The Procurement Engineering and Quality Assurance group performs evaluations in accordance with 1 J55 ADM 08.10, Subcontractor Quality Evaluations, and maintains the Evaluated Subcontractors List. Purchase Orders are developed based on procurement specifications, which specify receipt and source inspection requirements.

<IP_ADDRESS> Procurement Document Control The procurement document control system is defined in MAN 134 PPM, Procurement Program Manual; PRO 1034 PEQA, Procurement Engineering and Quality Assurance; PRO 1306 ARIBA, Ariba Buyer Users Guide; and, for design packages, 1 V51 COEM DES 210, Site Engineering Process Procedure. The procurement document controls specified in these manuals apply to:

  Waste packages, associated hardware and ancillary packaging materials;

  Capital equipment, piping, treatment units and other installed items used to treat or process waste;

  Radioactivity measuring equipment;

  Waste analysis laboratory chemicals, reagents, materials, and equipment;

  Measuring and test equipment used in waste treatment or processing; and   Contracted waste management services. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 72 <IP_ADDRESS> Procurement Document Review and Approval MAN 134 PPM, Procurement Program Manual; PRO 1034 PEQA, Procurement Engineering and Quality Assurance and 1 V51 COEM DES 210, Site Engineering Process Procedure define the procurement document review and approval process. Procurement document changes are subject to the same degree of control as the original documents.

Management prepares purchase requisitions according to MAN 134 PPM, Procurement Program Manual. Quality attributes are specified in PRO 1034 PEQA, Procurement Engineering and Quality Assurance; or in 1 V51 COEM DES 210, Site Engineering Process Procedure.

The Procurement organization prepares solicitations for waste commodities, submits them to suppliers, and receives offers as part of the bidding process, per the KH Procurement System Manual. When required by the requisition, Procurement lets contracts to successful bidders on the Evaluated Subcontractors List. The Waste Requirements Group ( WRG) and Site PQAO review requisitions for WIPP related commodities to ensure project requirements are included.

<IP_ADDRESS> Supplier Performance Evaluations MAN 134 PPM, Procurement Program Manual; PRO 1034 PEQA, Procurement Engineering and Quality Assurance and 1 J55 ADM 08.10, Subcontractor Quality Evaluations define the supplier performance evaluation process.

<IP_ADDRESS> Acceptance of Items or Services Items and services purchased to support the TRU Waste Program are controlled at all stages of procurement from requisition and purchase order preparation, specification development and approval, approval and selection of suppliers, supplier bid evaluation and award, verification, control of nonconformance and corrective action, acceptance of item or service, and maintenance of records. The system control procedures are found in MAN 134 PPM, Procurement Program Manual; PRO 1034 PEQA, Procurement Engineering and Quality Assurance; PRO 1306 ARIBA, Ariba Buyer Users Guide; and 1 V51 COEM DES 210, Site Engineering Process Procedure. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 73 <IP_ADDRESS> Acceptance of Items or Services ( continued)

Acceptance of Items Supplied items are purchased, inspected, and certified in accordance with direction and criteria contained in procurement specifications, or purchasing documents. Inspection and/ or verification is performed to verify vendor products comply with procurement specifications when delivered in accordance with PRO J44 RC& I 6600, Procured Items Inspection and Certification. When items do not conform to requirements they are dispositioned in accordance with applicable NCR procedures.

All component replacement and maintenance involving TRUPACT II packages are performed under the direct instructions of DOE/ WIPP 02 3183, CH Packaging Program Guidance; DOE/ WIPP 02 3184, CH Packaging Operations Manual; and DOE/ WIPP 02 3185, CH Packaging Maintenance Manual; Department of Energy procedures controlled through document control processes at CBFO.

Acceptance of Services Site and/ or TRU Waste Program management may elect to subcontract TRU waste characterization or waste processing operations based on cost effectiveness or other management initiatives. Contract management personnel select suppliers from the Evaluated Subcontractor List for purchases designated to be made from an approved supplier. If requested, a subcontractor evaluation is performed by Procurement Engineering and Quality Assurance. This evaluation may be based on evaluation of existing or subcontractor provided documents or records, or by a direct evaluation of the subcontractor's facilities, personnel, and quality assurance program. When services are procured for subcontractor owned and/ or operated systems, the following additional requirements apply:

  The statement of work for the prospective subcontractor shall be reviewed by the TWCP Site PM and TWCP Site PQAO to ensure appropriate TRU Waste Program requirements are incorporated and specified as contract deliverables. KH organizations preparing statements of work for subcontractor owned or operated systems shall provide copies of statements of work to the TRU Waste Program office for review and approval.

  Subcontractors selected to provide services must demonstrate implementation of QA program requirements that apply to scope of work activities. The subcontractor's QA program must be approved and placed on the Evaluated Subcontractors List when specified in the procurement document. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 74 <IP_ADDRESS> Acceptance of Items or Services ( continued)

Acceptance of Services ( continued)

  The subcontractor shall prepare an interface document in accordance with PRO 1132 WIPP 012, Preparation of an Interface Document for Vendor Owned or Operated Systems, that clearly defines the organizational working relationship with the subcontracting organization and the TRU Waste Program office. The interface document addresses implementation details of how the vendor quality assurance program integrates with TRU Waste Program requirements. The interface document provides review/ concurrence/ approval requirements of subcontractor procedures and documents. The interface document SHALL be reviewed and approved by the TWCP Site PM and the TWCP Site PQAO.

  If the subcontractor is providing new waste treatment or certified WIPP characterization services to the program, a PCP and/ or a PQP and reports shall be prepared that demonstrates operations comply with TRU Waste Program requirements. The PCPs or PQPs shall be prepared in accordance with 1 M60 WPC 001, Waste Process Control.

TRU Waste Program Management shall accept TRU waste related services by any or all of the following methods:

  Technical verification of data produced.

  Surveillance and/ or audit of the activity.

  Review of objective evidence for conformance to the procurement document requirements such as certifications or test reports.

<IP_ADDRESS> Control of Supplier Nonconformances MAN 134 PPM, Procurement Program Manual and PRO J44 RC& I 6600, Procured Items Inspection and Certification address the supplier nonconformance control process.

<IP_ADDRESS> Commercial Grade Items PRO 1034 PEQA, Procurement Engineering and Quality Assurance and PRO J44 RC& I 6600, Procured Items Inspection and Certification address the use of commercial grade items. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 75 3.2.4 Inspection & Testing Inspections are planned and performed at various points from initial waste generation through final shipment. The status of certification activities is maintained from the point of waste generation through the final shipment inspection through the waste packaging procedures. Required certification activities are identified, described, and referenced in waste certification procedures:

  1 PRO 072 001, Inspection & Acceptance Test Program;

  PRO J44 RC& I 6600, Procured Items Inspection and Certification; and   PRO X05 WC 4018, Transuranic ( TRU) Waste Certification.

  PRO 1045 WI 001, Solid Radioactive Waste Inspection.

Inspections that verify conformance to certification requirements are performed by personnel other than those who performed the work. Procedure 1 PRO 072 001, Inspection & Acceptance Test Program addresses the inspection and testing requirements.

This procedure addresses the qualification of inspection and test personnel, qualification of non destructive examination personnel, inspection and test planning, types of inspection and testing performed, and inspection and test documentation.

<IP_ADDRESS> Qualification of Inspection and Test Personnel Only personnel, qualified by using written instructions and defined acceptance criteria, perform inspection and test activities. Qualification results are documented and maintained as part of the certification records. PLN 97 007, TWCP Training Implementation Plan and MAN 094 TPM, Training Program Manual address the qualification of inspection and test personnel.

<IP_ADDRESS> Qualification of Nondestructive Examination ( NDE) Personnel PLN 97 007, TWCP Training Implementation Plan, MAN 094 TPM, Training Program Manual, and 5 NDT TC 1A, Training Qualification and Certification of NDT Personnel address the qualification of NDE personnel. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 76 <IP_ADDRESS> Inspection Inspections performed to verify conformance of an item or activity to specific requirements are planned, controlled and documented to assure consistent, repeatable, and retrievable results. Waste inspection procedures establish the inspection points, define the Waste Inspector responsibilities, include standards for acceptance and rejection, and provide instructions for inspection performance.

These inspections assess package integrity, package contents conformance, and package documentation, labeling, and marking. Nonconformance to criteria is documented according to PRO U76 WC 4030, Control of Waste Nonconformances on a Waste Nonconformance Report ( WNCR). The copy of the WNCR is attached to the package documentation and returned to the waste generator or Solid Waste Operations for corrective actions.

The following inspections are performed:

  Pre Use  inspection of drums or SWBs conducted by the waste generator prior to use ( refer to1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging for packaging type, and to 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, for pre use inspection);

  In Process  performed at management discretion during waste generation, to ensure wastes comply with IDC designation, contain no free liquids, compressed gases or gross levels of particulates or other prohibited materials, includes dock inspection performed on filled and sealed boxes and drums on process building docks to assess package integrity, labeling, handling damage and proper documentation ( refer to PRO 1045 WI 001, Solid Radioactive Waste Inspection);

  Final Inspection  performed just prior to loading drums or SWBs into the TRUPACT II package, to ensure proper documentation and package integrity ( PRO 1045 WI 001, Solid Radioactive Waste Inspection; and PRO X05 WC 4018, Transuranic ( TRU) Waste Certification);

  Traffic Management inspection of TRUPACT IIs are in accordance with PROT95 OSTP 002, Off Site Transportation Procedure, to ensure compliance with applicable DOT and DOE requirements;

  TRUPACT II Vehicle Inspection  to ensure proper loading of vehicle and the condition of the tractor, trailer, and TRUPACT II packages performed by the carrier, Traffic Management, and the Colorado State Patrol. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 77 <IP_ADDRESS> Inspection ( continued)

Inspection points in the waste stream verify the performance of required activities. Passage of a waste package through an inspection point is verified by the Waste Inspector signing and/ or stamping the W/ RT. Waste items found nonconforming must be tagged with a Waste Nonconformance Status Tag ( RF 47841) and segregated from conforming waste items.

The progress and control of waste packages through the waste stream is maintained by forms, labels and markings which require the performance of specific tasks to ensure compliance of each waste package to the WIPP WAC and the WIPP WAP. The performance of identified activities is documented by the waste generator or responsible party by affixing their signature at the appropriate location on the documentation. The serialization of each waste package and use of these numbers on all documentation ensures traceability through the system. The inspection status of waste is clearly marked on the forms, labels, and marking attached to the waste packages.

<IP_ADDRESS> Test Requirements Testing activities ensure the capability of an item to meet specified requirements by subjecting the item to physical, chemical, environmental or operating conditions. Tests performed to verify conformance of an item or activity to specific requirements are planned, controlled and documented to assure consistent, repeatable, and retrievable results. The tests associated with the TRU Waste Program are:

  Equipment Systems Operations Tests or component checkout ( per 1 PRO 072 001, Inspection and Acceptance Test Program)

  TRUPACT II Leak Testing ( per PRO 1419 WO LKTST, TRUPACT II Shipping Leak Test.)

  Waste Characterization Process Qualification Tests ( per 1 M60 WPC 001, Waste Process Control)

  NDA Qualification Plans ( Refer to Appendix 4)

  Gas Generation Testing ( Refer to RS 020 001, Gas Generation Testing Program Quality Assurance Project Plan. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 78 <IP_ADDRESS> Monitoring, Measuring, Testing and Data Collection Equipment To prevent inadvertent use of malfunctioning or otherwise defective equipment, inspection and test personnel clearly designate and document the operating status of equipment associated with waste management activities. Operational status controls are contained in MAN 066 COOP, Site Conduct of Operations Manual, and MAN 072 OS& IH PM, Occupational Safety & Industrial Hygiene Program Manual, Chapter 9: Lockout/ Tagout.

<IP_ADDRESS> Use and Control of Measuring and Testing Equipment All test and measurement equipment used is controlled and calibrated in accordance with requirements specified in MAN 092 M& TEM, Measuring and Test Equipment Management. Calibration of test and measuring equipment may be performed either internally, using in house reference standards, or externally by national certifying agencies or manufacturers. All reference standards have valid relationships to nationally recognized standards, for example, National Institute of Science and Technology ( NIST). If national standards do not exist, the basis for calibration is documented. All test and measuring equipment are uniquely identified.

