators are presented in the TWCP TIP, Appendix 4,
Analysis Processes.

Table B3-11, Testing Batch Data Report Contents

Required Information	Radiography	Visual Examination

(to Confirm RTR)	Visual Verification

of Acceptable Knowledge	Comment

Batch Data Report Date	X	X	X	This date is the date of the QAO release
signature.

Batch number	X	X	X

	Waste Container number	X	X	X	The Waste Container number corresponds to
the Drum number, POC Drum Assembly number, or Standard Waste Box number,
etc.  

For some Residues projects, the Waste Container number is NA because
these Residues projects report on the “inner containers”.  A list of
the “inner containers” is included on the cover page of each Residue
Testing Batch Report.  The WEMS database provides a cross-reference
between the inner container numbers and the number of the Drum or POC
Drum Assembly. 

Waste stream name and/or number	O	O	O	The waste stream name and number
are documented in RMRS-WIPP-98-100.

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	The Container Type corresponds to “Drum”,
“POC Drum Assembly”, or “Standard Waste Box”, etc.

For some Residues projects, the Container type is NA because these
Residues projects report based on the “inner containers”.  A list of
the “inner containers” is included on the cover page of each Residue
Testing Batch Report.  The WEMS database provides a cross-reference
between the inner container numbers and the number of the Drum or POC
Drum Assembly.

Videotape reference	X	X	NA	Reference to videotape(s) applicable to each
container.  For visual examination (for characterization) of newly
generated waste, videotape not required if two trained operators review
the contents of the waste container to ensure correct reporting.

Imaging check	O	NA	NA

	Camera check	NA	O	NA

	Audio check	O	O	NA

	

Table B3-11, Testing Batch Data Report Contents (continued)

Required Information	Radiography	Visual Examination

(to Confirm RTR)	Visual Verification

of Acceptable Knowledge	Comment

QC check of scales	NA	O	O	Available documented evidence that calibrated
scale(s) were used.  Only applicable if items are weighed during the
visual examination.

QC documentation	X	X	X	If items are weighed during the visual
examination, the scale/balance identification number and the
scale/balance calibration due date are recorded on the applicable
documents.

In addition for Residues, the ITR and QAO review the applicable
documentation to verify that the  scale/balance check weighing
activities are performed satisfactorily; however, this check is not
considered QC documentation and these documents are not included in the
batch reports.

Description of liners and layers of confinement (if possible)	X	X	X	For
some Residues projects, the description of liners and layers of
confinement of the outer container is NA because these Residues projects
report based on the “inner containers”.  A list of the “inner
containers” is included on the cover page of each Residue Testing
Batch Report.  The WEMS database provides a cross-reference between the
inner container numbers and the number of the Drum or POC Drum Assembly.

Indication of vented rigid liners	X	X	X	Only required for containers
with rigid liners.  If RTR is used to verify, then include in Testing
Batch Data Report.

For some Residues projects, the indication of vented rigid liners is NA
because these Residues projects report based on the “inner
containers”.  A list of the “inner containers” is included on the
cover page of each Residue Testing Batch Report.  The WEMS database
provides a cross-reference between the inner container numbers and the
number of the Drum or POC Drum Assembly.

Description of container contents	X	X	X	Provide enough details for
verification of estimated weights for the 12 waste material parameters,
and to identify all discernable waste items, etc..

Verification that the physical form matches the waste stream description
and Waste Matrix Code	X	X	X	Summary Category Group included in the Waste
Matrix Code.

Indication of sealed containers > 4 liters	X	X	X	Verification that
sealed containers greater than 4 liters were NOT detected is documented
on the applicable the data sheet.

Amount of free liquids	X	X	X	Verification that free liquids or
containerized liquids were NOT detected is documented on the applicable
the data sheet.

Estimated weights for the 

12 waste material parameters	X	X	X	Table B3-1 lists waste material
parameters.

For some Residues projects, the estimated weights of the outer packaging
is NA because these Residues projects report based on the “inner
containers”.  A list of the “inner containers” is included on the
cover page of each Residue Testing Batch Report.  The WEMS database
provides a cross-reference between the inner container numbers and the
number of the Drum or POC Drum Assembly.

Table B3-11, Testing Batch Data Report Contents (continued)

Required Information	Radiography	Visual Examination

(to Confirm RTR)	Visual Verification

of Acceptable Knowledge	Comment

Container gross weight	X	X	X	The Container gross weight corresponds to
the gross weight of the “Drum”, “POC Drum Assembly”, or
“Standard Waste Box”, etc.

When repackaging retrievably stored waste, the Waste Container gross
weight is NA because, although the net weight of the waste (without
packaging) is recorded, the gross weight of the  Drum or POC Drum
Assembly is not available for measurement at the time of the Visual
Verification activity.

The WEMS database provides a cross-reference between the inner container
numbers and the number of the Drum or POC Drum Assembly.

Container empty weight	O	O	O	Established, documented empty container
weights can be used.

For some Residues projects, the Waste Container empty weight is NA
because these Residues projects report based on the “inner
containers.”  A list of the “inner containers” is included on the
cover page of each Residue Testing Batch Report.  The WEMS database
provides a cross-reference between the inner container numbers and the
number of the Drum or POC Drum Assembly.

Comments	X	X	X

	Reference to or copy of associated NCRs, if any	X	X	X	Copies of data
quality NCRs, if any, are referenced in the Test Batch Data Report and
may be included with the Test Batch Data Report.

Copies of associated NCRs must be available.

Visual examination expert decisions	NA	X	NA	Only applicable if visual
examination expert is consulted during visual examination.

Verify absence of prohibited items	X	X	X	Verification that prohibited
items were NOT detected is documented on the data sheet.

Operator signature and date of test	X	X	X	Signatures for both operators
required for Visual Verification of Acceptable Knowledge.

Signature of visual examination expert and date	NA	X	NA

	Data review checklists	X	X	X	Copies of the completed data generation
level checklists are included in each Testing Batch Data Report.  All
data review checklists are identified.



X –	Required in batch data report.

O –	Information must be documented and traceable; inclusion in batch
data report is optional.

NA –	Not applicable.



Table B3-12, Sampling Batch Data Report Contents

Required Information	Headspace Gas	Solid Sampling	Comment

Batch Data Report Date	X	X	This date is the date of the QAO release
signature

Batch number	X	X

	Waste stream name and/or number	O	O	The waste stream name and number is
documented in RMRS-WIPP-98-100.

Waste Matrix Code	NA	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.

Waste Container number	X	X	The Waste Container number corresponds to the
Drum number, POC Drum Assembly number, or Standard Waste Box number,
etc.  

For some Residues projects, the Waste Container number is NA because
these Residues projects report based on the “inner containers”.  A
list of the “inner containers” is included on the cover page of each
Residue Testing Batch Report.  The WEMS database provides a
cross-reference between the inner container numbers and the number of
the Drum or POC Drum Assembly.

Container type	O	O	The Container Type corresponds to “Drum”, “POC
Drum Assembly”, or “Standard Waste Box”, etc.

For some Residues projects the Container type is NA because these
Residues projects report based on the “inner containers”.  A list of
the “inner containers” is included on the cover page of each Residue
Testing Batch Report.  The WEMS database provides a cross-reference
between the inner container numbers and the number of the Drum or POC
Drum Assembly.

Sample matrix and type	X	X	The sample matrix (e.g., solid) and the
sample type (e.g., TCLP Metals) are documented on the sample collection
data sheet and/or the COC form.

Analyses requested and laboratory	X	X

	Point of origin for sampling	X	X	Location where sample was taken (e.g.,
building number, room, material balance area). 

Sample number	X	X

	Sample size	X	X	The sample size (e.g., vial size, sample weight, etc.)
is documented on the sample collection data sheet and/or the COC form.



Table B3-12, Sampling Batch Data Report Contents (continued)

Required Information	Headspace Gas	Solid Sampling	Comment

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 the container (e.g., for the Grid
Sampling Method, this location is the randomly selected section of the
sampling pan; for the Cone and Quartering Sampling Method, this location
is the randomly selected opposing quarters).

Sample preservation	X	X	For SUMMA Canister HSG samples: The sample
preservation is equivalent to the Holding Temperature specified in Table
B1-3 (i.e., 0 - 40( C).

For Solid Samples: The method of sample preservation (e.g., cool to 4(
C) is documented on the applicable documentation (e.g., sample
collection data sheet, the COC form, or the refrigerator logsheet).

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 for each type of disposable equipment is recorded on the
applicable documentation.

Cross-reference of sampling equipment numbers with associated cleaning
batch numbers	O	X	As applicable to the equipment used for sampling.

For disposable equipment:  A reference to the lot and procurement
records to support cleanliness is sufficient

Drum age	X	NA	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 retrievably
stored waste, these values must clearly be identified as such.

Equilibration time	X	NA

	Verification of rigid liner venting	X	NA	Only applicable to containers
with rigid liners

Verification that sample volume taken is small in comparison to the
available volume	X	NA	Must include headspace gas volume when it can be
estimated

Scale calibration	NA	O

	Depth of waste	NA	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 by recording the sample collection
procedure on the applicable document.



Table B3-12, Sampling Batch Data Report Contents (continued)

Required Information	Headspace Gas	Solid Sampling	Comment

Calculation of core recovery	NA	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 by recording
the sample collection procedure on the applicable document.

Co-located core description	NA	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 by recording the sample
collection procedure on the applicable documentation.

Time between coring and subsampling	NA	X	Applicable only to coring

OVA calibration and reading	O	NA	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 review checklists are identified



X –	Required in batch data report.

O –	Information must be documented and traceable; inclusion in batch
data report is optional.

NA –	Not applicable.

Table B3-13, Analytical Batch Data Report Contents

Required Information	Headspace Gas	Solid Sampling	Comment

Batch Data Report Date	X	X	This date is the date of the QAO release
signature

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	NA	Original or copy

Sample preservation	X	X

	Holding time	NA	X

	Cross-reference of field numbers to laboratory sample numbers	X	X

	Date and time analyzed	X	X

	

Table B3-13, Analytical Batch Data Report Contents (continued)

Required Information	Headspace Gas	Solid Sampling	Comment

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

Case 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 are identified



X –	Required in batch data report.

O –	Information must be documented and traceable; inclusion in batch
data report is optional.

NA –	Not applicable.

Table B3-14, Data Reporting Flags

Data Flag	Indicator

B	Analytes 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 times exceeded  (not applicable to Headspace gas analysis)



Table B3-15, TC Levels Expressed as RTL Values in the Waste

ANALYTE	RTL VALUE (MG/KG) a

Metals and Semi-VOCsb

	Arsenic

	Barium

	Cadmium

	Chromium

	Cresols	

	1,4-Dichlorobenzene

	2,4-Dinitrotoluene

	Hexachlorobenzene

	Hexachloroethane

	Lead

	Mercury

	Nitrobenzene

	Pentachlorophenol

	Pyridine

	Selenium

	Silver	

	

100

2,000

20

100

4,000

150

2.6

2.6

60

100

4

40

2,000

100

20

100



VOCsc:	Benzene

	Carbon tetrachloride

	Chlorobenzene

	Chloroform

	1,2-Dichloroethane

	1,1-Dichloroethylene

	Methyl ethyl ketone

	Pyridine

	Tetrachloroethylene

	Trichloroethylene

	Vinyl Chloride	10	10

10

2,000

120

10

14

4,000

100

14

10

4

a 	The calculations assume 1) the maximum amount of material suggested
by the TCLP is used; 2) wastes are 100-percent solid (no liquid
fraction); 3) the maximum amount of extraction fluid is used; and 4) all
analytes are 100-percent soluble in the extraction fluid.

b	For metals and SVOCs, RTL value (mg/kg) = (TC level, mg/L) (volume of
extraction fluid, 2 L)/(weight of sample, 0.100 kg)

c	For VOCs, RTL value (mg/kg) = (TC level, mg/L) (volume of extraction
fluid, 0.5 L)/(weight of sample, 0.25 kg)

Table B3-16A, Hydrogen and Methane Analysis Quality Assurance
Objectives a 

ANALYTE GASES	

CAS NUMBER	PRECISION (%RSD OR RPD)	

ACCURACY (%R)	

PRQL

(VOL %)	

MDL 

(VOL %)	

COMPLETENESS (%)

Hydrogen	1333-74-0	<25	70-130%	0.1	.05	90

Methane	74-82-8	<25	70-130%	0.1	.05	90



a	The quality assurance objectives shown in this table are site-specific
and are not WIPP-WAP requirements. 

Table B3-16B, Summary of Laboratory Quality Control Samples and 

Frequencies for Hydrogen and Methane Analysis

QC SAMPLE	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTION a

Method performance samples	7 initially and 4 semi-annually	Meet Table
B3-16A QAOs	Repeat until acceptable

Duplicates 	1 per analytical batch	RPD ( 25 % b	Nonconformance if RPD >
25%

Blanks 	1 per analytical batch	Analytes ( PRQL	Flag data with a “B”



a	Corrective Action is required only if the concentration of a given
analyte exceeds the PRQL for that analyte.

b 	The RPD criterion applies only if the concentration of a given
analyte exceeds the PRQL for that analyte.

QAO	=	Quality Assurance Objective

RPD	=	Relative Percent Difference

PRQL	=	Program Required Quantitation Limits



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B4.	TRU WASTE CHARACTERIZATION USING ACCEPTABLE KNOWLEDGE

B4-1	Introduction

The Resource Conservation and Recovery Act (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, (20.4.1 NMAC) Subparts I through
VI, Subpart VIII, and Subpart IX, authorize the use of acceptable
knowledge (AK) in appropriate circumstances by waste generators, or
treatment, storage, or disposal facilities to characterize hazardous
waste.  Acceptable knowledge is described in Waste Analysis: EPA
Guidance Manual for Facilities That Generate, Treat, Store and Dispose
of Hazardous Waste (EPA, 1994).  Acceptable knowledge, as an alternative
to sampling and analysis, can be used to meet all or part of the waste
characterization requirements under the RCRA (EPA, 1994).

