Reviewers are technically competent in the subject area being reviewed.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

  Deviations are documented   QA results are complete and documented correctly.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Headspace gas  The gas within the headspace of a container.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sites  Department of Energy TRU waste generator/ storage sites.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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