Several RFETS organizations, including Metrology, Analytical Services, and Measurements, have responsibilities for controlling and calibrating test and measuring equipment. MAN 092 M& TEM, Measuring and Test Equipment Management, establishes Metrology as responsible for approving all other calibrating organizations through an active surveillance program. Calibrating organizations perform calibrations in accordance with this procedure, which describes the recall system establishing the traceability of all standards and test and measuring equipment under the purview of Metrology. All calibrating facilities shall have mechanisms in place for evaluating inspections or tests where out of tolerance instruments were used. These mechanisms shall include methods for evaluating the data obtained from the use of these instruments, and methods for re testing or correcting the data to ensure data accuracy. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 79 <IP_ADDRESS> Use and Control of Measuring and Testing Equipment ( continued)

As part of its surveillance program, Metrology assures that RFETS calibrating organizations comply with MAN 092 M& TEM, Measuring and Test Equipment Management. All calibrating organizations must establish a control system for the equipment under their purview, which includes unique identification of test and measuring equipment. All calibrating organizations must also use approved procedures for performing calibrations of test and measuring equipment. Those instruments that are calibrated shall be calibrated in an environmentally controlled area and the environmental data recorded and maintained ( e. g. temperature, humidity, and dust concentrations). Reference standards must either be certified by the Metrology Laboratories or be obtained from a nationally recognized source. Calibrating organizations must establish calibration frequencies and a mechanism for ensuring that only calibrated equipment is used for this project.

Measurements is responsible for tracking NDA standard certification.

<IP_ADDRESS> Calibration Nondestructive Assay Radiometric Counters Calibration NDA equipment used to assay TRU waste is calibrated and qualified according to approved procedures before assays of waste packages are performed. Calibration and qualification of each measurement system currently used to assay or planned to assay TRU waste are described in Appendix 4 of this document. Systems are calibrated with standards used to determine the response characteristics of a measurement system. Whenever possible radioactive calibration standards shall be obtained from suppliers maintaining nationally accredited measurement programs. Evidence of such traceability and certificates for individual standards shall be obtained from the standards suppliers.

RFETS still uses Chemical Standards Laboratory ( CSL) calibration standards that were prepared in accordance with PRO 697 MLC 00013, Preparation and Certification of Nondestructive Assay Standards and Sources. The RFETS plutonium oxide stream used to prepare NDA standards has been characterized using measurement systems traceable to NIST and/ or New Brunswick Laboratory ( NBL). Calibration standards are re certified using PRO 1566 NDA STD, Evaluating NDA Standards for Continued Use. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 80 <IP_ADDRESS> Calibration ( continued)

Nondestructive Assay Radiometric Calibration Verification Measurement control procedures and the controlling software of each NDA counter system ensure proper operating status of the NDA counter. It is usually possible to verify the proper function of the instruments with rugged, long lived sources. Since the data obtained from these " check" sources is not directly used to calculate analytical data, they do not have to be traceable to primary calibration standards, but only need to be adequately characterized for the proposed usage. The principal requirements for such sources are that they be long lived, simple to reposition with respect to the detector( s), of sufficiently high activity to obtain adequate counting statistics in short count times, and relatively insensitive to handling. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 81 3.3 Assessment Requirements 3.3.1 Management Assessments Managers at all levels of the project periodically assess performance of their organizations to determine the effectiveness of QA program provisions. The TWCP Site PM schedules and performs management assessments in accordance with 3 W24 MA 002, Kaiser Hill Management Assessment Program.

3.3.2 Independent Assessments The independent assessment program implemented for the TRU Waste Program is described in this section. It is implemented as part of overall RFETS independent assessment activities. Operations and functional managers are required to provide audit and surveillance personnel free access to documents, work areas, workers, and supervision during independent assessment activities.

Material Stewardship QA coordinates and issues an annual schedule of surveillances using input from the Site PQAO and other involved quality organizations. Material Stewardship QA performs this coordination to ensure that focus areas that may be identified by DOE or RFETS managers are included, and to reduce redundant surveillance activities. The schedule is distributed to the TWCP Site PM and involved quality managers. Corrective actions are documented and tracked according to 3 X31 CAP 001, Corrective Action Process.

Surveillances are performed to: 1) monitor work in progress; 2) verify compliance with established requirements and procedures; 3) identify actual and potential conditions adverse to quality; 4) obtain timely corrective action commitment from cognizant managers for identified conditions adverse to quality; 5) provide notification to responsible managers of the status and performance of work under surveillance; and 6) verify timely implementation of corrective action.

Audits and surveillances of activities performed by other organizations are reviewed by the TWCP Site PQAO for applicability to project activities. These audits and surveillances may substitute for project surveillances when project affecting activities are evaluated. Conditions adverse to quality identified in these surveillances are monitored in project trending of conditions adverse to quality. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 82 <IP_ADDRESS> Surveillances Surveillances of the TRU Waste Project are coordinated by the TWCP PQAO and performed by technically qualified personnel, knowledgeable of and independent of the areas assessed. The surveillances are performed according to PRO 985 SURV, Performance of Surveillances.

<IP_ADDRESS> Audits An annual independent assessment or a series of smaller independent assessments of the TRU Waste Program is performed.

<IP_ADDRESS>.1 Scheduling Audits The annual audit is scheduled according to 1 W37 IA 002, Integrated Planning and Scheduling of Assessment Activities.

<IP_ADDRESS>.2 Planning and Preparation for Audits Procedure 3 B52 IA 003, Conduct of Independent Assessment Activities, is used to plan and perform the assessment and report the audit results.

<IP_ADDRESS>.3 Audit Team Selection Procedure 3 B52 IA 003, Conduct of Independent Assessment Activities addresses the process for audit team selection.

<IP_ADDRESS>.4 Auditor Qualification Personnel performing audits are qualified according to procedure 1 N92 ADM 02.03, Training and Qualification of Assessment and Surveillance Personnel. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 83 <IP_ADDRESS>.5 Technical Specialist Qualification Technical specialists for the independent audit teams are supplied for the audit team by the TRU Waste Program. The technical specialists supplied shall be independent of the processes to be audited. Qualification of Technical Specialist is addressed in section <IP_ADDRESS>.4.

<IP_ADDRESS>.6 Lead Auditor Qualification Procedure 1 N92 ADM 02.03, Training and Qualification of Assessment and Surveillance Personnel addresses the qualification requirements for Lead Auditors.

<IP_ADDRESS>.7 Performing Audits Audits are performed in accordance with procedure 3 B52 IA 003, Conduct of Independent Assessment Activities.

<IP_ADDRESS>.8 Reporting Audit Results Procedure 3 X31 CAP 001, Corrective Action Process, defines the site level process for documenting and characterizing corrective actions identified during the assessment. The Plant Action Tracking System ( refer to 3 X31 CAP 001, Corrective Action Process) provides for tracking of corrective actions.

<IP_ADDRESS>.9 Audit Response and Follow up Responses and follow up to audits by management of the audited organization is directed by the requirements in 3 X31 CAP 001, Corrective Action Process.

<IP_ADDRESS>.10 Audit Records Audit records are controlled according to 1 V41 RM 001, Records Management Manual.

Records storage is performed in accordance with PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 84 3.4 Sample Control Requirements The sampling and analysis of RFETS wastes is planned, controlled, and performed in accordance with the TWCP QAPjP. The specific waste streams characterized through sample collection and analysis must be specified. The results of these efforts are compiled into reports contained in the WSRIC Building Books which provide information for the RCRA Part B operating permit application. The WSRIC Building Books are the source of much of the waste characterization data needed for certification of TRU waste to the WIPP WAC.

3.4.1 Sample Control Requirements The WIPP WAP defines the requirements for waste sample control which are reiterated and implemented by the TWCP QAPjP. Waste sampling is performed in accordance to Waste Sampling and Analysis Plans to meet specified Data Quality Assurance Objectives.

3.4.2 Sample Identification The TWCP QAPjP specifies the requirements and implementing procedures for sample identification.

3.4.3 Handling, Storage And Shipping Samples The requirements for waste sampling, storage and analysis and data quality objectives are defined in the WIPP WAP and are reiterated and implemented by the TWCP QAPjP.

3.4.4 Disposition Of Sample Nonconformance All waste stream analysis data are required to be validated to the DQO criteria, and data sets dispositioned as acceptable, acceptable with qualifications, or unacceptable. The Waste Operations organization is required to disposition data sets, initiate corrective actions such as re sampling if necessary, and maintain retrievable records of these activities.

CBFO is notified of any non administrative nonconformances related to applicable requirements specified in the WIPP WAP which are first identified at the TWCP Site PM's signature release level. This process is defined in PRO 940 WIPP 010, WIPP TRU Waste Characterization Project Level Data Review and Reporting.

3.5 Scientific Investigation Requirements RFETS does not conduct scientific investigations. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 85 3.6 Software Requirements 3.6.1 Software Quality Assurance ( SQA)

TRU Waste Program operations, supported by software systems, are controlled during development, use, and maintenance, to ensure that the software performs reliably and to expectations. 1 MAN 004 CSMM, Computer Software Management Manual, and MAN 134 PPM, Procurement Program Manual are the procedures that control the purchase or development and maintenance of computer software. These software programs also comply with the requirements of the QAPD, Section 6  Software Requirements. Each user identifies how their system complies with the requirements of the QAPD, Section 6  Software Requirements.

The following describes the primary software systems and software QA compliance:

  The WEMS is a multi user software package that operates on the Site computer network. This system tracks all waste types ( TRU/ TRU Mixed, LLW/ LLW Mixed, and Hazardous) from " cradle to grave" and is the responsibility of the Waste Systems organization. The WEMS software tracks individual waste packages during the waste generation, packing, storage, and shipping process and is used to prepare load lists to waste disposal sites. Waste Systems is responsible for maintaining 4 F72 WEM WP1205, WEMS and WSRIC Software Quality Assurance Compliance, for WEMS which addresses Software QA. Software validation testing for WEMS is performed according to 4 F72 WEM WP 1205, WEMS and WSRIC Software Quality Assurance Compliance.

  All software used to control NDA equipment and report results is demonstrated to satisfy the requirements of the QAPD, Section 6. Software compliance for each measurement system currently used to assay or planned to assay TRU waste is maintained according to PRO 548 SSOC SQA, Software Management for Nondestructive Assay Systems.

  Headspace Analytical Services and the Analytical Laboratories use a laboratory data management system to support TRU Waste Program activities. This software is part of the analytical instrumentation used for analysis. Software Quality Assurance on this software is described in L 4031, Software Quality Assurance1 and PRO 1668 SQA, TRU Waste Characterization Program ( TWCP) Software Quality Assurance.

1 This document will be deactivated in February 2004. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 86 4.0 RFETS TRU WASTE PACKAGING & CERTIFICATION This section describes the characterization, packaging, and certification process followed at RFETS to prepare TRU waste for shipment to WIPP. The Waste Packaging QA program requirements from 10 CFR 71, Subpart H are addressed in Section 4.6.

4.1 Characterization Process Acceptable Knowledge ( AK) is used to characterize TRU waste. Certification of RFETS to the WIPP disposal and transportation criteria is accomplished using a " tiered" or hierarchical approach. The certification process begins with the waste generator who must generate waste to procedures 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 other applicable documents. Procedures 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; and 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, apply to all personnel involved in radioactive line and non line generated waste packaging activities both inside and outside the Protected Area ( PA).

The first part of the actual waste certification process is performed by the waste generator who affirms by signature on the W/ RT that the waste is properly identified, segregated, and packaged in accordance to the procedures. In addition, a verification signature is required by a person ( not the same person that signed the waste generator signature) who is trained and qualified to package and segregate waste for the area of the package origin. Details on the W/ RT and the waste generator statements are provided in Section 4.3.1.

During the waste handling and packaging process, applicable information on the waste package paperwork is entered into the WEMS, in addition to the information obtained from the count sheets ( from NDA of package) and Hazardous Waste Label. Information pertinent to the certification is continually entered into WEMS as the package is transferred on site. ( See Section 4.3.2 for more information on WEMS.)