Acceptable knowledge 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).  RTR and/or visual examination, headspace gas
sampling and analysis, and homogeneous waste sampling and analysis
(specified in Permit Attachment B1) are used to acquire supplemental
sampling and analysis data to meet the requirements of the Waste
Analysis Plan (WAP) specified in Permit Attachment B.  Acceptable
knowledge 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 (20.4.1.200 NMAC, incorporating 40 CFR §261.24).

To assess if TRU wastes are listed (20.4.1.200 NMAC, incorporating 40
CFR §261.31).

Acceptable knowledge is used to assign waste matrix code and EPA
hazardous waste numbers to waste streams and to determine the physical
form of waste (waste material parameter).  The collection and use of
acceptable knowledge information applies to both retrievably stored and
newly generated TRU waste streams.  Determination of radionuclides by
acceptable knowledge is addressed in the TWMM.

Sampling and analysis is performed to confirm acceptable knowledge and
to update and modify initial AK assessments.  Sampling and analysis
includes RTR, visual examination, headspace gas, and homogeneous waste
sampling and analysis.  TRU waste streams undergo applicable provisions
of the acceptable knowledge process prior to management, storage, or
disposal of the waste at WIPP.

B4-2	Acceptable Knowledge Documentation

The RFETS acceptable knowledge information progresses from general
facility information (TRU waste management program information) to the
more detailed waste-specific information (TRU waste stream information).
 This acceptable knowledge information applies at RFETS to both the
retrievably stored and newly generated waste streams and is described in
detail in RF/RMRS-97-018, RFETS TRU Waste Acceptable Knowledge
Supplemental Information.

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(1) 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
RFETS, and describes how waste is tracked and managed at RFETS,
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 acceptable knowledge is
also provided.

The overview of RFETS and its TRU waste management operations that is
part of the acceptable knowledge record is contained in RF/RMRS-97-018,
RFETS TRU Waste Acceptable Knowledge Supplemental Information, which
includes:

A map of RFETS 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 generate TRU waste at RFETS.

Description of waste identification and characterization schemes used at
RFETS.

Types and quantities of TRU waste generated, including historical
generation through future projections.

Description of how waste streams generated from the same process in one
or many facilities are correlated (e.g., sludge, combustibles, metals,
and glass).

Waste certification procedures for retrievably stored and newly
generated wastes to be sent to the WIPP facility.

B4-2b	Required TRU Waste Stream Information

The process information and data that support the acceptable knowledge
used to characterize TRU waste streams is compiled into
RMRS-WIPP-98-100, Acceptable Knowledge TRU/TRM Waste Stream Summaries. 
The information on each waste stream includes:

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 that identify 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
verification of newly generated waste that later undergoes radiography;
information demonstrating neutralization of U134 [hydrofluoric acid] and
waste compatibility, etc.).

The acceptable knowledge 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 in the source documentation, the
inconsistencies are resolved using supplemental information from
interviews, phone contacts, or other correspondence.  A letter
(discrepancy report) documenting resolution to the discrepancy is
maintained as a quality record in the 

acceptable knowledge files.  If the discrepancy cannot be resolved, the
letter reflects this and all necessary information.  If discrepancies
exist between required information, then RFETS applies all hazardous
waste codes indicated by the information to the subject waste stream. 
Alternatively, RFETS may choose to justify an alternative assignment and
document the justification in the auditable record.  Discrepancy
resolution for the acceptable knowledge information in RF/RMRS-97-018,
RFETS TRU Waste Acceptable Knowledge Supplemental Information, is
documented in PRO-484-WIPP-003, Collection, Review, and Confirmation of
Acceptable Knowledge Documentation.  

B4-2b	Required TRU Waste Stream Information  (continued)

Procedures listed in Section B4-3b comply with the following acceptable
knowledge requirements:

Procedures for identifying and assigning the physical waste form of the
waste.  Refer to Section B4-3b(4) and (7).

Procedures for delineating waste streams and assigning Waste Matrix
Codes.  Refer to Section B4-3(5) and (7).

Procedures for resolving inconsistencies in acceptable knowledge
documentation.  Refer to Section B4-3b(4).

Procedures for confirming acceptable knowledge information through
headspace gas sampling and analysis, visual examination and/or RTR, and
homogeneous waste sampling and analysis.  Refer to Section B4-3b(6).

Procedures describing management controls used to ensure prohibited
items (specified in the WAP, Permit Attachment B) are documented and
managed.  Refer to Section B4-3b(3).

Procedures to ensure RTR 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,
ignitables, reactives, and incompatible wastes).  Refer to Section
B4-3b(3).

Procedures to document how changes to Waste Matrix Codes, waste stream
assignment, and associated EPA hazardous waste numbers based on material
composition are documented for any waste.  Refer to Section B4-3b(5) and
(7).

Procedures for newly generated waste shall describe how acceptable
knowledge is confirmed using either visual verification or radiography
(or VE in lieu of radiography).  Refer to Section B4-3b(6).  Procedures
also describe the criteria for selecting either radiography or VE to
ensure there is documentation and adequate justification of the process
selected.  RFETS newly generated waste is characterized with visual
verification unless the use of radiography in lieu of, or in combination
with, visual verification is justified by the following criteria:

Visual verification was conducted during packaging, but is unacceptable,

Visual verification requires extensive handling of high gram content
waste that results in high radioactive exposure for the VV personnel,
and/or

Where waste packaging is conducted at numerous locations generating
small quantities of TRU waste, requiring a large number of VV personnel.

Where waste was originally packaged as low-level waste, but subsequently
determined to be TRU.

B4-2c	Supplemental Acceptable Knowledge Documentation

Supplemental acceptable knowledge information, as appropriate, is
collected to support required TRU waste stream information.  This
supplemental information is included in the acceptable knowledge written
record.  Supplemental acceptable knowledge 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.

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 RFETS 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 WAP).

Material Data Safety Sheet, 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 acceptable knowledge documentation
assembled and used in the acceptable knowledge process, whether it
supports or contradicts any required acceptable knowledge 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.

B4-3	Acceptable Knowledge Training, Procedures and Other Requirements

RFETS uses a three phase process to characterize TRU waste by means of
acceptable knowledge information:  1) compiling enough acceptable
knowledge documentation for an auditable record, 2) confirming
acceptable knowledge information using RTR, and headspace gas and
homogeneous waste sampling and analysis, and 3) auditing acceptable
knowledge records.

B4-3a	Qualifications and Training Requirements

To ensure compliance with the requirements for assembling, evaluating,
and assessing acceptable knowledge, TWCP personnel are trained according
to the TWCP TIP, Appendix 1, TWCP Project Training Matrix.  RFETS
personnel who support the TWCP receive indoctrination in general TWCP
objectives as well as the WIPP-WAP purpose, scope, objectives and
task-specific QAOs.  These personnel maintain their technical competence
through ongoing training specified in their job analyses and training
needs assessments and listed in the TWCP TIP.

RFETS personnel responsible for assessing and compiling information and
resolving discrepancies associated with acceptable knowledge meet the
training and qualification requirements in the TWCP TIP.  The training
requirements in the TWCP TIP include the following subjects:

WIPP-WAP and TSDF-WAC requirements as follows:

	These requirements are covered in WSRIC and waste generator classroom
training.  These courses cover WIPP-WAC; WIPP-WAP; 1-M12-WO-4034, Solid
Radioactive Waste Packaging Requirements Manual; and 4-D99-WO-1100,
Solid Radioactive Waste Packaging Procedure.

	TWCP personnel receive training in WIPP-WAC through the Indoctrination
to the WIPP TRU Waste Characterization Program.  Personnel receive
training in the WIPP-WAP through required readings of acceptable
knowledge requirements from the WIPP-WAP, and a supplemental WAP
Indoctrination class.

State and Federal RCRA regulations associated with solid and hazardous
waste determinations as follows:

RCRA regulatory requirements are covered in classroom training and
qualifications for waste generation and RCRA compliance.  The
qualifications are updated annually through a RCRA and waste generator
checklist briefing; personnel who deliver the briefing but also need to
update their training annually receive a train-the-trainer briefing
conducted by RFETS SMEs for waste generation and RCRA qualification
programs.

Personnel who provide characterization support and provide acceptable
knowledge information, but do not become involved in hands-on waste
management activities, complete optional theoretical knowledge only
qualifications.

B4-3a	Qualifications and Training Requirements (continued)

Nonconformance process, including discrepancy resolution and reporting
as follows:

Headspace or Laboratory personnel and the HASQAO or LPQAO report and
resolve data package deficiencies in accordance with the procedure on
nonconforming items 1-A65-ADM-15.01, Control of Nonconforming Items.

Waste Inspectors are trained by Waste Certification and Oversight (WC &
O) in reporting nonconformances per PRO-U76-WC-4030, Control of Waste
Nonconformances.

	Waste Generators are trained during waste generator training and
qualification to recognize and report discrepancies on a Waste
Nonconformance Report (refer to PRO-U76-WC-4030, Control of Waste
Nonconformances).

NDT personnel are trained by WC & O in the nonconformance process per
4-W30-NDT-00664, Real-Time Radiography for Transuranic and Low-Level
Waste in Building 664; 4-I19-NDT-00569, Real-Time Radiography for
Transuranic and Low-Level Waste in Building 569; PRO-1520-Mobile-RTR,
Mobile Real-Time Radiography Testing of Transuranic and Low-Level Waste;
and PRO-U76-WC-4030, Control of Waste Nonconformances.

	TWCP support personnel have completed required reading course for
PRO-U76-WC-4030, Control of Waste Nonconformances.  TWCP Acceptable
Knowledge personnel resolve discrepancies in acceptable knowledge in
accordance with PRO-484-WIPP-003, Collection, Review, and Confirmation
of Acceptable Knowledge Documentation.

Site-specific procedures associated with waste characterization using
acceptable knowledge as follows:

	The training in the RFETS procedures for waste characterization using
acceptable knowledge includes WSRIC, waste generator classroom training,
and waste generator qualification.  Acceptable knowledge personnel also
receive training on updates to the waste characterization procedures.

Training for the documentation and use of supplemental acceptable
knowledge is accomplished through required reading of RF/RMRS-97-018,
RFETS TRU Waste Acceptable Knowledge Supplemental Information;
RMRS-WIPP-98-100, Acceptable Knowledge TRU/TRM Waste Stream Summaries;
and PRO-484-WIPP-003 Collection, Review, and Confirmation of Acceptable
Knowledge Documentation.

Acceptable knowledge personnel maintain proficiency through procedure
update training and review and approval of the documentation they
prepare.

B4-3b	Acceptable Knowledge Assembly, Compilation, and Confirmation
Procedures and Required Administrative Controls

Site-specific acceptable knowledge procedures address the following:

A written procedure(s) outlining the specific methodology used to
assemble acceptable knowledge 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(1)
of this document.

A written procedure(s) to compile the required acceptable knowledge
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 acceptable knowledge and resolve
discrepancies.  If different sources of information indicate different
hazardous wastes are present, then RFETS includes all sources of
information in its records and conservatively assign all potential
hazardous waste codes unless RFETS 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 20.4.1.200 NMAC (incorporating 40 CFR §261), Subpart D.  All
listed hazardous waste codes are assigned unless RFETS 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 20.4.1.200 NMAC (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.

B4-3b	Acceptable Knowledge Assembly, Compilation, and Confirmation
Procedures and Required Administrative Controls  (continued)

For newly generated wastes, procedures are implemented to characterize
hazardous waste using acceptable knowledge prior to packaging the waste.
 Refer to Section B4-3b(5) of this document.

A written procedure(s) for the confirmation of acceptable knowledge in
accordance with Section B4-3(d). Refer to Section B4-3b(6) 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.

B4-3b(1)	Procedures Used to Assemble the Acceptable Knowledge Record

Written procedure(s) outlining the specific methodology used to assemble
acceptable knowledge records, including the origin of the documentation,
how it will be used, and any limitations associated with the information
are as follows:

1-MAN-036-EWQA-Section 1.6.1, Waste Characterization Program Manual
[This manual provides a roadmap for the acceptable knowledge program and
contains a list of applicable operating procedures which are relevant to
waste determinations.]

4-H19-WSRIC-001, WSRIC Characterization and Reverification [This
procedure addresses how acceptable knowledge records are assembled from
source documentation called a WSRIC Change Form (WCF), WSRIC Change
Request (WCR), or BWRBB Change Form (BCF) which provide an auditable
record.]

PRO-484-WIPP-003, Collection, Review, and Confirmation of Acceptable
Knowledge Documentation [This procedure provides instructions for
compiling, reviewing, and managing additional acceptable knowledge not
specifically addressed by other RFETS documents.]

B4-3b(2)	Procedures Used to Compile the Acceptable Knowledge Record

Written procedure(s) used to compile the required acceptable knowledge
record are as follows: 

4-H19-WSRIC-001, WSRIC Characterization and Reverification;
PRO-1003-WSRIC-ADMIN, WSRIC Administration Guidance; and 4-D15-BBPE-001,
WSRIC Building Book Preparation and Editing [These procedures address
how acceptable knowledge records are assembled from source documentation
called a WCF or WCR which provide an auditable record.  WSRIC Building
Books contain the material inputs to processes, process controls, and
range of operations that affect final IDC (waste matrix code and waste
material parameter) and hazardous waste determinations.  The WSRIC
Building Books also reference the analytical data used in waste stream
characterization and the assignment of EPA hazardous waste numbers.  The
Characterization Rationale also identifies any limitations associated
with the acceptable knowledge information.]

B4-3b(3)	Procedures Used to Ensure Unacceptable Waste is Identified and
Segregated

Written procedure(s) that ensure unacceptable waste (refer to Section
B-1c) is identified and segregated from TRU waste populations to be sent
to WIPP are as follows:

4-H19-WSRIC-001, WSRIC Characterization and Reverification [This
procedure addresses the resolution of document discrepancies through the
use of the WCF, WCR, or BCF.  The appropriate change form is sent to
Waste Systems which processes a WCF or WCR for the WSRIC Building Books
or a BCF for the Backlog Waste Reassessment Baseline Book (BWRBB) and
has the unit owner (responsible for the waste container) update the WEMS
database.]

4-D99-WO-1100, Solid Radioactive Waste Packaging Procedure; and
1-M12-WO-4034, Solid Radioactive Waste Packaging Requirements Manual
[These documents include information on nonconforming items that the
waste generator must verify are not present in each waste container.]

PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Review [This procedure includes a list of WIPP-prohibited items which
the waste originator and waste validator must verify are not present in
each waste container.]

4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569; 4-W30-NDT-00664, Real-Time Radiography
Testing of Transuranic and Low-Level Waste in Building 664; and
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste. [These procedures include a list of nonconforming
items that the operator must verify are not present in each waste
container.]

PRO-1358-440-VERP, Glovebox and C-Cell Waste Operations;
PRO-1471-VE-771, Visual Examination for Confirmation of RTR; and
4-H80-776-ASRF-007, Visual Examination for Confirmation of RTR [These
procedures include a list of nonconforming items that the operator must
verify are not present in each waste container.]

PRO-544-SALT REPACK-371, Residue Repack, Building 371;
PRO-823-REPACK-371, Combustible Residue Repackaging4; 4-W84-RS-0114,
Salt Residue Stabilization/Repack, Bldg. 707; PRO-4-X56-RS-0123, Ash
Residue Repack, Bldg. 7075; and PRO-X32-RS-0128, Dry Residue
Repackaging, Bldg. 7075 [These procedures identify steps to open and
visually inspect the waste, and to segregate noncompliant items.]

PRO-U76-WC-4030, Control of Waste Nonconformances [This procedure
describes the methods to identify, control, and dispose of nonconforming
waste items.  Assigns responsibilities to RFETS organizations and
personnel to identify, report, control, evaluate the nonconformances,
obtain and document a disposition, determine root cause, define
corrective action, and establish recurrence control for reported
nonconforming items.]

B4-3b(4)	Procedures Used to Evaluate Acceptable Knowledge, Resolve
Discrepancies, Assign Hazardous Waste Numbers, etc.

Written procedure(s) to evaluate acceptable knowledge and resolve
discrepancies, assign hazardous waste codes, and preparation of an
auditable record of required documentation are as follows:

4-H19-WSRIC-001, WSRIC Characterization and Reverification [Resolution
of document discrepancies through the use of the WCF, WCR, or BCF.  The
appropriate change form is sent to Waste Systems which processes a WCF
or WCR for the WSRIC Building Books or a BCF for the BWRBB and has the
unit owner (responsible for the waste container) update the WEMS
database.]

PRO-484-WIPP-003, Collection, Review, and Confirmation of Acceptable
Knowledge Documentation [This procedure describes the process used to
document the re-evaluation of acceptable knowledge if radiography or
visual examination identifies wastes that must be assigned a different
waste matrix code (refer to PRO-484-WIPP-003, Figure 6-1, Compilation of
Acceptable Knowledge Documentation).]

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:

4-H19-WSRIC-001, WSRIC Characterization and Reverification [This
procedure is used for the characterization of retrievably stored and
newly generated waste.]

WSRIC Building Books and the BWRBB [The documents are used for
identification and assignment of the appropriate EPA hazardous waste
numbers through the WSRIC Process Number.  The waste generator is
assisted by Waste Requirements Group and Waste Characterization SMEs
when assigning appropriate EPA hazardous waste numbers.  Prior to
packaging newly generated waste, the WSRIC Building Books are used to
determine the proper Item Description Code (IDC), which is converted in
WEMS to a waste matrix code, and for hazardous waste determinations.]

RF/RMRS-97-018, RFETS TRU Waste Acceptable Knowledge Supplemental
Information [This procedure is used to identify the underlying hazardous
constituents which may be present in the TRU waste.]

1-PRO-079-WGI-001, Waste Characterization, Generation, and Packaging
[For newly generated waste, Waste Requirements Group prepares a Waste
Generating Instruction (WGI) that documents the waste characterization
based on acceptable knowledge as presented in WSRIC.  Also used for
verification that the processes generating the waste have operated
within established written procedures.]

1-PRO-Q11-WO-1221, Controls for Updating Waste Package Information in
WEMS [For newly generated waste, the waste generator reports the
contents of the waste container of the Waste/Residue Traveler form and
the WGI on the WEMS Container Worksheet.  This information is then
entered into WEMS.]

B4-3b(6)	Procedures Used to Confirm Acceptable Knowledge and to
Re-Evaluate Acceptable Knowledge

Written procedure(s) for the confirmation of acceptable knowledge in
accordance with Section B4-3d are as follows:

PRO-484-WIPP-003, Collection, Review, and Confirmation of Acceptable
Knowledge Documentation [Use of acceptable knowledge information (refer
to PRO-484-WIPP-003, Figure 6-2, Confirmation of Acceptable Knowledge
for Retrievably Stored Waste; and Figure 6-3, Confirmation of Acceptable
Knowledge for Newly Generated Waste).]

4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569; 4-W30-NDT-00664, Real-Time Radiography
Testing of Transuranic and Low-Level Waste in Building 664; and
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste. [RTR operator enters the physical form of waste
(waste matrix code) on the Waste Characterization RTR Report form.  The
RTR operator then estimates the weights of the physical form of waste
(waste matrix code) based on the estimated volume percent for each waste
material, the weights of the packaging materials, and the densities of
the waste materials.  The physical form of waste (waste matrix code) are
entered into WEMS from the Waste Characterization RTR Report form.]

1-PRO-079-WGI-001, Waste Characterization, Generation, and Packaging;
1-M12-WO-4034, Solid Radioactive Waste Packaging Requirements Manual;
4-D99-WO-1100, Solid Radioactive Waste Packaging Procedure; and
PRO-1031-WIPP-1112 TRU/TRM Waste Visual Verification (VV) and Data
Review [These documents include information on the confirmation of
acceptable knowledge using visual confirmation of the waste prior to or
during waste packaging.  Also refer to 1-C80-WO-1102-W/RT, Waste/Residue
Traveler Instructions]

PRO-860-RS-0156, Solid Sampling, Building 371; PRO-544-SALT REPACK-371,
Residue Repack, Building 3712; PRO-823-REPACK-371, Combustible Residue
Repackaging2; 4-W84-RS-0114, Salt Residue Stabilization/Repack, Bldg.
707; PRO-X56-RS-0123, Ash Residue Repack, Bldg. 7073; and
PRO-X32-RS-0128, Dry Residue Repackaging, Bldg. 7073 [These procedures
are used to document the individual waste items that are repackaged into
a drum or to perform solid sampling of retrievably stored, repackaged
retrievably stored, or newly generated waste.]

PRO-1266-SS-002, Tank Sludge Removal From Pre-Selected Areas, Building
774; PRO-1628-A2-001, Tank Sludge Removal From Pre-Selected Areas, Tank
T-207; PRO-1729-903-SOIL, Soil Removal From Pre-Selected Areas, 903 Pad;
and PRO-1585-PWS-440, Polymerized Waste Sampling Building 440 [These
procedures address the solid sampling of newly generated waste.]

PRO-1623-SCWS-440, Small Container Waste Sampling - TRU Projects [This
procedure is used to perform solid sampling of retrievably stored,
repackaged retrievably stored, and newly generated waste.]

B4-3b(6)	Procedures Used to Confirm Acceptable Knowledge and to
Re-Evaluate Acceptable Knowledge  (continued)

1-M60-WPC-001, Waste Process Control [This procedure provides guidance
and direction for determining the need for process control and
qualification plans for waste generated at the Site.  The process
control and qualification plans may be necessary and required to ensure
that the production of final waste forms and their supporting data are
defensible and meet disposal site requirements and waste acceptance
criteria.]

PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System; L-4231, Headspace Gas Sampling and Analysis Using an
Automated Manifold; PRO-1351-440-SWB, Room 113 Perma-Con Operations;
PRO-717-HDGAS-371, Headspace Gas Sampling, Building 371;
PRO-1141-WP-4701, Waste Characterization Gas Sampling; L-4146, Headspace
Gas Sampling of Waste Containers3; PRO-1669-HGAS-V&V, Headspace Gas V&V
(Data Generator Level); L-4053, Headspace Gas V & V (Data Generator
Level); and L-5017, HVOC Data Review and Validation (Data Generator
Level)3 [These procedures address headspace gas sampling and analysis.]

PRO-945-WIPP-009, RCRA Characterization of TRU Waste to be Disposed of
at WIPP [This procedure addresses waste characterization procedures, and
also provides for the review of characterization data found in WEMS
against acceptable knowledge.  The procedure is used to ensure that the
proper EPA hazardous waste numbers have been assigned.]

Written procedure(s) that are used when the characterization of a waste
must be changed (e.g., changes to waste matrix codes, waste steam
assignment, EPA hazardous waste numbers, etc.):

4-H19-WSRIC-001, WSRIC Characterization and Reverification; and
PRO-U76-WC-4030, Control of Waste Nonconformances [These procedures
address changes to waste matrix codes, waste steam assignment, and any
associated EPA hazardous waste numbers based on material composition. 
These changes are documented on a WCF, WCR, BCF, or Nonconformance
Report]

PRO-544-SALT REPACK-371, Residue Repack, Building 371;
PRO-823-REPACK-371, Combustible Residue Repackaging5; 4-W84-RS-0114,
Salt Residue Stabilization/Repack, Bldg. 707; PRO-X56-RS-0123, Ash
Residue Repack, Bldg. 7076; and PRO-X32-RS-0128, Dry Residue
Repackaging, Bldg.  7076 [These procedures are used to document the
individual waste items that are repackaged into a drum.]

4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569; 4-W30-NDT-00664, Real-Time Radiography
Testing of Transuranic and Low-Level Waste in Building 569; and
PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste [These procedures address reassignment of IDCs
(waste streams).  If radiography results in the reassignment to a
different waste matrix code (waste stream); 1) a Waste Characterization
RTR Report and a Nonconformance Report (NCR) are made out to document
any discrepancy, 2) the NCR is sent to the Waste Certification Official
(WCO) and the unit owner, 3) the unit owner, who is responsible for the
waste container, and the WCO write a change form for either the WSRIC
Building Books or the BWRBB, and 4) the WEMS database is updated.]

B4-3b(7)	Procedures Used to Cross-Reference to the Applicable Waste
Summary Category Group

Written procedure(s) that provide cross-reference to the applicable
waste summary category group (i.e., S3000, S4000, S5000) to verify all
of the required confirmation data has been evaluated and the proper
hazardous waste codes have been assigned:

PRO-944-WIPP-008, Completion of Waste Stream Profile Form for Waste to
be Disposed of at WIPP [This procedure addresses resolution of DQOs
which includes verification all required confirmatory data has been
evaluated for the waste summary category group, and the proper EPA
hazardous waste numbers are assigned to the waste stream.]

B4-3b(8)	Procedures Used to Ensure that Audit Results are Available

Written procedure(s) that ensure that the results of other audits of the
TWCP at RFETS are available in the records:

PRO-077-WIPP-005, Management of Waste Information Prior to Transmittal
to the Waste Records Center [Provides direction for the identification,
generation, receipt, authentication, and transmittal of WIPP in-process
QA documents and completed QA records to the Waste Records Center.]

PRO-767-WIPP-001, Waste Records Center Processing [The procedure
addresses the maintenance and updating of the records inventory.]

3-X31-CAP-001, Corrective Action Process [This system tracks the status
of corrective actions and provides a Corrective Action Status Report.]

B4-3b(9)	Procedures Used for Administrative Control

The following minimum elements are addressed in site-specific
documentation associated with administrative controls:

Prohibited items are documented and managed in accordance with the
following procedures:

4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569

4-W30-NDT-00664, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 664

PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste

PRO-544-SALT REPACK-371, Residue Repack, Building 371;
PRO-823-REPACK-371, Combustible Residue Repackaging2; 4-W84-RS-0114,
Salt Residue Stabilization/Repack, Bldg. 707; PRO-X56-RS-0123, Ash
Residue Repack, Bldg. 7073; and PRO-X32-RS-0128, Dry Residue
Repackaging, Bldg. 7073

PRO-U76-WC-4030, Control of Waste Nonconformances

PRO-X05-WC-4018, Transuranic (TRU) Waste Certification

B4-3b(9)	Procedures Used for Administrative Control (continued)

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 the
following procedures and schedules:

TRU Waste Project Management Assessment Schedule

TWCP Independent Assessment Schedule

PRO-X05-WC-4018, Transuranic (TRU) Waste Certification

1-W37-IA-002, Integrated Planning and Scheduling of Assessment
Activities

TWCP Integrated Surveillance Schedule

On-the-job training specific to administrative control procedures has
been developed as specified in the TWCP TIP.

Personnel may stop work if noncompliance with administrative controls is
identified in 1-V10-ADM-15.02, Stop Work Action.  This document
describes the method, and its applicability to stop work when it does
not comply with governing quality requirements.  Under specified
conditions adverse to quality, first-line supervision may issue such
orders.  Requirements for the resolution and release of stop work orders
are also defined.

Two nonconformance processes have been developed that comply with the
requirements in Section B3 of the WAP to document and establish
corrective actions as identified in the following procedures:

PRO-U76-WC-4030, Control of Waste Nonconformances

1-A65-ADM-15.01, Control of Nonconforming Items

These procedures include the corrective action process which specifies
the potential time frame of the noncompliance, the potentially affected
waste population(s), and the reassessment and recertification of those
wastes.