The signatures on the waste package paperwork and information from WEMS are used by the WCO to assess the package and its contents for compliance with the certification requirements. Section 4.2 provides more details on other information used as a basis for certification by the WCO. The WCO affirms compliance for each waste package by completing the checklist in PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. Certification is also indicated through an entry in WEMS. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 87 4.1 Characterization Process ( continued)

Certification that waste shipments comply with DOT requirements is provided on the Bill of Lading, and signed by the TCO or designated alternate, after all other certifications are complete. Certification that mixed waste shipments comply with RCRA requirements is provided on the Uniform Hazardous Waste Manifest, also signed by the TCO after all other certifications are complete. Mixed waste requires a Uniform Hazardous Waste Manifest.

This tiered approach provides instructions to all involved personnel so that all wastes are properly characterized, identified, in compliance with requirements, and ready for off site shipment. The following sections provide descriptions of the responsibilities and functions of each unit in this tiered approach.

AK was used to characterize legacy wastes packaged prior to the full implementation of the TWCP ( December 16, 1992). Specific criteria for AK data contents and assembly are contained in the WIPP WAP. RFETS uses a three phase process to characterize TRU wastes by means of AK information: 1) compiling enough AK documentation for an auditable record, 2) confirming AK information using radiography, sampling and analysis ( as applicable), and 3) audit of AK records. The TWCP QAPjP, Section B4 3b, describes the RFETS program for development, assembly, and approval of AK records. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 88 4.2 TRU Waste Certification Official ( WCO)

The WCO is independent of waste generation organizations. The WCO is responsible for certifying that wastes shipped from RFETS comply with applicable WIPP disposal requirements, and associated state and federal regulations. A complete description of WCO responsibilities is included under Section <IP_ADDRESS>.4. This certification is based on review and verification of, but not limited to, the following information:

  Overall waste generation/ packaging system;

  The waste generator's statement on the waste package paperwork stating that wastes are properly packaged and identified according to applicable procedures;

  In process package contents inspection results;

  RTR dispositions;

  RTR Technician( s) certification status;

  Nondestructive Assay ( NDA) or radiochemical analysis for determination of waste type as TRU waste, dependent on point of origin of the waste;

  Applicable WEMS data ( Fissile Gram Equivalent ( FGE), PE Ci, Wattage Limits, etc.);

  Physical condition of the waste package ( dents, rust, etc.);

  Installation of correct filters on waste boxes and drums;

  Documentation accuracy, completeness, legibility, and compliance to limits during certification processing activities and verification of shipment documentation;

  Verification that the waste IDC has been correctly identified and documented;

  Waste package marking, labeling, and stenciling is complete, accurate, and in compliance with Traffic Management department procedures;

  Computer data input ( WEMS) for completeness and accuracy during certification processing activities and for electronic transmittal of information to WIPP by WEMS Program Management;

  Loading of accepted waste packages for shipment; and   Surveillance or audit information.

The WCO must assess the information presented and based on this documentation, determine whether the waste in question meets requirements. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 89 4.3 Waste Packaging and Documentation Requirements All TRU waste is packaged under controlled conditions, and those conditions are documented on approved data collection forms. All instructions necessary to assure that wastes are packaged to comply with the WIPP WAC are provided to operations personnel. In the event that procedures are unclear or incomplete, the waste generator shall cease packaging operations, obtain information from the WRG, and initiate revisions to procedures that clarify or address the situation. The following requirements must be met when packaging TRU waste:

  Packaging in compliance to current packaging procedures: 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; 1 C80 WO 1102 W/ RT, Waste/ Residue Travelers Instructions; individual process procedures for those packages which are attached to gloveboxes and are not covered by 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; and MAN 010 MCA, Materials Control & Accountability Manual for packaging and handling 55 gallon drums inside the PA;

  Use of current data collection form;

  Waste generators are currently trained in waste handling courses;

  Waste data is entered into WEMS ( see Section 4.3.2 for details);

  Waste streams are identified and characteristics documented using the WSRIC Building Books.

4.3.1 Waste/ Residue Traveler The W/ RT is used as an in process control document that provides objective evidence of activities associated with packaging of radioactive and radioactive mixed line and non line generated waste.

Currently either an electronic W/ RT or a manual W/ RT may be used for packaging activities. If an electronic W/ RT is to be used, a printout of the electronic W/ RT is obtained prior to waste generation. The electronic W/ RT is printed from the ETraveler form in WEMS. Portions of the electronic W/ RT are electronically filled in based on information provided to WEMS from the WGI information. Unpopulated portions of the electronic W/ RT are filled in by hand. When using the manual W/ RT, all portions of the W/ RT are filled in by hand. Throughout this document ( i. e., the TWMM) discussion pertaining to the W/ RT is generalized ( i. e., including both the electronic W/ RT and the manual W/ RT). TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 90 4.3.1 Waste/ Residue Traveler ( continued)

Individual packaging procedures sequence W/ RT completion steps as they occur in packaging evolution. All radioactive waste generated after December 12, 1992 ( the implementation date of applicable TRU waste packaging procedures) are required to have a W/ RT. Prior to December 12, 1992, a Drum Label was used to provide objective evidence of activities associated with packaging of radioactive waste. 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions, provides instructions for personnel to complete W/ RT information.

The W/ RT is the documented, approved source of " process knowledge" information describing the presence or absence of RCRA regulated materials for each waste package. The waste generator is responsible for the accuracy of process knowledge information and affirms this by signature on the W/ RT for each item placed in a waste package, see Section <IP_ADDRESS> for more details. Waste generators are required to obtain written guidance from Waste Management  Technical Operations in the event that process knowledge characterization information is suspect, incomplete, or inaccurate. Waste generators are required to file a WCF or initiate a WCR if process material inputs or outputs change per WSRIC.

<IP_ADDRESS> Generator Waste Identification Statements The waste generator is responsible for accurate and complete identification of wastes that are packaged for off site disposal. This statement affirms that to the best of the waste generator's knowledge, the contents of each waste package or item placed in the package are properly identified and documented on the W/ RT. A second waste generator verification signature affirms that the package was visually inspected by a second party and complies with waste acceptance criteria. The waste generator and waste verifier signatures appear on the W/ RT. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 91 4.3.2 Waste and Environmental Management System ( WEMS)

WEMS is a secure computer database used for the storage and management of data related to waste packages. WEMS users are responsible for adherence to security requirements and procedures. WEMS User Authorizations are requested from the WEMS system administrator.

Packages are initially entered into WEMS when they are empty and they are tracked through waste processing operations until the waste is sent to an off site facility. Information obtained from the W/ RT is entered, as well as information obtained from package count sheets, the Hazardous Waste Label, and other source documents. Detailed operational instructions are provided in 1 PRO 087 WEMSWP 1201, WEMS Waste Package Inventory, Tracking, and Control.

Prior to off site shipment, packages are verified and certified in WEMS. Detailed operational instructions are provided in 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification. These functions are summarized below:

  Verification Function Prior to shipping, all waste package data must be verified for accuracy and completeness. This data verification includes the resolution of any discrepancies between the data in WEMS and the data shown on the documentation accompanying the package.

  Certification Once a package has been verified as correct in WEMS it is reviewed for certification. The package is certified in WEMS when it meets all the criteria for shipment and is acceptable for the appropriate off site facility.

  Shipping Reports and Electronic Data Transmission Shipping reports are available to assist the users in preparing a load for a shipment. Data is electronically transferred to the WIPP Waste Information System ( WWIS).

WEMS is programmed to halt the verification of final waste package information and to display an error message when data is missing from required fields. When applicable, field validation is performed on data in required fields with the information checked against a table of values. For optional entry fields, data is checked when data is entered. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 92 4.3.3 Waste Stream and Residue Identification and Characterization ( WSRIC) Building Books <IP_ADDRESS> Description The WSRIC is a comprehensive site wide assessment of current waste and residue generating processes. The WSRIC Building Books provide waste characterization information for waste generating processes for each building. Waste streams are characterized and assigned unique numbers for waste management purposes. The WSRIC provides preliminary designations of waste streams as RCRA regulated or non RCRA regulated.

WSRIC Building Books are controlled and maintained by Waste Systems according to 4 H19 WSRIC 001, Waste Characterization and Reverification; and PRO 1003 WSRIC ADMIN, WSRIC Administration Guidance. Operations Management has prime responsibility to assure that process knowledge information contained in the books is current and accurate.

<IP_ADDRESS> Process Knowledge and Analytical Characterization The WSRIC Building Books provide documented, reviewed, and approved characterization of wastes based on process knowledge and analytical data ( see Section 4.1). Chemical and physical waste parameters characterized by analysis will also be provided in WSRIC, as this information becomes available through 95 WP/ SAP 001, Transuranic ( TRU/ TRM) Waste Sampling Plan. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 93 <IP_ADDRESS> Maintenance, Control, Review and Approval Document control, review and approval of the WSRIC Building Books is performed according to 4 H19 WSRIC 001, Waste Characterization and Reverification. The operations approval indicates that the processing material inputs and outputs are accurately described; and the Waste Disposal approval indicates that the materials are properly designated as RCRA or non RCRA wastes. The waste generator is responsible for maintaining WSRIC accuracy when process changes occur by submitting a WCF or initiating a WCR per 4 H19 WSRIC 001, Waste Characterization and Reverification.

<IP_ADDRESS> Use The WSRIC provides characterization information for waste and residue packaging and handling; however, the definitive source of process knowledge information is provided by the waste generator on the W/ RT as wastes are generated. Information excerpted from the WSRIC Building Books may be reformatted and posted by operations personnel at process lines or waste generation sources. This posted information must be controlled through the building conduct of operation protocols and approved by the Operations Manager ( or cognizant designee).

4.3.4 Backlog Waste Reassessment Baseline Book ( BWRBB)

In 1994 and 1995, the Backlog Waste Reassessment project was responsible for compiling characterization information for process waste and residues generated prior to the implementation of the WSRIC and the W/ RT programs. Information from numerous sources was reviewed to assess the characterization of the containers in the backlog inventory. The results of this assessment were documented in the BWRBB. The resulting changes to container characterization were incorporated into WEMS and on container documentation, if necessary. The BWRBB is maintained as a controlled document and updated to reflect current container characterization as new information becomes available for the inventory. In addition, the BWRBB is being utilized to document changes to container characterization resulting from Waste Non Conformance Reports and other waste certification and analyses activities through the waste reassessment in accordance with 4 H19 WSRIC 001, WSRIC Characterization and Reverification. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 94 4.4 Shipment Certification Statements Each shipment of waste is collectively certified to DOT requirements using the Bill of Lading. Hazardous waste shipments are collectively certified using the Uniform Hazardous Waste Manifest. Certification statements are signed by the TCO after all other internal certifications are signed by the involved groups.

Additional shipping documents required for the shipment of waste to WIPP include the PCTCD, OPCTCD, and the PATCD. These documents will be reviewed, verified, and signed by the TCO. Refer to Section 6 for additional information on these documents.

4.5 RFETS IDCs Certifiable to WIPP Operations and Safety Criteria and TRUPACT II Payload Control Criteria Table 6 2 provides a listing of the RFETS waste materials ( by IDC descriptions) which have been shown to be certifiable to the requirements listed in Sections 2.1 and 2.2 of this document. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 95 This page is intentionally blank TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 96 4.6 Packaging QA Program Plan The Packaging QA Program Plan describes the RFETS QA Program for TRU Waste Packaging. The QA Requirements for packaging are found in 10 CFR 71, Subpart H. Preparation guidance is found in Regulatory Guide 7.10, Annex 2 ( NRC 1986) Quality Assurance Programs Applicable to Procurement, Use, Maintenance, and Repair of Packaging Used in Transport of Radioactive Material. A Packaging QA Program consistent with the provisions of Subpart H of 10 CFR 71 is required in order to deliver packaged licensed material to a carrier for transport.

This section describes how the requirements are met for the TWCP. This section follows the guidance given in Regulatory Guide 7.10, Annex 2, ( NRC 1986) Quality Assurance Programs Applicable to Procurement, Use, Maintenance, and Repair of Packaging Used in Transport of Radioactive Material. The section numbers and titles follow those in Annex 2 beginning with Section 4.6.1, Organization, which corresponds with Section 2.1, Organization in Annex 2.