B4-3c	Criteria for Assembling an Acceptable Knowledge Record and
Delineating the Waste Stream

Procedure PRO-484-WIPP-003, Collection, Review, and Confirmation of
Acceptable Knowledge Documentation, Figure 6-1, provides an overview of
the process for assembling acceptable knowledge documentation into an
auditable record.  The first step is to assemble all of the required
acceptable knowledge information and any supplemental information
regarding the materials and processes that generate a specific waste
stream.

Procedures are implemented to establish acceptable knowledge records in
compliance with the following criteria:

Acceptable knowledge information is compiled in an auditable record,
including a road map for all applicable information (refer to Sections
B4-3b(1) 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).

Correlations between waste streams, with regard to time of generation,
waste generating processes, and site-specific facilities is described in
the WSRIC Building Books and the BWRBB (refer to Section B4-3b(1) for a
listing of the procedures).   For newly generated waste, the rate (or
schedule) and quantity of waste to be generated is maintained by the
Waste Requirements Group according to PRO-484-WIPP-003, Collection,
Review, and Confirmation of Acceptable Knowledge Documentation.

A reference list is provided in Section B4-3b, Sections B4-3b(1) through
B4-3b(9),  that identifies documents, databases, Quality Assurance
protocols, and other sources of information that support the acceptable
knowledge information.

Container inventories for TRU waste currently in retrievable storage can
be found in the WEMS database.  These container inventories can be
delineated into waste streams by correlating the container
identification to all of the required acceptable knowledge information
and any supplemental acceptable knowledge information.

B4-3d	Requirements for Confirmation of Acceptable Knowledge

Waste characterization of retrievably stored waste (i.e., RTR or visual
examination, headspace gas sampling and analysis, and homogeneous
sampling and analysis) will be used to confirm acceptable knowledge
information.  All retrievably stored TRU waste containers undergo either
nondestructive examination by RTR or visual examination to confirm the
Waste Matrix Code and waste stream and certify compliance with the
WIPP-WAP.  If retrievably stored waste must be repackaged, then either
visual verification of the waste prior to or during waste packaging or
radiography (or VE in lieu of RTR) after waste packaging (refer to
Section B-3c) will be used to confirm acceptable knowledge. 
PRO-484-WIPP-003, Collection, Review, and Confirmation of Acceptable
Knowledge Documentation, Figure 6-2, illustrates the process RFETS uses
to confirm acceptable knowledge for retrievably stored waste.  The
procedures used for this confirmation of acceptable knowledge are listed
in Section B4-3b(6).

Waste characterization for newly generated waste (i.e., visual
verification during packaging or radiography after packaging,
homogeneous waste sampling and analysis, and headspace gas sampling and
analysis, if appropriate) will be used to confirm acceptable knowledge. 
For newly generated waste that RFETS elects to confirm AK during
packaging, RFETS has written procedures to document the confirmation of
acceptable knowledge information with visual examination prior to or
during waste packaging (refer to Section B4-3b(6)).  PRO-484-WIPP-003,
Collection, Review, and Confirmation of Acceptable Knowledge
Documentation, Figure 6-3, illustrates the process RFETS uses to confirm
acceptable knowledge for newly generated waste.  The procedures used for
this acceptable knowledge 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(1)); 

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(1));

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
PRO-484-WIPP-003 as listed in 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 RTR and Visual Examination

RFETS has established procedures for reevaluating acceptable knowledge
if RTR or visual examination results in the assignment of a different
Waste Matrix Code [e.g., Plastic/Rubber (S5310) versus Paper/Cloth
(S5330)].  RFETS procedures, as listed in B4-3b(4) and B4-3b(6),
describe how the waste is reassigned, acceptable knowledge reevaluated,
and appropriate hazardous waste codes assigned.  If a waste must be
assigned to a different Waste Matrix Code based on RTR or visual
examination, the following minimum steps are taken to reevaluate
acceptable knowledge: 

Existing information is reviewed based on the container identification
number and all differences in hazardous waste code assignments are
documented.

If differences exist in the hazardous waste codes that were assigned,
the information is reassessed,  and all required acceptable knowledge
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 RTR or visual examination).

All changes to acceptable knowledge records are recorded.

If discrepancies exist in the acceptable knowledge 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 (refer to PRO-U76-WC-4030, Control of Waste
Nonconformances).

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.  The Waste Matrix Code and physical form of the waste
(waste material parameter) are related to the base materials and waste
generating process, and RFETS assigns a Waste Matrix Code and waste
stream to each container of waste using acceptable knowledge.

In lieu of confirmatory sampling and analytical or other data to the
contrary, RFETS assigns toxicity characteristic EPA hazardous waste
numbers based on the presence of constituent, regardless of the quantity
or concentration.  RTR or VE are used to confirm the waste matrix code,
physical form of waste (waste material parameter), and waste stream
identified using acceptable knowledge.  If the waste stream designation
is so detailed that the specific components cannot be differentiated by
RTR (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)	Headspace Gas Sampling 

Headspace gas sampling and analysis is conducted on all TRU mixed waste
or randomly selected containers from waste streams that meet the
conditions for reduced headspace gas sampling listed 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 acceptable knowledge.

RFETS waste generators use acceptable knowledge taken from the WSRIC
Building Books to identify spent solvents and assign EPA hazardous waste
numbers associated with each TRU waste stream on the Waste/Residue
Traveler form which is completed for every container as the waste is
packaged or repackaged.  Headspace gas sampling and analysis is
conducted on TRU waste containers according to PRO-1676-HGAS-S&A,
Headspace Gas Sampling and Analysis Using an On-Line Integrated System;
L-4231, Headspace Gas Sampling and Analysis Using an Automated Manifold;
PRO-1351-440-SWB, Room 113 Perma-Con Operations; PRO-717-HDGAS-371,
Headspace Gas Sampling, Building 371; L-4146, Headspace Gas Sampling of
Waste Containers3; PRO-1141-WP-4701, Waste Characterization Gas
Sampling; PRO-1669-HGAS-V&V, Headspace Gas V&V (Data Generator Level);
L-4053, Headspace Gas V & V (Data Generator Level); and L-5017, HVOC
Data Review and Validation (Data Generator Level)3.  PRO-945-WIPP-009,
RCRA Characterization of TRU Waste to be Disposed of at WIPP, provides
specific instructions for the confirmation of EPA hazardous waste
numbers for spent solvents using headspace gas analytical results.

RFETS uses acceptable knowledge to identify spent solvents associated
with each TRU waste stream or waste stream lot.  Headspace gas data is
then used to confirm acceptable knowledge concerning the presence or
absence of F-listed solvents and applicable toxicity characteristic
constituents.  RFETS confirms the assignment of F-listed hazardous waste
codes (20.4.1.200 NMAC, 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 acceptable knowledge
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, radiolysis, 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, RFETS may assess
whether the headspace gas concentration would render the waste
non-hazardous for those characteristics and change the AK determination
accordingly.

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 acceptable knowledge and assign hazardous
waste codes, as applicable.  If the total/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 acceptable knowledge 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 are
present in excess of regulatory levels, then RFETS 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.  Each site documents, justifies, and consistently
delineates waste streams and assign hazardous waste codes based on
site-specific permit requirements and other state-enforced agreements.

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, RFETS will
not remove hazardous waste codes assigned using acceptable knowledge if
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 constituents with
elevated concentrations.  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 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 PRO-945-WIPP-009, RCRA Characterization
of TRU Waste to be Disposed of at WIPP.

B4-3e	Acceptable Knowledge Data Quality Requirements

The data quality objectives 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 acceptable knowledge.
 Acceptable knowledge 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 acceptable
knowledge documentation is to provide a clear and convincing argument
about the characteristics of the waste.  To ensure that the acceptable
knowledge process is consistently applied, RFETS complies with the
quality requirements presented below for acceptable knowledge
documentation.

B4-3e(1)	Precision

Precision is the agreement of a set of replicate measurements without
assumption of the knowledge of a true value.  The qualitative
determinations of acceptable knowledge, such as compiling and assessing
knowledge documentation, do not lend themselves to statistical
evaluation of precision.	

B4-3e(2)	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 /or designation of different EPA
hazardous waste numbers based on the re-evaluation of acceptable
knowledge or on obtaining sampling and analysis data will be reported as
a measure of acceptable knowledge accuracy in Acceptable Knowledge
Accuracy Reports published by the TWCP.

B4-3e(3)	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 acceptable knowledge record
contains the required TRU waste management program information and the
TRU waste stream information in the WSRIC Building Books, the BWRBB, and
RF/RMRS-97-018, RFETS TRU Waste Acceptable Knowledge Supplemental
Information.  The acceptable knowledge record contains 100 percent of
the information specified in Section B4-2.  This information has been
summarized for TRU waste streams in RMRS-WIPP-98-100, Acceptable
Knowledge TRU/TRM Waste Stream Summaries.  Each of the TRU/TRM waste
streams will be summarized in this document.

B4-3e(4)	Comparability

Data are considered comparable when one set of data can be compared to
another set of data.  Comparability is ensured at RFETS through meeting
the training requirements and complying with the minimum standards in
the procedures that are used to implement the acceptable knowledge
process.  RFETS has assigned waste matrix codes, assigned EPA hazardous
waste numbers, and identified the physical form of waste (waste material
parameter) in accordance with Section B4-3b(5) and (7).  The INEEL has
been provided all of this information regarding the wastes that RFETS
has sent to the INEEL for storage.

B4-3e(5)	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 acceptable knowledge
information is performed in accordance with the minimum standards
established in Section B4-3b.  RFETS has also assessed and documented
the limitations of the acceptable knowledge information used to assign
waste matrix codes and EPA hazardous waste numbers and to identify
physical form of waste (waste material parameter).

RFETS addresses quality control by tracking its performance with regard
to the use of acceptable knowledge by: 1) assessing the frequency of
inconsistencies among information, and 2) documenting the results of
acceptable knowledge confirmation through RTR or VE, headspace gas
analyses, and homogeneous waste analyses.  In addition, the acceptable
knowledge 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).

B4-3f	Audits of Acceptable Knowledge

CBFO will conduct an initial audit of RFETS prior to certifying RFETS
for shipment of TRU waste to the WIPP facility.  This initial audit will
establish an approved baseline that will be reassessed annually.  These
audits verify compliance with the WAP, ensure the consistent
compilation, application, and interpretation of acceptable knowledge
information throughout the DOE complex, and evaluate the completeness
and defensibility of site-specific acceptable knowledge documentation
related to hazardous waste determinations.

The Kaiser-Hill QA organization performs a periodic independent audit,
or several small scope audits, of TWCP activities.  Kaiser-Hill QA
acceptable knowledge audit checklists include the elements listed below
for review during the periodic audit, and the TWCP provides information
as requested by Kaiser-Hill QA to satisfy the acceptable knowledge
audit/surveillance requirements:

Documentation of the process used to compile, evaluate, and record
acceptable knowledge is available and implemented.

Personnel training and qualifications are documented.

All of the required acceptable knowledge 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.

 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 acceptable knowledge information
through:  a) RTR 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 TWCP at RFETS are available in site
records.

B4-4	Additional Final Confirmation of Acceptable Knowledge at the WIPP
Facility

Prior to shipping waste, RFETS provides all of the required data
associated with waste stream characterization, including summary
acceptable knowledge information, RTR 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, RFETS designates
the assigned hazardous waste codes for the waste stream on the WIPP WSPF
(refer to Figure B-1; PRO-944-WIPP-008, Completion of Waste Stream
Profile Form for Waste to be Disposed of at WIPP; and PRO-484-WIPP-003,
Collection, Review, and Confirmation of Acceptable Knowledge
Documentation.).

As part of the reconciliation of DQOs (refer to Section B3-10), RFETS
tracks and reports changes to hazardous waste characterizations.  If
data consistently indicate that discrepancies with acceptable knowledge
information are identified by RFETS (and were subsequently reconciled),
RFETS reassesses the materials and processes that generate the waste,
resubmits waste stream profile information, and implement the corrective
action system.  If review of a WSPF and associated waste
characterization data reveal nonconformance with acceptable knowledge
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 WIPP-WAP have been met.  Any
container with unresolved discrepancies associated with hazardous waste
characterization will not be shipped to the WIPP facility until the
discrepancies are resolved.



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B5.	quality assurance project plan requirements 

B5-1	Site-Specific Quality Assurance Project Plan

RFETS has developed and implemented this document to addresses the
applicable requirements specified in the WIPP-WAP.   This document
includes the qualitative or quantitative criteria to ensure that waste
characterization program activities are being performed satisfactorily. 
The organizations and positions responsible for the implementation of
the qualitative and quantitative criteria are identified in Section A-5
of this document.  Throughout this document, site-specific documents are
referenced that detail how each of the required elements of the
characterization program are performed.  

All members of the RFETS TWCP project staff are responsible for
reporting any obsolete or superseded information to the TWCP Site PM. 
The TWCP Site PM shall notify the appropriate personnel and the affected
documents shall be revised as necessary.  The TWCP Site PM implements
continuing training for document changes in accordance with the TWCP
TIP, Section 7.6, Continuing Education.

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 TRU waste
characterization program are controlled to assure that the correct and
current documents are used and referenced.  RFETS compliance with the
WIPP-WAP requirements for document review, approval, and control begins
with QAPM.

The QAPM establishes the QA requirements to ensure that activities
affecting quality are prescribed and performed in accordance with
documented instructions, procedures, and drawings.  These requirements
are addressed in approved RFETS policies and procedures for the
initiation, preparation, review, and revision control of instructions,
procedures, and drawings for all quality-related activities. 
Implementing procedures for document review, approval, and control
include the following:

MAN-001-SDRM, Site Document Requirements Manual.

PRO-815-DM-01, Developing and Maintaining Documents

PRO-1329-DM-03, Site Document Control

L-1000, Requirements for Laboratory L-Procedures.

Procedures are organized as directed by the above the documents to
include a title page, version change summary, table of contents,
purpose, scope, and instructions.  The procedures are formatted as
action statements with performers identified, and numbered where the
order of performance is mandatory.  The content and designation of
procedures are determined by specific activities and the associated
Responsible Manager.

B5-2	Document Review, Approval, and Control (continued)

Documents that support the TWCP (i.e., designated as WIPP-related), as
well as revisions and intent changes to such documents, are reviewed and
concurred with by qualified and independent individuals including the
TWCP Site PM and the TWCP Site PQAO.  Changes that affect performance
criteria or data quality, such as sample handling and custody
requirements, sampling and analytical procedures, quality assurance
objectives, calibration requirements, or QC sample acceptance criteria
comply with the WIPP-WAP and shall not be implemented without prior
approval of the WIPP facility.  The document number, revision or version
number, date, and page number, are included on every page of these
documents.  Changes to WIPP-WAP related plans and procedures that could
impact DQOs either positively or negatively shall be reported to CBFO
within five (5) days of identification.  TWCP determines when such
review is necessary, and coordinates such review. Documentation of such
review/concurrence is placed in the Document History File, but not
reflected on the document cover page or Document Change Form.

The TWCP Site PM notifies the DOE RFFO of  program changes through
submittal, review, and approval of the QAPjP and the TWMM.  No changes
that affect performance criteria or data quality shall be made without
prior approval of the DOE, RFFO and CBFO.

The QAPjP review shall consider the technical adequacy, completeness,
and correctness of the QAPjP, and the inclusion of and compliance with
the requirements established by the WIPP-WAP.  Table B5-1 presents the
minimum requirements for review, approval and implementation of the
QAPjP.  The QA Grading procedure also requires the same approvals as
listed in Table B5-1, except for approval by the National TRU Program
Team Leader.

Changes to documents shall be reviewed and approved by the same
functional organizations that performed the original review and
approval, unless other organizations are specifically designated 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 nonqualilty affecting schedules

Revised or reformatted forms, providing the original intent of the form
has not been altered

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
responsibilities is not considered an editorial change.  Changes to the
text shall be clearly indicated in the document.

B5-3	Quality Assurance Records Management

RFETS compliance with WIPP-WAP records requirements is provided by the
following:

1-V41-RM-001, Records Management Manual.

PRO-077-WIPP-005, Management of Waste Information Prior to Transmittal
to the Waste Records Center.

PRO-767-WIPP-001, Waste Records Center Processing.

L-4026, Records Handling, Storage, and Retrieval for the WIPP Project
Files.

When records are microfilmed, the records are microfilmed according to
PRO-1191-WRCM, WIPP Records Micrographics.

Forms developed for specific use by the TWCP are controlled by inclusion
in applicable procedures.  Special record-keeping requirements for TWCP
training are described in the TWCP TIP, Section 7.8, Records Processing
Instructions.

An electronic copy of the data sent to CBFO, as well as all QA/QC
records obtained from testing, sampling, and analytical facilities, will
be retained in the Waste Records Center.  Electronically transmitted
data will be compatible with and formatted in accordance with the WIPP
computer system requirements.  Additional information on meeting
electronic data reporting requirements is discussed in Section B3-12 of
this document.

B5-3a	Waste Records Center

Records related to waste characterization sampling and analysis
activities are maintained in the Waste Records Center.  In process
records are managed in accordance with PRO-077-WIPP-005, Management of
Waste Information Prior to Transmittal to the Waste Records Center.  The
PDCO is responsible for maintaining and updating the records inventory
and disposition schedule (RIDS) in accordance with PRO-077-WIPP-005,
Management of Waste Information Prior to Transmittal to the Waste
Records Center; and PRO-767-WIPP-001, Waste Records Center Processing.

PRO-767-WIPP-001, Waste Records Center Processing, provides processing
instructions to ensure consistency in records processing.  All WIPP QA
records are designated as either QA-Lifetime or QA Non-Permanent
records.  A listing of QA-Lifetime and QA Non-Permanent records is found
in the procedures listed above, and in Table B-7 of this document.

TWCP maintains project records according to requirements specified in
RFETS documents listed above.  Record retention requirements and
schedules (i.e., RIDS) are developed and maintained according to CBFO
guidelines.  Completed RIDS are transmitted to CBFO for review and
subsequent submittal to the National Archives and Records Administration
(NARA).  Existing conflicts with record retention periods are pending
RIDS approval by NARA.  Prior to RFETS closure, records are offered to
CBFO for permanent archiving of information and/or transferred to the
appropriate FRC.

B5-3b	Flow of Data Records

Figure B5-1 illustrates the flow of data records, beginning with data
generation and ending with final transmittal of data to CBFO.  All waste
characterization documentation such as COC forms generated or updated
will be forwarded to the TWCP Site PQAO for validation and verification.
The TWCP Site PQAO will then prepare a TWCP Site PQAO Summary, include
it in the Batch Data Report, and forward waste characterization
documentation and a signature release to the TWCP Site PM.  The TWCP
Site PM will prepare a Data Validation Summary and transmit data with a
TWCP Site PM and TWCP Site PQAO signature release to the Waste Records
Center. Characterization data for each waste container is transmitted
from WEMS to CBFO via the WWIS.  CBFO must notify the TWCP Site PM in
writing that the data are acceptable.

The WEMS database is maintained on a file server and backed up nightly
in accordance with RFETS-SOP-BACKUP-001, Server Backup Standard
Operating Procedure.

RFETS  is currently working on a standard site method for storage and
transmission of electronic records and is aware of a DOE Complex wide
effort to develop requirements for the same.  RFETS will meet those
requirements when they are established.  In the interim, the records are
retrievable and will be transmitted according to CBFO guidelines.  

B5-4	QA Reports to Management

The TWCP Site PQAO periodically provides CBFO and the TWCP Site PM with
a summary presentation of the status of the program.  These reports to
management are normally presented during meetings of all Department of
Energy site PQAOs called by CBFO.

Reports on trends in nonconformances and corrective actions provided
monthly to the TWCP Site PM and other appropriate site management. 
Procedure PRO-943-WIPP-007, TWCP Trending and Analysis of
Quality-Affecting Problems, provides instructions for preparation and
distribution of the reports.

B5-5	QA Grading

RFETS utilizes a graded approach in the application of standards
identified as applicable to an activity.  The application of these
standards is limited to those which are necessary and sufficient to
acceptably perform the activity.  The graded approach is implemented by
PRO-486-WIPP-006, TRU Waste Characterization Project Quality Assurance
Grading.

A process by which the level of analysis, documentation, and actions
necessary to comply with requirements are commensurate with:

the relative importance of an item or activity with respect to safety,
safeguards, security, waste isolation, and other mission objectives.

the importance of the data to be generated.

the need to demonstrate compliance with specific regulatory design and
QA requirements.

the impact on the results of performance assessments and engineering
analyses.

the magnitude of any hazard or the consequences of failure.

the life-cycle stage of a facility or item.

the programmatic mission of a facility.

the particular characteristics of a facility, item or activity (e.g.,
complexity, uniqueness, history, or the necessity for special controls
or processes).

any other relevant factors.



Table B5-1, Minimum Requirements for Review, Approval, Implementation
and Control of QAPjP

RESPONSIBLE PARTY

Manager, 

CBFO QA	Team Leader, National TRU Program	

DOE, RFFO PM	TWCP Site

 PM	TWCP Site 

PQAO

Review/Approval	X	X	X	X	X

Implementation



X

	Change Approval	X

X	X	X

Change Control



X

	



Figure B5-1, Flow of Data Records for the Project



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B6.	RFETS audit and surveillance program 

RFETS is audited both internally and externally to ensure 1) that the
RFETS TWCP meets the requirements specified in the WIPP-WAP, and 2) that
RFETS supplies information to the WIPP facility to satisfy the waste
screening and acceptability requirements specified in Section B-4 of the
WIPP-WAP.

B6-1	Internal Management Assessments and Independent Surveillances  

The Material Stewardship QA Manager ensures that a minimum of one QA
assessment occurs each year to determine the effectiveness of quality
systems. The QA assessment is conducted by an independent assessments
group in accordance with 3-B52-IA-003, Conduct of Independent Assessment
Activities.  The results of the assessment are reported to the TWCP Site
PM and maintained as part of the TWCP files.  The annual QA assessment
requirement may be satisfied by conducting several smaller scope audits
during the year.

Management assessments are performed at RFETS in accordance with
3-W24-MA-002, Kaiser-Hill Management Assessment Program; and
1-MAN-008-WM-001, Transuranic (TRU) Waste Management Manual.

Surveillances are brief reviews of limited scope that assess program
performance to requirements.  Surveillances of the TWCP are conducted to
provide an additional mechanism to identify and prioritize corrective
actions.  Surveillance topics are requested by program management to
obtain information about suspected deficiencies, to verify program
implementation, or to confirm completion of corrective actions for
previously identified deficiencies.  Surveillances are performed by QA
personnel in accordance with PRO-985-SURV, Performance of Surveillances.

The TWCP Site PQAO maintains oversight of headspace and analytical
laboratory functions through routine project level data validation and
verification activities.  The PQAO also performs a quarterly repeat of
the data generation level review, validation, and verification in
accordance with PRO-940-WIPP-010, WIPP TRU Waste Characterization
Project Level Data Review and Reporting.

B6-2	External Audits 

The Site facilities, operations, and quality functions for the TWCP
covered by this QAPjP require auditing by a WIPP Audit Team and NMED
approval of the final audit report prior to shipment of waste from the
Site and annually, or as scheduled or conducted, thereafter.  CBFO is
responsible for coordinating and performing this audit in accordance
with the WIPP-WAP.  Corrective action is required if any conditions
adverse to quality are detected during the audit.

Only personnel with appropriate U.S. Department of Energy clearances and
the need-to-know will have access to classified information during
audits.  Classified information will not be included in audit reports
and records.

The audit checklists used at RFETS include, at a minimum for the
applicable summary category groups, the checklists found in Tables B6-1
through B6-6 of the WIPP-WAP.

B6-2	External Audits (continued)

Audits shall include RFETS personnel interviews, document and record
reviews, observations of operations, and any other activities deemed
necessary by the auditors to meet the objectives of the audit. 
Observations or deficiencies identified during the audit will be
investigated or evaluated, as necessary, to determine if they are
isolated conditions or represent a general breakdown of the waste
characterization quality assurance program.  

RFETS personnel will be given the opportunity to correct any deficiency
that can be corrected during the audit period.  Deficiencies and
observations will be documented and included as part of the final audit
report.  Those items that have been resolved during the audit (isolated
deficiencies that do not require a root cause determination or actions
to preclude recurrence), will be verified prior to the end of the audit,
and the resolution will be described in the audit report.  Those items
that affect the quality of the TWCP, and/or the data generated by the
TWCP, which are required by the WIPP-WAP will be documented on a
Corrective Action Report (CAR) and included as a part of the final audit
report.

When a deficiency is identified by the audit team, the audit team member
who identified the deficiency prepares the CAR.  RFETS reviews the CAR,
evaluates the extent and cause of the deficiency, and provides a
response to CBFO indicating the remedial actions and actions taken to
preclude recurrence.  CBFO reviews the response and, if acceptable,
communicates acceptance.  RFETS completes remedial actions and actions
to preclude recurrence.  After all corrective actions have been
completed, CBFO may schedule and perform a verification visit to assure
that corrective actions have been completed and are effective.  NMED
personnel may participate as observers in these verification visits.

RFETS shall submit corrective action plans to eliminate the deficiency
stated on the CAR, including a resolution of the acceptability of any
data generated prior to the resolution of the 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.

RFETS will respond to any deficiencies and observations within thirty
(30) 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 must indicate the expected date the action will be
completed.  CARs applicable to WIPP-WAP requirements are resolved prior
to waste shipment.

C.	RECORDS PROCESSING

The following documents are initiated, processed or maintained as a
result of this manual and SHALL be processed as follows:

Records Identification	Record Type Determination	Protection / Storage
Methods	

Processing Instructions

NONE	N/A	N/A	N/A





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D.	REFERENCES

D-1	External References

10 CFR Part 830.  April 1994.  Nuclear Safety Management.  Code of
Federal Regulations, Washington, D.C., Office of the Federal Register
National Archives and Records Administration.

20.4.1 NMAC New Mexico Hazardous Waste Management Regulations, Title 20,
New Mexico Administrative Code, Chapter 4, Part 1, Sections 200, 300,
500, and 800

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.

40 CFR Part 264.  December 1994.  Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities.  Code of
Federal Regulations, Washington, D.C., Office of the Federal Register
National Archives and Records Administration.

40 CFR Part 265.  Code of Federal Regulations, Washington, D.C., Office
of the Federal Register National Archives and Records Administration.

40 CFR Part 268.  January 1995.  Land Disposal Restrictions.  Code of
Federal Regulations, Washington, D.C., Office of the Federal Register
National Archives and Records Administration.

40 CFR Part 270.  December 1994.  EPA Administered Permit Programs: The
Hazardous Waste Permit Program.  Code of Federal Regulations,
Washington, D.C., Office of the Federal Register National Archives and
Records Administration.

ANSI.  1993.  American National Standard, Sampling Procedures and Tables
for Inspection by Attributes, ANSI/ASQC Z1.4-1993, American National
Standards Institute

ASTM.  1983a.  Test Method for Chemical Composition of Gases by Mass
Spectrometry, ASTM D2650-83, American Society for Testing and Materials

ASTM.  1983b.  Type I or Type II Water, ASTM D1193-77, American Society
for Testing and Materials

D-1	External References  (continued)

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

ASTM.  1995.  Standard Practice for Sampling Consolidated Solids in
Drums or Similar Containers, ASTM D5679-95a, Annual Book of ASTM
Standards, Philadelphia, Pennsylvania, American Society for Testing and
Materials

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.  2000. Standard Guide for Selection of Sampling Equipment for
Waste and Contaminated Media Data Collection Activities, ASTM D6232-00,
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-2000-01207, Liekhus, K.J.,
S.M. Djordjevic, M. Devarakonda, and M.J. Connolly, Bechtel BWXT Idaho,
LLC, Idaho National Engineering and Envirnmental Laboratory.