4.6.1 Organization Section <IP_ADDRESS>, of this document, defines the organization responsible for TWCP activities. Controls over activities important to safety are defined in accordance with PRO 486 WIPP 006, TRU Waste Characterization Project QA Grading, and implemented through Site infrastructure QA documents. QA personnel have the responsibility and authority to stop unsatisfactory work and delivery or installation of nonconforming material according to 1 V10 ADM 15.02, Stop Work Action, and have direct access to management levels to ensure that QA procedures important to safety have been accomplished.

Section <IP_ADDRESS>.3 of this document identifies the responsibilities of the principal personnel for the overall QA program; the TWCP Site PM, who has overall authority and responsibility for the TWCP QA program; the TWCP Site PQAO; the Material Stewardship QA Manager; and the KH Quality Program Manager. The TWMM is approved by the TWCP Site PM. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 97 4.6.2 Quality Assurance Program <IP_ADDRESS> Scope of Quality Assurance Program The scope of the Packaging QA Program includes packaging and transport of 55 gallon waste drums and SWBs and the receiving, preparation, and loading of the TRUPACT II. Procedures are established and identified in this plan which ensure that activities important to safety are performed using suitable equipment and under suitable environmental conditions. These procedures identify QA/ QC responsibilities for implementing activities important to safety. The Site TPM and the TWCP TIP are implemented to identify and document training and qualification necessary for personnel to adequately perform their functions.

<IP_ADDRESS> Applicability of Quality Assurance Program CBFO provides the QA Program for the TRUPACT II packaging. The TRUPACTII has been authorized by a Certificate of Compliance per the Nuclear Regulatory Commission regulation 10 CFR 71. DOE/ WIPP 02 3183, CH Packaging Program Guidance; DOE/ WIPP 02 3184, CH Packaging Operations Manual; and DOE/ WIPP 02 3185, CH Packaging Maintenance Manual; are followed in maintaining the TRUPACT II for use. Loading and preparation of the TRUPACT II is covered by the program in this section. Where it has been determined that Packaging QA Program requirements apply to the loading and preparation of the TRUPACT II, controls are specifically identified relative to the TRUPACT II.

The program described here is currently applicable to 55 gallons drums, the POC and SWBs used for shipment of TRU waste to the WIPP. Receiving the TRUPACT II vessels at RFETS, and loading and preparing the TRUPACT II for shipment is also covered by the Packaging QA Program.

Items and activities important to safety are categorized and identified in accordance with PRO 486 WIPP 006, TRU Waste Characterization Project QA Grading.

4.6.3 Design Control The TWCP complies with design configuration for the POC ( Reference DOE/ CAO Drawing No. 163 001) through the application of 1 V51 COEM DES 210, Site Engineering Process Procedure. Refer to PRO 284 POC 001, Pipe Overpack Component Initial Assembly Process for the applicable RFETS POC fabrication drawings. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 98 4.6.4 Procurement Document Control <IP_ADDRESS> Packaging Procurement The procurement document control system is defined in MAN 134 PPM, Procurement Program Manual; the KH Procurement System Manual; and Engineering procedures. The 55 gallon drum, POC, ten drum overpack ( TDOP), and SWB packages are procured according to specifications that are controlled by 1 V51 COEM DES 210, Site Engineering Process Procedure; and PRO 1034 PEQA, Procurement Engineering and Quality Assurance. The Process Specification identifies the appropriate certifications to be provided by the manufacturer and provides the information necessary for receipt at RFETS.

TRUPACT II vessels are government furnished equipment maintained according to DOE/ WIPP 02 3183, CH Packaging Program Guidance; DOE/ WIPP 02 3184, CH Packaging Operations Manual; and DOE/ WIPP 02 3185, CH Packaging Maintenance Manual. DOE maintains the Certificate of Compliance for the TRUPACT II vessels. RFETS verifies the vessel number against a list of certified vessels through PRO T43 Traffic 528, TRUPACT II Operations.

<IP_ADDRESS> Replacement Part Procurement Procedure MAN 134 PPM, Procurement Program Manual; KH Procurement System Manual; and procurement specifications provide for procurement of replacement parts for drums, POCs, TDOPs, and SWBs.

Replacement parts for TRUPACT II vessels are not procured by RFETS, but are obtained according to DOE/ WIPP 02 3183, CH Packaging Program Guidance.

<IP_ADDRESS> High Purity Helium Procurement High purity helium used for leak testing TRUPACT II seals is procured according to MAN 134 PPM, Procurement Program Manual. The vendor provides certification for product purity which exceeds the purity specified by ANSI N14.5 1997, Radioactive Materials   Leakage Tests on Packages for Shipment. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 99 4.6.5 Instructions, Procedures, and Drawings <IP_ADDRESS> Preparation of Packaging for Use Waste generators package waste in accordance with 1 PRO 079 WGI 001, Waste Generating, Characterization, and Packaging. A WGI is then provided to the waste generator. The WGI and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, provide instructions for the waste generator to put the waste package into use.

TRUPACT II vessels are prepared for use following PRO 1418 WO TRUOP, TRUPACT II Operations.

<IP_ADDRESS> Repair, Rework, and Maintenance The procedure PRO 1406 SWB, Standard Waste Box Repair/ Replacement Operations provides controls for field repair and replacement parts for SWBs. No repair or maintenance of drums is performed. Drums and SWBs may be reworked if nonconformances to requirements are determined to exist. Waste generation and packaging processes include appropriate inspection steps and hold points that assure waste is properly packaged. Any deficiencies identified in the waste generation and packaging processes are documented on WNCRs. WNCRs on waste packages are issued according to PRO U76 WC 4030, Control of Waste Nonconformances. Dispositioning of nonconformances assures packaging is reworked to meet the requirements of the waste packaging requirements in 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure.

No repair or rework of TRUPACT II vessels is performed. Maintenance of TRUPACT II vessels is accomplished according to DOE/ WIPP 02 3183, CH Packaging Program Guidance; and DOE/ WIPP 02 3185, CH Packaging Maintenance Manual. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 100 <IP_ADDRESS> Loading and Unloading Contents The documents 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, provide instructions for loading radioactive materials into the drum and SWB packaging.

TRUPACT II vessels are loaded in accordance with the following procedures:

  PRO 1418 WO TRUOP, TRUPACT II Operations   PRO 1419 WO LKTST, TRUPACT II Shipping Leak Test Maintenance and calibration of TRUPACT II leak testing equipment to the guidelines of ANSI N14.5 1997, Radioactive Materials   Leakage Tests on Packages for Shipment requirements is performed according to equipment manufacturer's instructions and procedure PRO 1419 WO LKTST, TRUPACT II Shipping Leak Test.

<IP_ADDRESS> Transport of Packages Traffic and Transportation coordinates the on site transfer of waste packages. Requirements for assuring packages are properly marked, secured and transported are specified in MAN T91 STSM 001, Site Transportation Safety Manual and PRO 015 NMT 003, On Site Transfer Procedure.

Measures are included in PRO T43 Traffic 528, TRUPACT II Operations, to assure TRUPACT II vessels are in good condition, are adequately secured, properly sealed, and properly marked. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 101 4.6.6 Document Control Controls to assure that documents affecting packaging are controlled, that the most recent versions or revisions are available to those persons using the documents, and that changes are reviewed and approved are contained in MAN 001 SDRM, Site Document Requirements Manual; PRO 1329 DM 03, Site Document Control; and PRO 815 DM 01, Developing and Maintaining Documents.

As a minimum, that control should be exercised over the following documents:

  QA and QC Manuals   Operating Procedures   Maintenance Procedures   Inspection and Test Procedures   Loading and Unloading Procedures   Packaging for Transport Procedures   Repair Procedures, and   Procurement Procedures MAN 001 SDRM, Site Document Requirements Manual, requires that the 8 bulleted items listed above, as well as other RFETS documents, are controlled.

PRO 815 DM 01, Developing and Maintaining Documents, requires that changes to items 1 8 above are reviewed and approved by appropriate organizations.

PRO 1329 DM 03, Site Document Control, requires that the 8 bulleted items listed above are verified, distributed, and that the most recent version or revision is available to those persons responsible for using those documents. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 102 4.6.7 Control of Purchased Material, Equipment, and Services The following documents provide direction for the control of purchased material, equipment, and services:

  MAN 134 PPM, Procurement Program Manual   PRO 1034 PEQA, Procurement Engineering and Quality Assurance   PRO 1306 ARIBA, Ariba Buyer Users Guide   1 V51 COEM DES 210, Site Engineering Process Procedure   PRO J44 RC& I 6600, Procured Items Inspection and Certification TRUPACT II vessels are not purchased by RFETS.

For details regarding how these documents address design, fabrication, and quality assurance requirements for procurement of items and services see Section <IP_ADDRESS>.4, Procurement Document Control; Section <IP_ADDRESS>.5, Purchasing; and Section <IP_ADDRESS>.7, Control of Purchased Items and Services. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 103 4.6.8 Identification and Control of Materials, Parts, and Components Identification and/ or traceability of TRU waste packages ( drums and SWBs) is ensured through several measures. Waste packages are uniquely identified from the initial receipt up to and including use, packaging, storage, and transportation to the WIPP.

The key document that records traceability information is the W/ RT ( 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions). As described in Section 4.3.1, either an electronic W/ RT or a manual W/ RT may be used for packaging activities. The WR/ T data collection form is generated for each waste package and documents the employee numbers of the waste generators, waste verifiers, Waste Inspectors, and test technicians directly involved with processing the waste package. The form also documents inspection and test results, waste generation source ( process number), hazardous constituent number ( if applicable), and package serial number. Waste Management   Technical Operations personnel control the development of waste identification and characterization information through 1 PRO 079 WGI 001, Waste Characterization, Generation and Packaging.

Refer to Section <IP_ADDRESS> of this document for further information on the identification and control of materials, parts, and components.

4.6.9 Control of Special Processes The TRUPACT II verification leak check is the only special process in the Packaging QA Program. Procedure PRO 1419 WO LKTST, TRUPACT II Shipping Leak Test, ensure that: 1) Procedures, equipment, and personnel are qualified in accordance with applicable codes, standards, and specifications; 2) Operations are performed by qualified personnel and accomplished in accordance with written process sheets with recorded evidence of verification; and 3) Qualification records of procedures, equipment, and personnel are established, filed, and kept current. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 104 4.6.10 Inspection Control <IP_ADDRESS> Receipt Inspection Receipt Inspection is performed to assure packaging meets procurement specifications in accordance with PRO J44 RC& I 6600, Procured Items Inspection and Certification. Nonconformances are documented according to procedure 1 A65 ADM 15.01, Control of Nonconforming Items.

TRUPACT II vessels are inspected when received on site according to PRO T43 Traffic 528, TRUPACT II Operations.

<IP_ADDRESS> Maintenance Inspections of packaging during use and prior to shipment is performed by Waste Inspectors according to PRO 1045 WI 001, Solid Radioactive Waste Inspection.

TRUPACT II vessels maintenance inspections are performed in accordance with DOE/ WIPP 02 3183, CH Packaging Program Guidance; and DOE/ WIPP 02 3185, CH Packaging Maintenance Manual.

<IP_ADDRESS> Final Inspection Final inspection of the packaging is performed according to PRO 1045 WI 001, Solid Radioactive Waste Inspection, and PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. Also see Section 6.6 of this document for controls implemented for the final inspection and certification of packaging and the TRUPACT II.

Final inspection measures for TRUPACT II vessels are included in PRO T95 OSTP 002, Off Site Transportation Procedure; PRO T13 Traffic 306, Labeling and Marking TRUPACT Packages; and PRO T43 Traffic 528, TRUPACT II Operations. The above procedures ensure inspections verify the following have been complied with:

  All shipping papers are properly completed,

  Packages are legibly, conspicuously and durably marked as required by DOT regulations,

All inspections are performed by personnel who are independent from the individual performing the work being inspected. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 105 4.6.11 Test Control The TRUPACT II verification leak check is the only testing conducted as part of the Packaging QA Program. Testing is controlled PRO 1419 WO LKTST, TRUPACT II Shipping Leak Test. See Sections <IP_ADDRESS> and 4.6.9 for additional details.

4.6.12 Control of Measuring and Test Equipment Measuring and test equipment ( M& TE) is calibrated, adjusted, and maintained according to MAN 092 M& TEM, Measuring and Test Equipment Management. Measuring and test equipment are labeled to assure calibration at prescribed intervals or prior to use. Calibration records are maintained to identify historical information and assure traceability to nationally recognized standards. Procedure MAN 092 M& TEM, Measuring and Test Equipment Management, describes the action to take to validate previous inspection/ test results if M& TE is found to be out of calibration. See Section <IP_ADDRESS>.1 of this document for additional details and controls related to M& TE. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 106 4.6.13 Handling, Storage, and Shipping <IP_ADDRESS> Handling and Storage Measures to ensure that special handling and lifting equipment is used are established through the MAN 072 OS& IH PM, Occupational Safety & Industrial Hygiene Program Manual, Chapter 11: Powered Industrial Trucks and Chapter 12: Hoisting and Rigging.

Special handling or storage provisions for packaging ( e. g., shock absorbers, tags, or markings to adequately protect and identify critical components) are used for the TRUPACT II vessels according to instructions in the TRUPACT II loading procedures ( PRO 1418 WO TRUOP, TRUPACT II Operations; PRO 1419 WOLKTST TRUPACT II Shipping Leak Test; and PRO 1411 WO WASTE, Waste Receiving, Transfer, & Handling).

On site sample transfer is discussed in the TWCP QAPjP, Section B1 5.

<IP_ADDRESS> Preparation for Release and Shipment TRU waste packaging is inspected by Traffic Management prior to shipment according to PRO T95 OSTP 002, Off Site Transportation Procedure; and PRO T13 Traffic 306, Labeling and Marking TRUPACT Packages.

Inspection of the TRUPACT II for certification and shipment is performed according to PRO T95 OSTP 002, Off Site Transportation Procedure; PRO T43 Traffic 528, TRUPACT II Operations; and PRO T30 Traffic 515, Preparation and Retention of Hazardous Materials Shipping Documents.

4.6.14 Inspection, Test, and Operating Status The measure for ensuring the inspection and operating status of drum and SWB waste packaging is the W/ RT. Instructions for preparing the W/ RT are provided in 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions.

The operating status of the TRUPACT II vessels is identified through the use of DOE/ WIPP 02 3183, CH Packaging Program Guidance; DOE/ WIPP 02 3184, CH Packaging Operations Manual; and DOE/ WIPP 02 3185, CH Packaging Maintenance Manual.

See Section 3.2.4 for additional details. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 107 4.6.15 Control of Nonconforming Materials, Parts, or Components Controls for the identification, segregation, disposition, and evaluation of nonconforming packaging are provided in 1 A65 ADM 15.01, Control of Nonconforming Items; and PRO U76 WC 4030, Control of Waste Nonconformances. See Section <IP_ADDRESS>.3 for additional detail of the control of the nonconformance process.

4.6.16 Corrective Action <IP_ADDRESS> Reporting Conditions adverse to waste acceptability are identified promptly through inspections, tests, surveillances, and audits and corrected as soon as practical. Corrective actions are initiated, documented and tracked in accordance with 3 X31 CAP 001, Corrective Action Process.

<IP_ADDRESS> Closeout Closeout to ensure that corrective actions have been implemented is performed according to instructions in 3 X31 CAP 001, Corrective Action Process. The individuals responsible for closeout are identified in this procedure.

See Section <IP_ADDRESS>.4 of this document for additional detail of the corrective action process. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 108 4.6.17 Quality Assurance Records <IP_ADDRESS> General Records are maintained and transmitted to the TWCP files according to PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center. In addition to the following, Section 3.1.5 of this document provides more additional description of Quality Assurance Records.

<IP_ADDRESS> Generating Records Measures to ensure that documents designated as QA records are legible and completed to reflect the work accomplished and are processed quickly to avoid unnecessary delay when the record is needed have been established. These measures are contained in PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center, and the RIDS.

<IP_ADDRESS> Receipt, Retrieval, and Disposition of Records A receipt system is established in PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center. Measures to ensure records maintained are identifiable and retrieval and are not disposed of until prescribed conditions are satisfied are contained in the RIDS and PRO 767 WIPP 001, Waste Records Center Processing.

<IP_ADDRESS> Storage, Preservation, and Safekeeping Measures for storage, protection, and safekeeping of records are provided in 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. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 109 4.6.18 Audits An independent assessment ( or a series of smaller independent assessments) of the TWCP is performed annually by MS Quality Assurance. The scope of the audit includes the Packaging QA Program requirements. Procedure 3 B52 IA 003, Conduct of Independent Assessment Activities, is used to plan and perform the assessment and report the audit results. Procedure 3 X31 CAP 001, Corrective Action Process, defines the site level process for documenting, characterizing and tracking corrective actions identified during the assessment. Additional description of the audit process is provided in Sections 3.3.2 and <IP_ADDRESS> of this document. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 110 5.0 RFETS CERTIFICATION TO WIPP WASTE ACCEPTANCE CRITERIA The requirements and associated criteria for acceptance of defense TRU waste at WIPP for disposal ( the WIPP WAC Section 3) and the method( s) of compliance employed at RFETS to meet these criteria are specified in the following subsections. The acceptance criteria of the WIPP WAC describe the controlling ( i. e., the most restrictive) requirements to be used by RFETS in preparing waste for transportation to and disposal at the WIPP. In some instances the acceptance criteria and regulatory requirements are synonymous. The WIPP WAC requirements are derived from several source documents: the WIPP SAR, the TRUPACT II Certificate of Compliance, the WIPP Land Withdrawal Act, the WIPP Hazardous Waste Facility Permit, and the Criteria for the Certification and Re Certification of the Waste Isolation Pilot Plant's Compliance with the 40 CFR Part 191   Disposal Regulations. Definitions of terms used in this document are included as Section 9.1.

5.1 General All of the requirements and associated criteria from the WIPP WAC are addressed in this section. However, some of these criteria are not limiting when the restrictions for TRUPACT II payload control and the WIPP Waste Acceptance Criteria are combined. The TRUPACT II payload criteria that are defined in the TRAMPAC parallel the WIPP WAC for many of the restrictions. In the cases where the WIPPWAC and the TRAMPAC have identified equivalent criteria or where the TRAMPAC criteria are more restrictive, Section 6.0 of this TWMM, RFETS TRUPACT II Payload Compliance Plan, is referenced to demonstrate compliance.

The WIPP Waste Acceptance Requirements and Criteria ( WIPP WAC, Section 3) are organized into five main categories in this document. These categories ( and their corresponding section numbers) include the following:

  Container Properties ( Section 5.2);

  Radiological Properties ( Section 5.3);

  Physical Properties ( Section 5.4);

  Chemical Properties ( Section 5.5); and   Data Packages ( Section 5.6); TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 111 5.1 General ( continued)

Within each of these categories the specific requirement( s) is quoted and the method( s) of compliance documented. Only CH TRU wastes from a properly characterized and approved waste stream may be certified as meeting the requirements and associated criteria contained in the WIPP WAC. Any waste payload package from a waste stream that has not been preceded by an appropriate certified WSPF is not acceptable for disposal at WIPP.

RFETS plans and procedures, as referenced in this document, contain details of the processes, controls, techniques, tests, and other actions to be applied to each TRU payload package, waste stream, and shipment. Methods of compliance with each requirement are described and the specific procedure cited. These methods of compliance include procedural controls, administrative controls, and waste generation process controls. The QA requirements applicable to waste characterization, certification, and transportation are addressed in the TWCP QAPjP, and Sections 3, 4.6, and Appendix 4 of this TWMM. The data resulting from the implementation of the plans and procedures will form the basis for verifying that CH TRU waste to be sent to WIPP is certified to meet the WIPP WAC by the responsible site certifying official.

RFETS shall transmit required characterization, certification, and shipping data to WIPP using the WWIS. The WWIS is an electronic database equipped with edit/ limit checks to ensure that the data representing the waste payload packages are in compliance with the WIPP WAC. Before shipping TRU waste payload packages from a WIPP accepted waste stream, RFETS shall transmit the required waste characterization, certification, and shipping data via WWIS to WIPP. RFETS may periodically be requested to transmit payload package radiography reports or other data to WIPP. WIPP will not accept any waste package shipments for disposal if the waste payload package information has not been correctly submitted and approved for shipment by the WWIS Data Administrator. The WWIS User's Manual provides the information needed by TRU waste sites to perform tasks associated with transmittal of the payload package's characterization, certification, and shipment information to WIPP.

RFETS will be notified of revisions to external regulatory requirements by CBFO. Revisions of requirements in referenced documents not controlled by the DOE ( but by, for example, the EPA, NRC, or NMED) shall have precedence over the values specified in the WIPP WAC if they are more restrictive. These changes will be incorporated in future revisions of the WIPP WAC. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 112 5.1.1 DOE Operations and Safety Requirements The WIPP SAR addresses CH TRU waste handling and emplacement operations. The waste accepted for emplacement in the WIPP must conform to the SAR and the associated technical safety requirements. The WIPP SAR documents the safety analyses that develop and evaluate the adequacy of the WIPP safety bases necessary to ensure the safety of workers, the public, and the environment from the hazards posed by WIPP waste receiving, handling, and emplacement operations. The WIPP SAR establishes and evaluates the adequacy of the safety bases in response to WIPP normal and abnormal operations and postulated accident conditions. In addition to the requirements found in the WIPP SAR, requirements from best practices and operational experience are also listed in this section.

<IP_ADDRESS> Methods of Compliance Compliance with the applicable Operations and Safety Requirements are described throughout Section 5 of this document.

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

RFETS shall have a packaging QA program that defines the QA activities that apply to the use of NRC approved transportation packagings in accordance with 10 CFR Part 71, subpart H.

<IP_ADDRESS> Methods of Compliance The RFETS TRAMPAC is defined in Section 6.0 of this document. The corresponding packaging QA program is described in Section 4.6 of this document. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 113 5.1.3 NMED Hazardous Waste Facility Permit Requirements TRU waste is classified as TRU mixed waste if it contains hazardous constituents regulated under RCRA. Only TRU mixed waste and TRU waste that have been characterized in accordance with the WIPP WAP and that meet the TSDF waste acceptance criteria as presented in permit conditions II. C. 3. a through II. C. 3. k of the WIPP Hazardous Waste Facility Permit will be shipped to WIPP for disposal in the permitted underground hazardous waste disposal unit.

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

<IP_ADDRESS> Methods of Compliance The TWCP QAPjP describes compliance with the WIPP WAP. The TWCP QAPjP is approved by CBFO.

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

The repository limit for free water is a maximum of 1684 m3 and is met by the residual liquid criterion specified in Section 3.4.1 of the WIPP WAC. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 114 5.1.4 EPA Compliance Certification Decision Requirements ( continued)

The limits for metals are a minimum of 2 × 107 kg for ferrous metals and 2 × 103 kg for nonferrous metals. These limits will be met in the total repository inventory by the metals that constitute the waste payload packages alone; thus, WIPP tracks and reports the number and type of payload packages emplaced in the repository as reported in the WWIS by the sites ( see WIPP WAC Section 3.2.1).

The repository limit for CPR is a maximum of 2 × 107 kg. RFETS estimates the CPR weights and reports these estimates in the WWIS on a payload package basis as required by WIPP WAC Section 3.6.1.

RFETS must quantify and report the activities and masses of specific radionuclides for the purpose of tracking the total radionuclide inventory of the repository as specified in Section 3.3.1 of the WIPP WAC. The presence or absence of these specific radionuclides is determined from AK, radioassay, or both in accordance with Appendix A of the WIPP WAC. The results of this determination are reported in the WWIS on a payload package basis.

<IP_ADDRESS> Methods of Compliance.

Site compliance with free liquid requirements is discussed in Section 5.4.1 of this document. The information necessary for compliance with the metals limit is provided as described in Section 5.2.1 of this document. The weights of cellulose, plastic, and rubber ( CRP) are estimated during the characterization processes ( RTR or Visual Examination) described in the TWCP QAPjP. These weights are reported to the WWIS through 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification; and 4 K47 WEM WP1210, WEMS Offsite Shipping Module. The quantification and reporting of radionuclides is performed as described in Section 5.3.1 of this document.