CAO-00-029.  WIPP Clarification, Control Charting for Newly Generated
Waste (Section B-3d(1)), Carlsbad, New Mexico, Carlsbad Area Office,
U.S. Department of Energy

CAO-95-1076.  Performance Demonstration Program Plan for the Analysis of
Simulated Headspace Gases for the TRU Waste Characterization Program,
Carlsbad, New Mexico, Carlsbad Area Office, U.S. Department of Energy

CAO-95-1077.  Performance Demonstration Program Plan for the RCRA
Constituent Analysis of Solidified Wastes, Carlsbad, New Mexico,
Carlsbad Area Office, U.S. Department of Energy

DOE.  1995a.  (See DOE/LLW-217)

DOE.  1995b.  (See DOE/CAO-94-1005)

DOE.  1997a.  WIPP RCRA Part B Permit Application.  Carlsbad, New
Mexico, Carlsbad Area Office, U.S. Department of Energy

DOE.  1999a (see CAO-95-1076)

DOE.  1999b.  (See CAO-95-1077)

D-1	External References  (continued)

DOE.  2001.  U.S. Department Of Energy.  WIPP Waste Information System
User’s Manual for Use by Shippers/Generators.  Carlsbad, New Mexico,
Carlsbad Field Office, U.S. Department of Energy

DOE.  2003a.  U.S. Department of Energy.  Carlsbad Field Office. 
Attachment to the Statement of Work for the INEEL TRU Waste
Characterization Program.

DOE.  2003b.  (See DOE/CBFO-94-1012)

DOE/CAO-94-1005.  Waste Isolation Pilot Plant Transuranic Waste Baseline
Inventory Report., Carlsbad, New Mexico, Carlsbad Area Office, U.S.
Department of Energy

DOE/CBFO-94-1012.  Quality Assurance Program Document, Carlsbad, New
Mexico, Carlsbad Field Office, U.S. Department of Energy

DOE/LLW-217.  DOE Waste Treatability Group Guidance, Idaho Falls, ID,
INEL-Lockheed Idaho Technologies Company, U.S. Department of Energy

DOE/WIPP-02-3122, Contact-Handled Transuranic Waste Acceptance Criteria
for the Waste Isolation Pilot Plant, Current Revision, Waste Isolation
Pilot Plant, U.S. Department of Energy

DOE/WIPP 89-004, TRUPACT-II Content Codes (TRUCON), Current Revision,
Waste Isolation Pilot Plant, U.S. Department of Energy

EG&G.  1993.  Preliminary Assessment of Real-Time Radiography and Visual
Characterization for Selected Waste Containers, RFP-4604, Golden,
Colorado, D. L. Ziegler and R. V. Harder, EG&G Rocky Flats, Rocky Flats
Plan

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.  9240.05A, Office of Solid Waste and
Emergency Response, U.S. Environmental Protection Agency

EPA.  1994.  Waste Analysis:  EPA Guidance Manual for Facilities that
Generate, Treat, Store and Dispose of Hazardous Waste, OSWER 9938.4-03,
Office of Solid Waste and Emergency Response, 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

D-1	External References  (continued)

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

EPA.  1999.  USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review, EPA 540/R-99/008, U.S. Environmental
Protection Agency

EPA.  2002. USEPA Contract Laboratory Program National Functional
Guidelines for Inorganic Data Review, EPA 540-R-01-008, U.S.
Environmental Protection Agency

Gilbert.  1987.  Richard O. Gilbert.  1987.  Statistical Methods for
Environmental Pollution Monitoring.  Van Nostrand Reinhold, New York

Glaser.  1981.  J.A. Glaser, D.L. Foerst, G.D.  McKee, W.A.  Quave, and
W.L. Budde.  1981.  Environmental Science and Technology, Vol. 15, No.
12: p.  1426

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.  1999.  Waste Isolation Pilot Plant (WIPP) Hazardous Waste Permit,
New Mexico Environment Department, #NM4890139088-TSDF

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

D-2	RFETS References

1-A65-ADM-15.01, Control of Nonconforming Items

1-C80-WO-1102-W/RT, Waste/Residue Traveler Instructions

1-M12-WO-4034, Solid Radioactive Waste Packaging Requirements Manual

1-M60-WPC-001, Waste Process Control

1-MAN-008-WM-001, Transuranic (TRU) Waste Management Manual

1-MAN-026, Rocky Flats Environmental Technology Site Security Manual

1-MAN-036-EWQA-Section 1.6.1, Waste Characterization Program Manual

1-PRO-079-WGI-001, Waste Characterization, Generation, and Packaging

1-PRO-087-WEMS-WP-1201, WEMS Waste Package Inventory, Tracking, and
Control

1-PRO-Q11-WO-1221, Controls for Updating Waste Package Information in
WEMS

1-V10-ADM-15.02, Stop Work Action

1-V41-RM-001, Records Management Manual

1-W37-IA-002, Integrated Planning and Scheduling of Assessment
Activities

3-B52-IA-003, Conduct of Independent Assessment Activities

3-W24-MA-002, Kaiser-Hill Management Assessment Program

3-X31-CAP-001, Corrective Action Process

4-9500-MLP-12001, Check Weight Calibration

4-D15-BBPE-001, WSRIC Building Book Preparation and Editing  [Superseded
by PRO-1003-WSRIC-ADMIN, WSRIC Administration Guidance]

4-D99-WO-1100, Solid Radioactive Waste Packaging Procedure

D-2	RFETS References  (continued)

4-G83-WEM-WP-1209, WEMS Waste Package Verification and Certification

4-H19-WSRIC-001, WSRIC Characterization and Reverification

4-H80-776-ASRF-007, Visual Examination for Confirmation of RTR  [This
procedure is inactive as of November 6, 2001.]

4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 569  [This procedure is inactive as of April
30, 2003.]

4-K47-WEM-WP1210, WEMS Offsite Shipping Module

4-W30-NDT-00664, Real-Time Radiography Testing of Transuranic and
Low-Level Waste in Building 664

4-W84-RS-0114, Salt Residue Stabilization/Repack, Building 707  [The
Salt Residue stabilization/repack activity that utilized this procedure
was completed in June 2000.]

5-NDT-TC-1A, Training, Qualification and Certification of Nondestructive
Testing Personnel

95-WP/SAP-001, Transuranic (TRU/TRM) Waste Sampling Plan

ELD-057-01, Interoffice Memorandum From E.L. D’Amico to Waste Records
Center, Rigid Liner Lid Hole Size, June 2001

GAO-032-01, Interoffice Memorandum From G.A. O’Leary to C.A.Turner,
Addition of Tentatively Identified Compound (TIC) to the Solid Volatile
Organic Compound (VOC) Target Analyte List For TRU Stabilized
Pyrochemical Salts Waste Stream (RF005.01), March 2001

GAO-057-00, Interoffice Memorandum from G.A. O’Leary to C.A.Turner,
Addition of Tentatively Identified Compound (TIC) to the Solid Volatile
Organic Compound (VOC) Target Analyte List For TRU Pyrochemical Salts
(Repackaged) Waste Stream (RF009.01), September 2000

GAO-069-01, Interoffice Memorandum from G.A. O’Leary to C.A.Turner,
Addition of Tentatively Identified Compound (TIC) to the Solid
Semi-Volatile Organic Compound (SVOC) Target Analyte List For
Transuranic Mixed (TRM) Incinerator Ash (D004-D011, F001, F002, F005)
Waste Stream (RF118.01), August 2001

D-2	RFETS References  (continued)

GAO-070-01, Interoffice Memorandum from G.A. O’Leary to C.A.Turner,
Addition of Tentatively Identified Compound (TIC) to the Solid Volatile
Organic Compound (VOC) Target Analyte List For Transuranic Mixed (TRM)
Incinerator Ash (D004-D011, F001, F002, F005) Waste Stream (RF118.01),
August 2001

L-1000, Requirements for Laboratory L-Procedures  [This procedure is to
be deactivated in February 2004.]

L-2421, Precision Gas Mass Spectrometry Operations and Analysis (VG
30-38)  [This procedure is no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS]

L-4006, Chain-of-Custody and Sample Administration for Headspace Sample
Canisters  [This procedure is no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS]

L-4026, Records Handling, Storage, and Retrieval for the WIPP Project
File  [This procedure is to be deactivated in February 2004.]

L-4028, Sample Administration for the Radiological Laboratories  [This
procedure is to be deactivated in February 2004.]

L-4035, Metals Data Verification and Validation Data Generation Level 
[This procedure is to be deactivated in February 2004.]

L-4038, WIPP Data Review and Validation for Volatile Organic Compounds 
[This procedure is to be deactivated in February 2004].

L-4039, WIPP Data Review and Validation for Semi-Volatile Organic
Compounds in Solid Samples [This procedure is to be deactivated in
February 2004.]

L-4053, Headspace Gas V & V (Data Generator Level)  [This procedure is
inactive as of June 18, 2003, superseded by PRO-1669-HGAS-V&V.]

L-4108, Toxicity Characteristic Leaching Procedure (TCLP) for Metals in
Waste  [This procedure is to be deactivated in February 2004.]

L-4111, GC/MS Determination of Volatile Organics For Waste
Characterization  [This procedure is no longer active.  As of October
22, 2002 headspace gas sampling with SUMMA( canisters has been
discontinued at RFETS]

L-4138, SUMMA® Passivated Stainless Steel Canister Cleaning and
Certification  [This procedure is no longer active.  As of October 22,
2002 headspace gas sampling with SUMMA( canisters has been discontinued
at RFETS]

L-4146, Headspace Gas Sampling of Waste Containers  [This procedure is
no longer active.  As of October 22, 2002 headspace gas sampling with
SUMMA( canisters has been discontinued at RFETS]

L-4148, Preparation of Samples and Calibration Standards for
Determination of Gases in Sample Canisters  [This procedure is no longer
active.  As of October 22, 2002 headspace gas sampling with SUMMA(
canisters has been discontinued at RFETS]

D-2	RFETS References  (continued)

L-4150, Total Metals Acid Digestion Procedure of Solid, Liquid, and TCLP
Extract Samples  [This procedure is to be deactivated in February 2004.]

L-4151, Waste Analysis by Atomic Absorption Spectroscopy  [This
procedure is to be deactivated in February 2004.]

L-4152, Mercury Analysis in Waste (Cold-Vapor Technique)  [This
procedure is to be deactivated in February 2004.]

L-4153, Trace Metals by ICP Spectrometry (Solids, Liquids, and TCLP
Extracts)  [This procedure is to be deactivated in February 2004.]

L-4165, GC/MS Determination of Volatile Organic Compounds (Solids,
Liquids, and TCLP Extracts)  [This procedure is to be deactivated in
February 2004.]

L-4214, Extraction of Total SVOCs for GC/MS Analysis for WIPP  [This
procedure is to be deactivated in February 2004.]

L-4215, GC/MS Determination of Total SVOCs for WIPP  [This procedure is
to be deactivated in February 2004.]

L-4217, Metals Analysis, Data Compilation and Reporting  [This procedure
is to be deactivated in February 2004.]

L-4231, Headspace Gas Sampling and Analysis Using an Automated Manifold 
[This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A]

L-5016, Data Review and Validation for Inorganic Gases for WIPP-TRU
Waste Characterization Program (TWCP) – Data Generation Level  [This
procedure is no longer active.  As of October 22, 2002 headspace gas
sampling with SUMMA( canisters has been discontinued at RFETS]

L-5017, HVOC Data Review and Validation (Data Generator Level)  [This
procedure is no longer active.  As of October 22, 2002 headspace gas
sampling with SUMMA( canisters has been discontinued at RFETS]

MAN-001-SDRM, Site Document Requirements Manual

MAN-094-TPM, Training Program Manual (known as the TPM)

MAN-131-QAPM, Quality Assurance Program Manual

MAN-T91-STSM-001, Site Transportation Safety Manual (STSM)

PLN-97-007, TRU Waste Characterization Program Training Implementation
Plan (TWCP TIP)

PRO-077-WIPP-005, Management of Waste Information Prior to Transmittal
to the Waste Records Center

PRO-264-RS-0141, Data Review and Verification of Residue Repack Batch
Reports

D-2	RFETS References  (continued)

PRO-404-RS-0145, Data Review and Verification Of Ash Residue Repack
Batch Reports  [This procedure is inactive as of May 2002.]

PRO-428-RS-0146, Data Review and Validation Of Ash Residue Repack Sample
Batch Reports  [The Ash Residue repack and sampling activities that
utilized this procedure stopped operation in Building 707 in December
2000.]

PRO-484-WIPP-003, Collection, Review, and Confirmation of Acceptable
Knowledge Documentation

PRO-486-WIPP-006, TRU Waste Characterization Project Quality Assurance
Grading

PRO-543-ASD-002, Initiation, Preparation, and Implementation of
Chain-of-Custody Forms

PRO-544-SALT REPACK-371, Residue Repack, Building 371  [This procedure
is to be deactivated in February 2004.]

PRO-603-RS-0152, Data Review and Verification of Solid Sampling Batch
Reports

PRO-604-RC-001, Field Sample QC Data Calculation, Review, and Validation
Batch Reports

PRO-717-HDGAS-371, Headspace Gas Sampling, Building 371  [This procedure
is inactive as of May 12, 2003.]

PRO-767-WIPP-001, Waste Records Center Processing

PRO-815-DM-01, Developing and Maintaining Documents

PRO-823-REPACK-371, Combustible Residue Repackaging  [This procedure is
to be deactivated in February 2004.]

PRO-860-RS-0156, Solid Sampling, Building 371  [This procedure is to be
deactivated in February 2004.]

PRO-908-ASD-004, On-Site Transfer and Off-Site Shipment of Samples

PRO-940-WIPP-010, WIPP TRU Waste Characterization Project Level Data
Review and Reporting

PRO-943-WIPP-007, TWCP Trending and Analysis of Quality-Affecting
Problems

PRO-944-WIPP-008, Completion of Waste Stream Profile Form for Waste to
be Disposed of at WIPP

PRO-945-WIPP-009, RCRA Characterization of TRU Waste to be Disposed of
at WIPP

PRO-985-SURV, Performance of Surveillances

D-2	RFETS References  (continued)

PRO-1003-WSRIC-ADMIN, WSRIC Administration Guidance

PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Review

PRO-1141-WP-4701, Waste Characterization Gas Sampling  [This procedure
is no longer active.  As of October 22, 2002 headspace gas sampling with
SUMMA( canisters has been discontinued at RFETS]

PRO-1191-WRCM, WIPP Records Micrographics

PRO-1265-SS-001, Building 774 and Tank T-207 Aqueous Sludge Removal and
Characterization Plan

PRO-1266-SS-002, Tank Sludge Removal From Pre-Selected Areas, Building
774  [This procedure is inactive as of April 29, 2003.]

PRO-1329-DM-03, Site Document Control

PRO-1351-440-SWB, Room 113 Perma-Con Operations

PRO-1358-440-VERP, Glovebox and C-Cell Waste Operations

PRO-1418-WO-TRUOP, TRUPACT-II Operations

PRO-1471-VE-771, Visual Examination for Confirmation of RTR  [This
procedure is inactive as of November 14, 2003.]

PRO-1520-Mobile-RTR, Mobile Real-Time Radiography Testing of Transuranic
and Low-Level Waste

PRO-1569-SAP-001, Polymerized Organic and Inorganic Liquid Process –
Sampling and Analysis Plan

PRO-1585-PWS-440, Polymerized Waste Sampling Building 440

PRO-1608-VECRTR-371, RTR Visual Examination Confirmation, Building 371 
This procedure is inactive as of August 12, 2003.]

PRO-1618-PLP-001, Data Review and Verification of Solid Sampling Batch
Data Reports – TRU Projects

PRO-1623-SCWS-440, Small Container Waste Sampling - TRU Projects

PRO-1628-A2-001, Tank Sludge Removal From Pre-Selected Areas, Tank T-207
 [This procedure is inactive as of July 10, 2003.]

PRO-1669-HGAS-V&V, Headspace Gas V & V (Data Generator Level)

PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System

PRO-1729-903-SOIL, Soil Removal From Pre-Selected Areas, 903 Pad

PRO-1730-903-001, 903 Pad Soil Removal/Repack and Characterization Plan

D-2	RFETS References  (continued)

PRO-U76-WC-4030, Control of Waste Nonconformances

PRO-X05-WC-4018, Transuranic (TRU) Waste Certification

PRO-X32-RS-0128, Dry Residue Repackaging, Building 707  [The Dry Residue
repack activity that utilized this procedure stopped operation in
Building 707 in November 2000.]

PRO-X56-RS-0123, Ash Residue Repack, Building 707  [The Ash Residue
repack and sampling activities that utilized this procedure stopped
operation in Building 707 in December 2000.]

RFETS-SOP-BACKUP-001, Server Backup Standard Operating Procedure

RF/RMRS-97-018, RFETS TRU Waste Acceptable Knowledge Supplemental
Information

RMRS-WIPP-98-100, Acceptable Knowledge TRU/TRM Waste Stream Summaries

RS-012-004, Grid Method - Solid Sampling and Analysis Plan

RS-012-005, Cone and Quartering Method - Solid Sampling and Analysis
Plan  [This plan is inactive as of December 2003.]

RS-020-001, Gas Generation Testing Program Quality Assurance Project
Plan

RS-020-006, Salt Residue Stabilization, Building 707 Process
Control/Qualification Plan  [This operation has been completed, and the
document inactive as of May 2002.]

RS-020-012, Ash Residue Repack Process Control Plan

RS-020-013, Dry Residue Repacking Process Control Plan

RS-020-018, Combustible Residue Repackaging Process Control Plan

RS-020-021, Salt Residue Repack, Buildings 371 and 707 Process Control
Plan

SPEC-11170-0485, Solid Waste Handling Equipment (liner, 110 mil,
polyethylene, 55 gallon drum, straight wall, rigid, type IV,
WIPP-related use)

TRU Waste Project Management Assessment Schedule

TWCP Independent Assessment Schedule

TWCP Integrated Surveillance Schedule



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E.	Glossary

E-1	Acronyms and Abbreviations

AA	atomic absorption

AK	Acceptable Knowledge

ANSI	American National Standards Institute

ASME	American Society of Mechanical Engineers

ASRF	Advanced Size Reduction Facility

ASTM	American Society for Testing and Materials

BCF	BWRBB Change Form

BFB	bromofluorobenzene

BIR	Waste Isolation Pilot Plant Transuranic Waste Baseline Inventory
Report (DOE 1995b)

BWRBB	Backlog Waste Reassessment Baseline Book

(C	degrees Centigrade

%C	percent complete

CAO	Carlsbad Area Office (historic acronym)

CAS	Chemical Abstract Services

CBFO	Carlsbad Field Office (current acronym)

CCC	Calibration Check Compounds (refer to the specific methods in SW-846
for the listings of CCCs)

cc/sec	cubic centimeter per second

CCV	Continuing Calibration Verification

CFR	Code of Federal Regulations

CH	contact handled

CH TRU	Contract Handled Transuranic

CH4	methane

CO2	Carbon Dioxide

COC	Chain-of-Custody

CRDL	contract required detection limit

Cr-NiO	chromium-nickel oxide

CVAA	Cold Vapor Atomic Absorption Spectroscopy

%D	percent difference

D&D	Decontamination and Decommissioning

DFTPP	decafluorotriphenylphosphine

DOE	U.S. Department of Energy

DOT	U.S. Department of Transportation 

DQO	Data Quality Objective

E&E	education and experience

EPA	Environmental Protection Agency

E-1	Acronyms and Abbreviations  (continued)

FLAA	Flame Atomic Absorption Spectroscopy

FRC	Federal Records Center

ft lbs	foot pounds

FTIRS	Fourier Transform Infrared Spectroscopy

g	gram

Gas PDP Plan	Performance Demonstration Program Plan for the Analysis of
Simulated Headspace Gases for the TRU Waste Characterization Program
(DOE 1999a)

GC	Gas Chromatography

GC/ECD	Gas Chromatography/Electron Capture Detection

GC/FID	Gas Chromatography/Flame Ionization Detector

GC/MS	Gas Chromatography/Mass Spectrometry

GFAA	Graphite Furnace Atomic Absorption Spectroscopy

H2	hydrogen

HAA	Hydride Generation Atomic Absorption Spectroscopy

HEPA	High Efficiency Particulate Air

HPLC	High Pressure Liquid Chromatography

HQ	Headquarters

ICP-AES	Inductively Coupled Plasma-Atomic Emission Spectroscopy

ICP-MS	Inductively Coupled Plasma-Mass Spectroscopy

ICS	interference calibration standard

ICV	initial calibration verification

ID	identification

IDC	Item Description Code

IDL	Instrument Detection Limit

INEEL	Idaho National Engineering Laboratory

kg	kilogram

L	liter

LB	Laboratory Blank

LCS	Laboratory Control Sample

LDR	Land Disposal Restrictions

LLW	low-level waste

LPQAO	Laboratory Project Quality Assurance Officer

E-1	Acronyms and Abbreviations  (continued)

m	meter

µg/L	micrograms per liter

M&O	management and operating

MDC	Minimum Detectable Concentration

MDL	Method Detection Limit

mg/kg	milligrams per kilogram

mg/L	milligrams per liter

mL	milliliter

mm	millimeter

MMDDYY	Month-Day-Year Format

mm Hg	millimeters mercury

MS	Mass Spectrometry

mV	millivolts

NARA	National Archives and Records Administration

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

OCS	On-Line Control Sample

OSHA	Occupational Safety and Health Administration

OVA	Organic vapor analyzer

P	Pressure

PDCO	Project Data Control Officer

PDP	Performance Demonstration Program

PFTBA	Perfluorotributylamine

PID	photoionization detector

PM	Project Manager

POC	Pipe Overpack Component

ppm	parts per million

ppmv	parts per million by volume

PQAO	Project Quality Assurance Officer

E-1	Acronyms and Abbreviations  (continued)

PRDL	Program Required Detection Limit

Program	WIPP TRU Waste Characterization Program

PRQL	Program Required Quantitation Limit

psig	pounds per square inch gauge

pt	point

QA	Quality Assurance

QAO	Quality Assurance Objective

QAPD	Quality Assurance Program Document (DOE 2003b)

QAPM	Quality Assurance Program Manual

QAPjP	Quality Assurance Project Plan

QAPP	Quality Assurance Program Plan

QA/QC	Quality Assurance/Quality Control

QC	Quality Control

%R	Percent Recovery

RCRA	Resource Conservation and Recovery Act

RCT	Radiation Control Technician

RFETS	Rocky Flats Environmental Technology Site

RFFO	Rocky Flats Field Office

RFO	Rocky Flats Office

RIDS	Records Inventory and Disposition Schedule

RPD	Relative Percent Difference

%RSD	Percent Relative Standard Deviation

RT	Retention Time

RTL	Regulatory Threshold Limit

RTR	Real-Time Radiography

Solid PDP Plan	Performance Demonstration Program Plan for the RCRA
Constituent Analysis of Solidified Wastes (DOE 1999b)

SOP	Standard Operating Procedure

SOW	Statement of Work

SPCC	System Performance Check Compound

SQA	Subcontractor Quality Assurance

SRV	Size Reduction Vault

SVOC	Semi-Volatile Organic Compound

SW-846	Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods

SWB	Standard Waste Box

E-1	Acronyms and Abbreviations  (continued)

TC	Toxicity Characteristic

TCLP	Toxicity Characteristic Leaching Procedure

TIC	Tentatively Identified Compounds

TID	Tamper Indicating Device

TRM	Transuranic-Mixed Waste

TRU	Transuranic

TRUCON	TRUPACT-II Content Codes (DOE/WIPP 89-004)

TRUPACT-II	Transuranic Package Transporter-II

TSCA	Toxic Substances Control Act

TPM	Training Program Manual

TWCP	Transuranic Waste Characterization Program

TWCP TIP	TWCP Training Implementation Plan

TWMM	Transuranic Waste Management Manual

UCL90	upper 90% confidence limit

VOA	Volatile Organic Analysis

VOC	Volatile Organic Compound

VTSR	Validated Time of Sample Receipt

WC & O	Waste Certification & Oversight

WCF	WSRIC Change Form

WCR	WSRIC Change Request

WEMS	Waste Environmental Management System

WIPP	Waste Isolation Pilot Plant

WIPP-WAC	Waste Acceptance Criteria for the Waste Isolation Pilot Plant
(DOE/WIPP-02-3122)

WIPP-WAP	Waste Analysis Plan for the Waste Isolation Pilot Plant,
Attachment B of the WIPP Hazardous Waste Permit (NMED 1999)

WM	Waste Management

WO	Waste Operations

WSPF	Waste Stream Profile Form

WWIS	WIPP Waste Information System

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 (i.e., 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 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;
(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 in order 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 that
sample and data integrity is maintained.

Comparability.  A qualitative parameter expressing the confidence with
which one data set can be compared to another.

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

E-2	Definitions  (continued)

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

10-9 Ci or 37 disintegrations per second.

Data Quality Objective (DQO).  A qualitative and quantitative statement
that describes the overall level of uncertainty that a decision maker is
willing to accept in results derived from data.

Economic Discard Limit (EDL).  A variety of industrial materials that
were used in manufacturing and reprocessing operations that became
contaminated with nuclear material to such an extent that it became
economical to recover the plutonium.  At RFETS, this is the threshold at
which material is considered economically feasible to submit for
recovery operations rather than to dispose of it as waste.

Equipment Blanks.  Samples of high purity gas or water used to establish
cleanliness of

sampling equipment.  They are collected after the equipment has been
cleaned and prior to sampling.  These blanks are useful in documenting
adequate cleaning of sampling equipment.

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 prior to 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 Reference Sample (FRS).  Standard samples of known concentration
of target analytes, introduced through the sampling equipment, to
identify any bias in the sampling process.

Field Sample.  A portion of material received for analysis that is
contained in single or multiple containers and identified by a unique
DOE Sample Number.

Frequency.  A frequency specification during an analytical sequence
allowing for no more than a set number of analytical samples between
required quality control measurements, as specified in the WAP.

E-2	Definitions  (continued)

Hazardous Waste.  A waste that exhibits the characteristics of being
corrosive, ignitable, reactive, or toxic or that is listed in 6CCR1007-3
Sec.  261 and 40 CFR 261.24 or as a hazardous waste in 40 CFR 261,
Subpart B.

Holding Time.  The maximum time allowed between time of sample
collection and time of preparation or analysis.

Independent Standard.  A standard solution that is composed of analytes
from a different

source than those used in the standards for the initial calibration.

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.

Innermost Layer of Confinement.  Within a waste container, a plastic bag
that is closest to a waste source that may be a source of VOCs and/or
hydrogen and methane and has a minimum of 1 liter of headspace.

Instrument Detection Limit (IDL).  The minimum signal that the
instrument can detect with 99% confidence that the analyte concentration
is greater than zero.

Item Description Code (IDC).  A three or four-character numeric or
alphanumeric code that describes each waste form matrix.