5.1.5 Land Withdrawal Act Requirements The term " WIPP" means the Waste Isolation Pilot Plant project authorized under Section 213 of the Department of Energy National Security and Military Applications of Nuclear Energy Authorization Act of 1980 ( Pub. L. 96 164; 93 Stat. 1259 1265) to demonstrate the safe disposal of radioactive waste materials generated by atomic energy defense activities. Hence, by law, WIPP can accept only radioactive waste generated by atomic energy defense activities of the United States. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 115 5.1.5 Land Withdrawal Act Requirements ( continued)

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

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

High level radioactive waste or spent nuclear fuel shall neither be transported, emplaced, nor disposed of at WIPP. Also, no transuranic waste may be transported by or for the DOE to or from WIPP, except in packages ( 1) the design of which has been certified by the NRC, and ( 2) that have been determined by the NRC to satisfy its quality assurance requirements.

<IP_ADDRESS> Methods of Compliance The RFETS' TRU waste was generated by Atomic Energy defense activities only. Using AK, RFETS determined that each waste stream to be disposed of at WIPP is defense waste. This is documented in an auditable record and summarized in RF/ RMRS 97 018, RFETS TRU Waste Acceptable Knowledge Supplemental Information. Furthermore, based on review of AK information, there is no historical evidence or record of high level waste or spent nuclear fuel ever being handled at RFETS. RFETS did not and does not generate or possess any high level waste or spent nuclear fuel.

The RFETS TRAMPAC is defined in Section 6.0 of this document. The corresponding packaging QA program is described in Section 4.6 of this document. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 116 5.2 Container Properties 5.2.1 Description Acceptance Criterion. Each payload package shall be assigned to a payload shipping category. Authorized payload packages include:

  55 gallon drums ( either direct loaded or containing a POC)

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

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

Payload packages shall meet U. S. Department of Transportation ( DOT) Specification 7A, Type A, packaging requirements. Payload packages must be made of steel and be in good and unimpaired condition prior to shipment from RFETS. To demonstrate compliance with the requirement that payload packages be in good and unimpaired condition, the exterior of all payload packages shall undergo 100% visual examination prior to loading into a TRUPACT II. The results of this visual examination shall be documented using the payload package integrity checklist contained in Appendix 3. A payload package in good and unimpaired condition 1) does not have significant rusting, 2) is of sound structural integrity, and, 3) does not leak. Significant rusting is a readily observable loss of metal due to oxidation ( e. g., flaking, bubbling, or pitting) that causes degradation of the payload package's structural integrity. Rusting that causes discoloration of the payload package surface or consists of minor flaking is not considered significant. A payload package is not of sound structural integrity if it has breaches or significant denting/ deformation. Breaching is defined as a penetration in the payload package that exposes the internals of the packaging. Significant denting/ deformation is defined as damage to the payload package that results in creasing, cracking, or gouging of the metal, or damage that affects payload package closure. Dents or deformations that do not result in creasing, cracking, or gouging or affect payload package closure are not considered significant. RFETS will report to the WWIS the number and types of payload packages planned for shipment to the WIPP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 117 <IP_ADDRESS> Methods of Compliance See Section 6.5.1 for description of compliance with shipping category requirements.

Per document 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, only 55 gallon drums ( direct fill or containing a POC) or SWBs are approved TRU waste packages for use at the site. Both of these packages are composed of steel and are non combustible.

Procedure 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, and applicable WGIs, that are prepared in accordance with procedure 1 PRO 079 WGI 001, Waste Characterization, Generation and Packaging, specify packaging instructions that ensure that packagings used to package transuranic waste are Specification 7A, Type A packages.

Procedure PRO 1045 WI 001, Solid Radioactive Waste Inspection, provides instructions for the performance of a final inspection of each payload package prior to certification and shipment that ensures that payload packages are in good condition. The Container Integrity Checklist is used when examining the payload package condition.

RFETS reports the number and type of waste packages in the WWIS. Inspections, tests, or other certifications are conducted at the manufacturer to assure drums and SWBs meet RFETS specifications. See Section <IP_ADDRESS> for additional information related to compliance of payload packages to the requirements of the TRUPACT II SAR. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 118 5.2.2 Weight Limits and Center of Gravity Acceptance Criterion. Each payload package, payload assembly, and loaded TRUPACT II shall comply with the weight limits shown in Table 5 2. Weight calculations for the payload assembly must include the measurement error. The total weight of the top seven 55 gallon drums or SWB of the payload assembly shall be less than or equal to the total weight of the bottom seven 55 gallon drums or SWB, respectively. The total weight of the top five 55 gallon drums or three 85 gallon drum overpacks in a TDOP shall be less than or equal to the total weight of the bottom five 55 gallon drums or three 85 gallon drum overpacks, respectively. Calibrations of the scales used to make these weight determinations shall be in accordance with the National Institute of Standards and Technology ( NIST) Handbook 44 or an equivalent standard.

<IP_ADDRESS> Methods of Compliance NOTE: The RFETS maximum weight of a 55 gallon drum is limited to 800 lbs. per 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual.

Methods of compliance are described in Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 119 5.2.3 Assembly Configurations Acceptance Criterion. Payload package assembly configurations authorized for shipment in the TRUPACT II shall be in accordance with Table 5 1.

Although 85 gallon drum overpacks are acceptable at WIPP, they are not authorized for transport in a TRUPACT II as individual payload packages.

<IP_ADDRESS> Methods of Compliance Methods of compliance are described in Section <IP_ADDRESS>.

5.2.4 Removable Surface Contamination Acceptance Criterion. Removable surface contamination on CH TRU waste payload packages, payload assemblies, and packagings shall not exceed 20 dpm/ 100 cm2 alpha and 200 dpm/ 100 cm2 beta gamma. The fixing of surface contamination to meet these criteria is not allowed by WIPP in accordance with best management practices for ensuring worker radiation dose as low as reasonable achievable.

<IP_ADDRESS> Methods of Compliance The documents 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 PRO 079 WGI 001, Waste Characterization, Generation and Packaging; and 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions, include steps for completing the W/ RT which instructs the RCT to complete the signature block of the form thereby assuring that the removable alpha surface contamination is < 20 dpm/ 100 cm2. Payload packages and assemblies are surveyed for compliance with the removable surface contamination criteria prior to shipment in accordance with applicable Radiological Safety Practices ( RSP) procedures and instructions. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 120 5.2.5 Identification/ Labeling Acceptance Criterion. Each payload package shall be labeled with a unique package identification number using bar code labels permanently attached in conspicuous locations. The payload package identification number shall be in medium to low density Code 39 bar code symbology as required by American National Standards Institute ( ANSI) standard ANSI/ AIM BC1 1995 in characters at least one inch high and alphanumeric characters at least one half inch high. In the case of 55 gallon drums, the bar code identification labels shall be placed at three locations approximately 120 degrees apart so that at least one label is clearly visible when the drums are assembled into a seven pack ( i. e., a label must be visible after slip sheets and wrapping are applied). In the case of SWBs, bar code labels are required on the flat sides of the SWBs. For TDOPs, a minimum of one bar code is required.

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

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

  Unique package identification number   " EMPTY" or " DUNNAGE"

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

<IP_ADDRESS> Methods of Compliance Payload package identification and labeling is performed in accordance with procedure PRO T13 Traffic 306, Labeling and Marking TRUPACT Packages. This procedure specifies instructions that ensure payload packages comply with the requirements for payload package identification and labeling. Refer to Section <IP_ADDRESS> for additional information on compliance to the requirements for payload package identification/ labeling. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 121 5.2.6 Dunnage Acceptance Criterion. RFETS shall use empty 55 gallon drums or a SWB as dunnage to complete a payload configuration if too few payload packages are available that meet transportation requirements. The dunnage package( s) must meet the specifications of Appendix 2.1 of the TRAMPAC with the exception that dunnage packages shall have open vent ports ( i. e., not filtered or plugged).

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

<IP_ADDRESS> Methods of Compliance Dunnage packages consist of 55 gallon drums and SWBs that are inspected to verify they meet the requirements as described in Section <IP_ADDRESS>. Instructions specified in procedure DOE/ WIPP 02 3183, CH Packaging Program Guidance, ensure dunnage drums or SWBs have open vent ports. Refer to Sections <IP_ADDRESS> and <IP_ADDRESS> for additional information on compliance with the dunnage requirements.

5.2.7 Filter Vents Acceptance Criterion. Payload packages that have been stored in an unvented condition ( i. e., no filter and/ or unpunctured liner) shall be aspirated for a specific length of time as described in the TRAMPAC to ensure equilibration of any gases that may have accumulated in the closed payload package.

Each payload package shall have one or more filter vents that meet the specifications of Appendix 2.5 of the TRAMPAC. The model number of each filter vent or combination of filter vents installed on a payload package shall be reported to the WWIS. A listing of available CBFO filter vent models is provided on the CBFO Web Page.

<IP_ADDRESS> Methods of Compliance See Section <IP_ADDRESS> for methods of compliance with aspiration requirements.

Refer to Section <IP_ADDRESS> for methods of compliance with the filter vent requirements. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 122 5.3 Radiological Properties With respect to the required radiological properties identified within this section, they can be divided into two distinct groups.

The first group includes the activities and masses of the ten WIPP tracked radionuclides ( i. e., 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) and the TRU alpha activity concentration ( i. e., > 100 nCi/ g of alpha emitting TRU isotopes with half lives greater than 20 years) of the waste. This set of radiological properties is regulated by the EPA in accordance with 40 CFR Parts 191 and 194. Estimates of their activities and masses shall be derived from a system of controls certified by CBFO that includes AK, computations, measurements, sampling, etc. Appendix 4 provides the methods and requirements by which to characterize the radiological composition of the CH TRU waste utilizing radioassay techniques.

The second group includes the remaining radionuclides contributing to the fissile gram equivalent ( FGE), the plutonium 239 equivalent curies ( PE Ci), and the decay heat of the payload package. This set of radiological data is regulated both by the NRC as specified in the TRAMPAC and the CBFO as required by the WIPP Technical Safety Requirements. PE Ci quantities shall be calculated for each payload package in accordance with Appendix B of the WIPP WAC. Any TRAMPAC compliant method may be used to quantify the remaining radiological properties at the discretion of RFETS. Appendix 4 provides radioassay methods by which to characterize the remaining radiological properties. However, the resulting data ( e. g., AK from Safeguards and Security data), the source/ method from which the data was generated, and the basis for the reliability of the data shall be submitted to and approved by CBFO prior to use.

5.3.1 Radionuclide Composition Acceptance Criterion. The activities and masses of 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs shall be established on a payload package basis for purposes of tracking their contributions to the total WIPP radionuclide inventory. The estimated activities and masses, including their associated total measurement uncertainties ( TMU) expressed in terms of one standard deviation, for these ten radionuclides shall be reported to the WWIS on a payload package basis. For any of these ten radionuclides whose presence can be substantiated from AK, direct measurement, computations, or a combination thereof, and whose measured data are determined to be below the lower limit of detection ( LLD) for that radionuclide, RFETS shall report the character string "< LLD" to the WWIS for the activity and mass of that radionuclide; otherwise a value of zero shall be reported. See Appendix 4, Section A4.3, for information pertaining to the development and application of LLD. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 123 5.3.1 Radionuclide Composition ( continued)

In addition, all radionuclides other than the ten WIPP tracked radionuclides ( i. e., 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) that contribute to 95% of the radioactive hazard for the payload package shall be reported on the TRUPACT II bill of lading or manifest in accordance with 49 CFR Part 172.203 and 49 CFR Part 173.433. The activities and masses of these other radioisotopes shall also be reported to the WWIS along with their associated TMU, expressed in terms of one standard deviation for each waste package.

<IP_ADDRESS> Methods of Compliance See Section <IP_ADDRESS>.

5.3.2 Pu 239 Fissile Gram Equivalent Acceptance Criterion. For each payload package and loaded TRUPACT II, the sum of 239Pu FGE plus two times its associated TMU, expressed in terms of one standard deviation, shall comply with the limits in Table 5 3. The values calculated for 239Pu FGE and its associated TMU ( expressed in terms of one standard deviation) shall be reported to the WWIS for each payload package.

<IP_ADDRESS> Methods of Compliance The quantity of radioactive material in payload packages is determined by approved and authorized assay methods ( refer to Appendix 4). Assay is either performed directly on the payload package or on all of the smaller waste packages composing the payload package. If the payload package is not directly assayed, then the assay values ( and uncertainties) for the payload package are calculated from the associated assay results for all of the smaller packages composing the payload package. The assay results are used to calculate the Pu 239 FGE and associated uncertainty.

The Pu 239 FGE of the radionuclides in each waste package is reported to WIPP using the WWIS. Refer to Section <IP_ADDRESS> for more specific information on the methods of compliance for the Pu 239 FGE requirements. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 124 5.3.3 TRU Alpha Activity Concentration Acceptance Criterion. TRU waste payload packages shall contain more than 100 nCi/ g of alpha emitting TRU isotopes with half lives greater than 20 years. Without taking into consideration the TMU, the TRU alpha activity concentration for a payload package is determined by dividing the TRU alpha activity of the waste by the weight of the waste. The weight of the waste is the weight of the material placed into the payload package ( i. e., the net weight of the package). The weight of the waste is typically determined by subtracting the tare weight of the payload package ( including the weight of the rigid liner and any shielding external from the waste, if applicable) from the gross weight of the payload package. In the event waste packages ( e. g., 55 gallon drums) that have been radioassayed are overpacked in a payload package ( e. g., in an SWB), RFETS shall sum the individual TRU alpha activity values of the individual waste packages and divide by the sum of the individual net waste weights ( i. e., less container, shielding, and liner weights as appropriate) to determine the activity per gram for the payload package. Loading a 55 gallon POC with cans is considered direct loading  not overpacking for the purposes of calculating the weight of the package. The TRU alpha activity concentration shall be reported to the WWIS; however, there are no reporting requirements for its associated TMU.

<IP_ADDRESS> Methods of Compliance Approved and authorized assay methods are used to quantitate the radioactive material in payload packages. RFETS assay methods and procedures are described in Appendix 4. Calibrated scales are used to measure the weight of payload packages and/ or their contents in accordance with approved procedures PRO 1411 WO WASTE, Waste Receiving, Transfer and Handling and/ or PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( VV) and Data Review. The assay results and weight measurements are used to calculate the TRU alpha activity concentration. Both the assay results and the weight measurements are entered into the site Waste and Environmental Management System ( WEMS). WEMS software specifications for Calculated and Assigned fields define the methods that WEMS uses to calculate the TRU alpha activity concentration including subtraction of the tare weight ( including the rigid liner and any added shielding), if applicable, prior to performing the calculation. WEMS software specifications also provide the methodology used by WEMS to ensure transuranic payload packages comply with the TRU alpha activity concentration restrictions.

Verification that correct data is input and used by WEMS for calculation of TRU alpha activity concentration is performed during the " WIPP Verify" function described in 4 G83 WEM WP 1209, WEMS Package Verification and Certification. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 125 5.3.4 Pu 239 Equivalent Activity Acceptance Criterion. PE Ci limits are shown in Table 5 4. PE Ci quantities shall be calculated for each payload package ( see WIPP WAC Appendix B) and reported to WIPP using the WWIS. There are no reporting requirements for the associated TMU.

<IP_ADDRESS> Methods of Compliance Approved and authorized assay methods are used to quantitate the radioactive material in payload packages. The assay results are used to calculate the PE Ci for each payload package as specified in Appendix B to the WIPP WAC in WEMS. WEMS software specifications for Calculated and Assigned fields define the methods that WEMS uses to calculate the PE Ci for each payload package. WEMS software specifications also provide the methodology used by WEMS to ensure transuranic payload packages comply with the PE Ci restrictions prior to certification and shipment.

Verification that correct data is input and used by WEMS for calculation of PE Ci is performed during the " WIPP Verify" function described in 4 G83 WEM WP 1209, WEMS Package Verification and Certification. PE Ci values for each package are transmitted to the WWIS using WEMS in accordance with 4 K47 WEM WP1210, WEMS Offsite Shipping Module.

Most of the waste generated at the site is not treated or overpacked ( i. e., 55 gallon drums overpacked into a SWB or a TDOP). In general, waste is treated or overpacked if needed to produce a waste form or package in compliance with all applicable disposal waste acceptance criteria or other site specific requirements. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 126 5.3.5 Radiation Dose Rate Acceptance Criterion. The external radiation dose equivalent rate of individual payload packages shall be   200 mrem/ h at the surface. The external radiation dose equivalent rate of the TRUPACT II shall be   200 mrem/ h at the surface and   10 mrem/ h at 2 meters. Additional internal payload package shielding, beyond that identified in Appendix 2.1 of the TRAMPAC as an integral component of the payload package, shall not be used to meet this criterion. Total dose equivalent rate and the neutron contribution to the total dose equivalent rate shall be reported for each payload package in the WWIS.

<IP_ADDRESS> Methods of Compliance Radiation dose rates are determined as described in Section <IP_ADDRESS>. Neutron contributions to the total payload package dose rate are reported separately in the WWIS as specified in procedure 4 K47 WEM WP1210, WEMS Offsite Shipping Module.

5.3.6 Decay Heat Acceptance Criterion. The sum of the decay heat for each payload package plus its TMU shall be less than or equal to the limits of the assigned shipping category specified in Table 5.5 1 of Appendix 5.5 of the TRAMPAC. For CH TRU waste from Los Alamos National Laboratory Technical Area 54 assigned content Code LA 154, compliance with the decay heat requirements is pursuant to Appendix 1.2 of the TRAMPAC. For those payload packages that exceed the decay heat limit, a determination of compliance with the unified flammable ( gas/ volatile organic compound [ VOC]) concentration limit as specified in the TRAMPAC allows the payload package to be shipped in the TRUPACT II package under test category. The values calculated for decay heat and its associated TMU ( expressed in terms of one standard deviation) shall be reported to the WWIS for each payload package.

<IP_ADDRESS> Methods of Compliance Compliance with decay heat requirements is described in Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 127 5.4 Physical Properties 5.4.1 Residual Liquids Acceptance Criterion. Liquid waste is prohibited at WIPP. Waste shall contain as little residual liquid as is reasonably achievable by pouring, pumping, and/ or aspirating. Internal containers shall also contain no more than 1 inch or 2.5 cm in the bottom of the internal containers. The total residual liquid in any payload package shall not exceed 1 percent by volume of that payload package. If visual examination methods are used in lieu of radiography, then the detection of any liquids in non transparent internal containers will be addressed by using the total volume of the internal container when determining the total volume of liquids within the payload package.

<IP_ADDRESS> Methods of Compliance Compliance is provided through the use of 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 1 PRO 079 WGI 001, Waste Characterization, Generation and Packaging; PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( VV) and Data Review; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; associated WGI( s); and/ or radiography, or the appropriate Residues repackaging procedures as referenced in the TWCP QAPjP. To comply with 49 CFR, RFETS procedures do not permit the packaging of free liquids. The document 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, includes the requirement to thoroughly dry all wastes prior to packaging when possible. When it is not possible to thoroughly dry the waste items, the waste must be packaged in contact with enough suitable absorbent to accommodate twice the amount of any liquid that could potentially accumulate due to gravity or condensation.

Refer to Section <IP_ADDRESS> for additional information on compliance with the liquids restriction.

5.4.2 Sealed Containers Acceptance Criterion. Payload packages shall be verified to be free of sealed containers greater than 4 liters.

<IP_ADDRESS> Compliance Methods Refer to Section <IP_ADDRESS> for information on compliance with the prohibition of sealed containers greater than 4 liters in volume. Unvented rigid containers greater than 4 liters in volume are either headspace gas sampled or are vented prior to initiating headspace drum age and equilibrium criteria. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 128 5.5 Chemical Properties 5.5.1 Pyrophoric Materials Acceptance Criterion. Pyrophoric radioactive materials shall be present only in small residual amounts (< 1 percent by weight) in payload packages and shall be generally dispersed in the waste. Radioactive pyrophorics in concentrations > 1 percent by weight and all nonradioactive pyrophorics shall be reacted ( or oxidized) and/ or otherwise rendered nonreactive prior to placement in the payload package. Nonradionuclide pyrophoric materials are not acceptable at WIPP.

<IP_ADDRESS> Methods of Compliance The document 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, provides the requirement to exclude pyrophoric materials from being packaged. WGIs provide instructions for excluding pyrophoric materials from being packaged with the waste by referring to AK characterization.

AK documentation verifies no pyrophoric materials are present in TRU waste. This documentation is contained in an auditable record and summarized in RF/ RMRS 97 018, RFETS TRU Waste Acceptable Knowledge Supplemental Information.

Additional discussion of compliance is provided in the TRAMPAC section of this document. Specifically, Section <IP_ADDRESS> addresses compliance with the restriction on pyrophoric materials. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 129 5.5.2 Hazardous Waste Acceptance Criterion. Hazardous wastes not occurring as co contaminants with TRU wastes ( non mixed hazardous wastes) are not acceptable at WIPP. Each CHTRU mixed waste package shall be assigned one or more EPA hazardous waste codes as appropriate. Only EPA hazardous waste codes listed as allowable in the Hazardous Waste Facility Permit may be managed at WIPP. Wastes exhibiting the characteristic of ignitability, corrosivity, or reactivity ( EPA hazardous waste numbers of D001, D002, or D003) are not acceptable at WIPP. In the context of the WIPP WAC, hazardous waste codes are synonymous with hazardous waste numbers.

<IP_ADDRESS> Methods of Compliance AK is the basis for compliance and verification to the hazardous waste criterion. AK documentation, in the form of WSRIC process descriptions and Backlog Waste Reassessments, is used to assign EPA HWNs to waste packages. A detailed description of the RFETS AK process and controls is presented in the TWCP QAPjP, Section B4.

The documents 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, specify requirements and instructions to segregate non mixed waste from mixed waste to prevent commingling of RCRA regulated waste with non RCRA regulated waste. These documents also specify that waste may contain hazardous constituents as co contaminants of the waste only. Assigned EPA HWNs are entered into WEMS on a waste package basis ( 1 PRO 087 WEMS WP 1201, WEMS Waste Package Inventory, Tracking, and Control) and subsequently verified to ensure accuracy ( 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification). The WEMS software disqualifies transuranic waste packages with assigned EPA HWNs ( including HWNs D001, D002, and D003) that are not included on the list of EPA Hazardous Waste Numbers Acceptable at WIPP.

A complete discussion of how information on these constituents and compounds is collected and reported, along with references to implementing procedures, is provided in the TWCP QAPjP, Section B. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 130 5.5.3 Chemical Compatibility Acceptance Criterion. TRU waste containing incompatible materials or materials incompatible with payload package and packaging materials, shipping container materials, other wastes, repository backfill, or seal and panel closure materials are not acceptable for transport in the TRUPACT II and disposal at the WIPP. Chemical constituents shall conform to the lists of allowable materials in Tables 4 1 through 4 8 of the TRAMPAC. Other chemicals or materials not identified in these tables are allowed provided that they meet the requirements for trace constituents as specified in Section 4.3 of the TRAMPAC.

<IP_ADDRESS> Methods of Compliance Compliance with chemical compatibility requirements is accomplished by only shipping wastes under approved TRUCON codes. Chemical compatibility is evaluated during the submittal and authorization of site TRUCON codes. Chemical compatibility is accomplished by only shipping waste that comply with the TRUPACT II chemical lists for the assigned TRUCON code and waste material type. Refer to Sections 6.4.3 and 6.4.4 for additional information on the TRUPACT II chemical lists.

5.5.4 Explosives, Corrosives, and Compressed Gases Acceptance Criterion. Waste shall contain no explosives, corrosives, or compressed gases ( pressurized containers).

<IP_ADDRESS> Methods of Compliance The TRAMPAC Section ( Section <IP_ADDRESS>) documents compliance with the restriction on explosives, corrosives, and compressed gases. These prohibited items are controlled through a combination of AK, RTR and visual examination. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 131 5.5.5 Headspace Gas Concentrations Acceptance Criterion. The headspace gas of payload packages shall be sampled and analyzed in accordance with an approved site specific QAPjP, as defined in the WIPP WAP, to determine VOC concentrations.