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.

Laboratory Duplicate.  A second aliquot portion of a sample that is
treated and analyzed identically to the original; used to determine the
precision of the method.

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.

Lot.	When all of the waste within a waste stream is not be 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.

Lower Explosive Limit (LEL).  The lowest concentration of a fuel
(flammable gas and/or VOC) in air that will propagate a flame from an
ignition source; the lower explosive limit (LEL) is synonymous with the
lower limit of flammability (LLF); LEL values are typically expressed as
the volume of fuel per volume of air (v/v%).

Low-Level Waste (LLW).  Radioactive waste that is less than or equal to
100 nCi/gram.

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 zero.

E-2	Definitions  (continued)

Nonconformances.  Nonconformances are uncontrolled and unapproved
deviations from an approved plan or procedure.

Nonconforming Items.  Nonconforming items and activities are those that
do not meet the TWCP requirements, procurement document criteria, or
approved work procedures.

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's conformance without destroying it or modifying the
physical state of the sample.

On-Line Batch.  The number of headspace gas samples that are collected
within a 12-hour period using the same on-line integrated
sampling/analysis system.  The analytical requirements are specified by
the analytical method being used in the on-line system (e.g., FTIR,
GC/MS).

Packaging.  Flexible containment materials, e.g., plastic bags
(Program-specific material definition).

Percent Difference (%D).  The difference between an initial measurement
and a subsequent one, expressed as a percentage of the initial
measurement.

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.

Procedure.  A written, formally approved and controlled, step-by-step
sequence of detailed actions to be followed to perform a given task.

Program-Required Detection Limit (PRDL).  Minimum level of analyte
detection acceptable under the WIPP-WAP.

Program-Required Quantitation Limit (PRQL).  Minimum level of analyte
quantitation acceptable under the WIPP-WAP.

Quality Assurance (QA).  Planned and systematic actions necessary to
provide adequate confidence that a facility, structure, system, or
component will perform satisfactorily and safely in service.

Quality Control (QC).  A routine application of procedures for
controlling a process.

E-2	Definitions  (continued)

Radiation Control Technologist (RCT).  Job title of personnel who
provide radiation protection through controls and monitoring of areas,
items, and personnel.

Radioassay.  Assay methods used to identify and quantify radionuclides
in TRU waste.

Real-Time Radiography (RTR).  A radiographic method that allows
simultaneous remote imaging for the viewing of waste package contents.

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.

Residual Material.  Anything not characterized as a waste item or
packaging material, such as cement or oil dry (program-specific
definition).

Sample.  A portion of material for analysis that is 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 (i.e., 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 field QC samples), all of which must be collected within 14
days of the first sample in the batch.  Also refer to “Analytical
Batch”.

Sampling Manifold Blank (SMB).  Sample of high-purity gas used to purge
sampling equipment; collected after the sampling manifold has been
cleaned and prior to sampling; useful in documenting adequate equipment
cleaning.

Standard Waste Box (SWB).  A container for solid radioactive waste.

SUMMA®.  A stainless-steel pressure vessel with SUMMA® passivated
interior surfaces for collection and stable storage of gas samples and
many specific organic compounds.

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 visual
verification, visual examination to confirm radiography, or radiography
using the same testing equipment.  A testing batch can be up to 20 waste
containers without regard to waste matrix.

Transportation Certification Official (TCO).  The person (In Traffic
Management Organization) who affirms by signature that the Bill of
Lading and Uniform Hazardous Waste Manifest are accurate according to
DOT regulations.  Certifies that the shipment meets transportation
requirements of EPA, WIPP-WAC, DOE, and DOT.  

E-2	Definitions  (continued)

Transuranic (TRU) Waste.  Without regard to source or form, waste that
is contaminated with alpha-emitting transuranic radionuclides with
half-lives greater than 20 years and concentrations greater than 100
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.  Transuranic Package Transporter.  An NRC approved Type-B
shipping container for shipping transuranic radioactive waste.

Validate.  To confirm or corroborate that data resulting from a
characterization process are usable.

Waste.  At RFETS, material that is below the economic discard limit
(EDL).

Waste and Environmental Management System (WEMS).  A computer software
program and database used for the management of RFETS wastes.

Waste Certification Official (WCO).  The person who affirms by signature
that wastes meet all TSDF waste acceptance and other applicable
criteria.  Ensures independent oversight is conducted to verify that
quality assurance requirements and waste disposal site waste acceptance
criteria are satisfied.  The person(s) who affirms by signature that
waste meets all WIPP-WAC criteria for off-site shipment.

Waste Container.  Container that holds waste items.

Waste Generator.  This term is interchangeable with originator.  Any
person whose action process produces a waste or whose act causes a waste
to become subject to regulation or DOE Order.  This includes RFETS
subcontractors and DOE prime contractors who create wastes.

Waste Inspection (WI).  A function at RFETS that provides inspection
services.  Waste Inspection ensures conformance to applicable waste
acceptance and certification criteria.  The waste inspectors assess
package integrity, drum or box contents conformance, and package
documentation, labeling, and marking.

Waste Package.  Individual items placed into waste collection boxes and
drums.

Waste Stream.  Waste material generated from a single process or
activity that is similar in material, physical form, and hazardous
constituents.

Waste Stream and Residue Identification and Characterization (WSRIC). 
The Waste Stream and Residue Identification and Characterization
Building Books (WSRIC Building Books), which are reference documents for
operating personnel; used in conjunction with the WWIS to provide
documented characterization of RFETS wastes.

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) as established by the TRUPACT-II Safety Analysis Report.

 Residues Projects were originally organized to manage radioactive
material which, at the time, was above the Economic Discard Limt (ECL).

 Salt Residue Stabilization/Repack includes only Summary Category Group
S3000.  The associated Process Control Plans (PCPs) are RS-020-006, Salt
Residue Stabilization, Bldg. 707; and RS-020-021, Salt Residue Repack,
Bldgs. 371/707.

 Ash Residue Repack includes Summary Category Groups S3000, S4000, and
S5000.  The associated PCP is RS-020-012, Ash Residue Repack Project.

 Combustible Residue Repack includes Summary Category Group S3000 and
Summary Category Group S5000.  The associated PCP is RS-020-018,
Combustible Residue Repackaging.

 Dry Residue Repack includes only Summary Category Group S5000.  The
associated PCP is RS-020-013, Dry Residue Repackaging.

 These procedures are no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is inactive as of May 12, 2003.

 These procedures are no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

 Collection of duplicates simultaneously rather than sequentially is
permitted based on the configuration of the equipment as indicated in
WAP Clarification Number CAO-00-037.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This plan is inactive as of December 2003.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of November 14, 2003.

 This procedure is inactive as of August 12, 2003.

 This procedure is inactive as of October 6, 2001.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of November 14, 2003.

 This procedure is inactive as of August 12, 2003.

 This procedure is inactive as of November 6, 2001.

 This procedure is inactive as of November 14, 2003.

 This procedure is inactive as of August 12, 2003.

 This procedure is inactive as of November 6, 2001.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 These procedures are no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling using SUMMA( canisters has been discontinued at RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is no longer active.  As of October 22, 2002 headspace
gas sampling with SUMMA( canisters has been discontinued at RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

 This procedure is inactive as of April 30, 2003.

 This procedure has been superseded by PRO-1003-WSRIC-ADMIN, WSRIC
Administration Guidance.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of November 14, 2003.

 This procedure is inactive as of November 6, 2001.

 This procedure is to be deactivated in February 2004.

 The repackaging activities that utilized these procedures were all
completed by December 2000.

 This procedure is inactive as of April 30, 2003.

 This procedure is to be deactivated in February 2004.

 The repackaging activities that utilized these procedures were all
completed by December 2000.

 This procedure is inactive as of April 29, 2003.

 This procedure is inactive as of July 10, 2003.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is inactive as of May 12, 2003.

 These procedures are no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

 This procedure is to be deactivated in February 2004.

 The repackaging activities that utilized these procedures were all
completed by December 2000.

 This procedure is inactive as of April 30, 2003.

 This procedure is inactive as of April 30, 2003.

 This procedure is to be deactivated in February 2004.

 The repackaging activities that utilized these procedures were all
completed by December 2000.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1676-HGAS-S&A.

 This procedure is inactive as of May 12, 2003.

 These procedures are no longer active.  As of October 22, 2002
headspace gas sampling with SUMMA( canisters has been discontinued at
RFETS.

 This procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V.

 This procedure is to be deactivated in February 2004.

 This procedure is to be deactivated in February 2004.

 PAGE   

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RFETS TRU WASTE CHARACTERIZATION	95-QAPjP-0050

PROGRAM QUALITY ASSURANCE		VERSION 9

 

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PROGRAM QUALITY ASSURANCE	02/11/2004	VERSION 9

PROJECT PLAN	SECTION A	PAGE   PAGE  17 

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RFETS TRU WASTE CHARACTERIZATION		95-QAPjP-0050

PROGRAM QUALITY ASSURANCE	02/11/2004	VERSION 9

PROJECT PLAN	SECTION B1	䅐䕇
ഠ഍䙒呅⁓剔⁕䅗呓⁅䡃剁䍁䕔䥒䅚䥔乏उ㔹儭偁偪〭
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佒䕊呃倠䅌N	SECTION B3	PAGE   PAGE  220  

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PROJECT PLAN	SECTION B6	PAGE   PAGE  254  

RFETS TRU WASTE CHARACTERIZATION		95-QAPjP-0050

PROGRAM
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彟彟彟ൟ流楢湥⁴敔灭牥瑡牵⁥彟彟彟彟彟ൟ流楢湥t
Pressure ______________

Sampler Initials ________________

GC/MS (     )              GMS (     )

QC Designation ________________

[SMB, FRS, FB, FD, or N/A]

Custody Seal Application:

Name ________________________

Signature _____________________

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 matrix

parameter category and

waste material parameter weights

be determined without opening

bags/packages?

Perform a limited visual

examination through the

unopened bags/packages.

Confirm radiography-indicated

matrix parameter category and

determine waste material 

parameter weights.

Perform a full visual

examination.

Open bags/packages.

Determine matrix parameter

category and waste material

parameter weights.

Based on the results of visual

examination, calculate the 

percentage of waste containers

with incorrectly assigned waste matrix code.

 

 

 

 

_

Segregate waste containers into waste streams.

Using acceptable knowledge and headspace gas

analytical results, determine EPA hazardous waste

numbers for spent solvents 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? 

Classify waste stream as hazardous for

this contaminant.

Classify waste stream as nonhazardous

for this contaminant.

PRQL = Program Required Quantitation Limit

RTL    = Regulatory Threshold Limit

UCL90 = Upper 90-percent Confidence Limit

YES

NO

 

t (n-1, 1-a = .99)

17

1.     Waste container routing		 9.   Visual Examination Data Form

2.     Radiography Data Form 		10.  Site Project QA Officer Signature
Release

3.     Radioassay Data Forms		11.  Site Project QA Officer Summary

4.     Headspace Gas Sampling Data Reports	12.  Site Project Manager
Signature Release

5.     Sample COC Form			13.  Data Validation Summary

6.     Headspace Sample Canister Tags		14.  Waste Container Data Package

7.     Homogenous Solid and Soil/Gravel		15.  Waste Container Data
Package Acceptance

        Sampling Data Reports		       Notification

8a    Headspace Analytical Data Reports	16.  WIPP Sample Drum Log

8b    Laboratory Analytical Data Reports		17.  Waste Container Data to
WWIS

9

7

5

6

8b

6

16

3

2

5

5

1

1

1

1

1

1

Analytical

Laboratory

Waste Container

Storage

Visual Examination

Homogenous Solid

and Soil/Gravel

Sampling

Headspace

Sampling

Radioassay

Radiography

Waste Container

Storage

10 - 14

Carlsbad Field

Office

NOTE:  This is a generic flow of data records for the program.  Actual
flow of data records may vary, based on the specific characterization
requirements of a waste stream.

TWCP Site PM / 

TWCP Site PQAO

15

Project Data

Control Office

(PDCO)

4

6

8a

4

Headspace

Analytical

Services

 

 

RPD

  =                      * 100

|C1 - C2|

(C1 + C2)

2

x

 =

n



i

=1

x

i

n

  1

s

 =

n



i

=1

(

x

i

-x)

2

n

 - 1

2

1

n

  =

2

-x)

2

t

a,n0-1

s

2

(RTn

n

  =

2

i

i

2

t

0.9,n0-1

s

2

E

eVOC

i

VOC

VOC

MDL

 =

 

t

(

n

-1, 1-

a

 = .99)

 

*

 S

Newly Generated

Waste

Assign waste stream and make initial

radionuclide content (AK) waste

material parameters (AK) hazardous

waste determination (AK)

Package waste

- Verify initial determination of waste

forms through VE, during packaging or perform radiography

- Weigh, measure, categorize by waste

material parameters

100% NDA 

or

 previous radioassay

reconciled with WAC requirements

Unable to verify

AK waste form

during packaging

using VE?

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

Extract sample for chemical

analysis

- Minimum of 1 container/year/

waste stream sampled/analyzed

S/A per retrievably

stored waste

requirements

No chemical analysis,

hazardous waste

characterized by

acceptable knowledge

only

S3000

Homogenous

S4000

Soil/Gravel

S5000

Debris

Does S/A

confirm waste

code assigned

by AK?

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

Yes

No

Yes

No

No

Yes

Yes

No

No

No

Yes

AK = Acceptable Knowledge

VE = Visual Examination

Yes

Verify process

 operated within administrative

controls?

- Uncontrolled or unexpected

events that could affect

waste characteristics

verified during

packaging

Id’d

?

Yes

Waste unacceptable at

WIPP W/O additional

characterization

considered a process

batch (characterize as

retrievably stored)

No

Develop baseline

statistical process

control charts

Constant

mean and

variance

demonstrated?

No

Yes