Flammable VOCs are restricted to   500 ppm in the payload package headspace. For those payload packages that exceed the flammable VOC limit, a determination of compliance with the unified flammable ( gas/ VOC) concentration limit as described in the TRAMPAC allows the payload package to be shipped in the TRUPACT II under the test category.

Test category payload packages shall be tested to quantify the hydrogen/ methane, VOC, and total gas generation rates ( as appropriate) for purposes of determining if all applicable limits are met.

<IP_ADDRESS> Methods of Compliance The RFETS TWCP QAPjP is the approved site specific QAPjP at Rocky Flats. Headspace gas sampling and analysis of payload packages is performed to determine VOC concentrations in accordance with the RFETS TWCP QAPjP.

Flammable VOCs are restricted to   500 ppm in the payload package headspace. Payload packages that exceed the 500 ppm flammable VOC limit are categorized as Test Category Waste and evaluated to determine compliance with the unified flammable ( gas/ VOC) concentration limits as described in the TRAMPAC ( see Section <IP_ADDRESS>).

Test category payload packages are tested to quantify the hydrogen/ methane, VOC and total gas generation rate ( as appropriated) to determine if the payload package is shippable in the TRUPACT II. The methods used to test and qualify test category waste for shipment in the TRUPACT II are described in detail in Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 132 5.5.6 Polychlorinated Biphenyls Acceptance Criterion. Waste shall contain no polychlorinated biphenyl ( PCB) concentrations equal to or greater than 50 parts per million ( ppm).

<IP_ADDRESS> Methods of Compliance Compliance is accomplished through AK and/ or through sampling and analysis in accordance with the TWCP QAPjP and 95 WP/ SAP 001, Transuranic ( TRU/ TRM) Waste Sampling Plan. Waste streams containing PCBs are identified in the WSRIC Building Books. Individual packages containing PCBs are identified in the BWRBB. This information is tracked in WEMS for each PCB contaminated package. Waste potentially containing PCBs in concentration equal to or greater than 50 ppm are not shipped to WIPP for disposal.

5.6 Data Package Contents 5.6.1 Characterization and Certification Data Acceptance Criterion. RFETS shall prepare a WSPF for each waste stream. Each WSPF shall be approved by the CBFO prior to the first shipment of that waste stream. Characterization and certification information for each payload package shall be submitted to the WWIS and approved by the Data Administrator. Sites are required to estimate the CPR weights and report these estimates in the WWIS on a payload package basis. Any payload package from a waste stream that has not been preceded by an appropriate certified WSPF is not acceptable at WIPP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 133 <IP_ADDRESS> Compliance Methods WSPFs are prepared and submitted to WIPP for review and acceptance in accordance with PRO 944 WIPP 008, Completion of Waste Stream Profile Form for Waste to be Disposed of at WIPP. Characterization and certification data are maintained in WEMS and transmitted to the WWIS in accordance with 4 K47 WEM WP1210, WEMS Offsite Shipping Module; 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification; and 1 PRO 110 WP 1212, WIPP Waste Information System ( WWIS) Data Entry. Prior to WSPF approval, WEMS software controls allow characterization data to be transmitted to WWIS, but prevent transmission of certification data. Once a WSPF is approved by CBFO and an approval date is entered into the WWIS and WEMS, WEMS software controls allow transmission of certification data to the WWIS for payload packages in the waste stream. Assignment of payload packages to, and assembly of, TRUPACT II payloads is controlled by the e TRAMPAC system in WWIS. The e TRAMPAC system prevents payload packages from being assembled into TRUPACT II payloads until the payload package certification data are approved in the WWIS by a WWIS Data Administrator. This prevents any payload package from being shipped to WIPP prior to approval of a WSPF.

The quantity of cellulosics, plastics and rubber ( CPR) ( and other waste material parameters) are estimated either by RTR or Visual Verification in accordance with approved procedures as described in the RFETS TWCP QAPjP.

5.6.2 Shipping Data Acceptance Criterion. Sites shall prepare either a bill of lading or a uniform hazardous waste manifest for CH TRU waste shipments as required by the transportation requirements. The land disposal restriction notification for CH TRU mixed waste shipments shall state that the waste is not prohibited from land disposal. For shipment in TRUPACT II, the following documents shall be prepared for packages and assemblies, as appropriate: payload container transportation certification document; overpack payload container transportation certification document; and payload assembly transportation certification document.

<IP_ADDRESS> Methods of Compliance The Uniform Hazardous Waste Manifest and/ or the Bill of Lading is completed according to Traffic Management procedures. A LDR notification for TRU mixed waste shipments is generated in WEMS. The LDR notification states that the waste is not prohibited from land disposal. Refer to Section 6.6.2 for information on completion and processing of PCTCDs, OPCTCDs and PATCDs that are prepared for payload packages and assemblies. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 134 Table 5 1, Payload Package Assembly Configurations NUMBER OF PAYLOAD PACKAGES IN ASSEMBLY PAYLOAD PACKAGE CONFIGURATION 14 55 gallon drums 14 55 gallons drums, each containing one standard POC 14 55 gallons drums, each containing one S100 POC 14 55 gallons drums, each containing one S200 POC 2 SWBs 2 SWBs, each containing one ( 1) bin 2 SWB, each containing up to four ( 4) 55 gallon drums 1 TDOP, containing up to ten ( 10) 55 gallon drums 1 TDOP, containing up to six ( 6) 85 gallon drums ( each 85 gallon drum containing one 55 gallon drum) 1 TDOP, containing one ( 1) SWB 1 TDOP, containing one ( 1) bin within a SWB 1 TDOP, containing up to four ( 4) 55 gallon drums within a SWB Table 5 2, Weight Limits COMPONENT MAXIMUM WEIGHT ( LBS) Individual Payload package 55 Gallon Steel Drum ( DOT Spec. 17C) < 1,000 55 Gallon Steel Drum ( DOT Spec. 17H) < 1,000 55 Gallon Steel Drum ( UN/ 1A2/ X320/ S) < 700 55 Gallon Steel Drum ( UN/ 1A2/ X325/ S) < 716 55 Gallon Steel Drum ( UN/ 1A2/ X400/ S) < 822 55 Gallon Steel Drum ( UN/ 1A2/ X425/ S) < 937 55 Gallon Steel Drum ( UN/ 1A2/ X430/ S) < 948 55 Gallon Steel Drum ( UN/ 1A2/ X435/ S) < 959 55 Gallon Drum Overpacked in SWB < 1,450 SWB < 4,000 TDOP < 6,700 POC Payload package Standard POC  6" diameter < 328 Standard POC  12" diameter < 547 S100 POC < 650 S200 POC < 547 Payload package Assembly Payload Assembly of 14 55 gallon drums < 7,265 Payload Assembly of two SWBs < 7,265 TRUPACT II < 19,250 Truck ( Tractor/ Trailer) < 80,000 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 135 Table 5 3, Pu 239 FGE Limits PACKAGE TYPE PU 239 FGE LIMITa 55 gallon drum ( including all POCs) < 200 SWB < 325 TDOP < 325 TRUPACT II ( containing either 14 55 gallon drums, 2 SWBs, or 1 TDOP) < 325b TRUPACT II ( containing either 14 standard, 14 S100, or 14 S200 POCs) < 2800b a The above limits additionally require that each payload package contain no more than trace quantities ( less than or equal to 1 percent by weight of the contents) of beryllium. b Payloads that contain greater than trace quantities of beryllium shall be acceptable for transport in a TRUPACT II only if the Pu 239 FGE plus two times the measurement error is less than or equal to 100. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 136 Table 5 4, PE Ci Limits WASTE PACKAGE PACKAGING CONFIGURATION 239PU PE Ci LIMIT Direct load   all approved waste forms < 80 Direct load   solidified/ vitrified waste only < 1,800 Overpacked into a 85 gallon drum, SWB, or TDOP   all approved waste forms < 1,100 55 gallon drum in good condition Overpacked into a 85 gallon drum, SWB, or TDOP   solidified/ vitrified waste only < 1,800 Overpacked into a 85 gallon drum, SWB, or TDOP   all approved waste forms < 80, < 130, < 130 respectively 55 gallon drum in damaged condition Overpacked into a 85 gallon drum, SWB, or TDOP   solidified/ vitrified waste only < 1,800 55 gallon POC in good condition Direct load   all approved waste forms < 1,800 Overpacked into a TDOP   all approved waste forms < 1,100 85 gallon drum in good condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 Overpacked into a TDOP   all approved waste forms < 130 85 gallon drum in damaged condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 Direct load ( or a bin)   all approved waste forms < 130 Direct load ( or a bin)   solidified/ vitrified waste only < 1,800 Overpacked into a TDOP   all approved waste forms < 1,100 SWB in good condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 Overpacked into a TDOP   all approved waste forms < 130 SWB in damaged condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 137 This page is intentionally blank TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 138 6.0 TRUPACT II AUTHORIZED METHODS FOR PAYLOAD CONTROL ( TRAMPAC) COMPLIANCE PLAN 6.1 Introduction The TRAMPAC is the governing document for payload shipments in the TRUPACT II. All users of the TRUPACT II are required to comply with all payload requirements outlined in the TRAMPAC, using one or more of the methods described therein.

Each site shipping TRU waste in the TRUPACT II is required to prepare a sitespecific TRAMPAC Compliance Plan. This section of the TWMM ( i. e., Section 6.0) constitutes the TRAMPAC Compliance Plan for RFETS.

This TRAMPAC Compliance Plan identifies requirements and responsibilities for the management of TRU and TRU mixed waste in order to ensure compliance with the payload restrictions of the TRUPACT II package as outlined in the TRAMPAC. The TRAMPAC lists the restrictions on the waste to be transported in the TRUPACT II and the allowable methods for determination and control of these restrictions, and this TRAMPAC Compliance Plan also identifies applicable procedures to demonstrate how RFETS complies with each of the TRUPACT II payload restrictions. Appendix 10 correlates TRUPACT II payload restrictions to applicable RFETS procedures. The RFETS procedures will also be shown to be acceptable methods for payload control and/ or determination and verification as is dictated by the TRAMPAC. Adherence to the TRAMPAC Compliance Plan ensures that RFETS TRU and TRU mixed wastes are characterized, packaged, and controlled according to the methods and procedures described herein and will qualify for transport in the TRUPACT II package.

6.1.1 Scope The scope of the RFETS TRAMPAC Compliance Plan is to define and identify the methods used to ensure that only authorized contents are shipped in the TRUPACT II package from RFETS.

6.1.2 Purpose The purpose of this TRAMPAC Compliance Plan is to:

  Define the applicable requirements for a payload to be transported in the TRUPACT II.

  Describe the methods of compliance used at RFETS to prepare and characterize the contact handled ( CH) TRU materials or other payload materials prior to transport in a TRUPACT II package, including the quality control ( QC) and quality assurance ( QA) programs that shall be applied to these methods. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 139 6.1.3 Requirements Requirements are established to ensure compliance of the payload with the transportation parameters of the TRUPACT II packaging. This TRAMPAC Compliance Plan identifies payload requirements under the following categories:

  Container and Physical Properties   Nuclear Properties   Chemical Properties   Gas Generation   Payload Assembly   Quality Assurance.

6.1.4 Methods of Compliance The TRAMPAC describes all allowable methods to be used for determining compliance with each payload requirement and the controls imposed on the use of each method. This TRAMPAC Compliance Plan describes the specific allowable methods used at RFETS to ensure that the payload is compliant with each requirement and is qualified for shipment.

Compliance with transportation requirements applies to the following two categories of waste:

1. Waste Generated Under a Formal Certification Program. Payload packages in this category ( designated " 100 Series") are characterized individually based on process knowledge and visual examination at the time of waste generation. For sites using a set of site/ equipment specific procedures for payload control for compliance, an independent verification of compliance must be performed prior to transport for no less than 10 percent of the 100 Series payload packages transported from each site per year. This independent verification may consist of a second operator verifying the package contents or waste records during the waste generation process or RTR. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 140 6.1.4 Methods of Compliance ( continued)