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

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

1 02/ 26/ 03 Various DCR 1821. Correct procedure titles and numbers. Added DOE ID to the Document Approval Sheet in accordance with MP DOCS 18.4. Document issue date was 12/ 19/ 02. DOE/ WIPP approval was received 02/ 25/ 03 thus the change in effective date to 02/ 26/ 03.

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

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

5 TABLE OF CONTENTS ( continued)

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

6 TABLE OF CONTENTS ( continued)

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

7 TABLE OF CONTENTS ( continued)

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

8 TABLE OF CONTENTS ( continued)

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

9 TABLE OF CONTENTS ( continued)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

  homogeneous solids ( summary category S3000)

  soil/ gravel ( summary category S4000)

  debris waste ( summary category S5000).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

  To delineate TRU waste streams.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

  Proper sample handling and preservation.

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

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

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

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

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

B 4a( 7) Records Management Contract laboratories forward testing, sampling, and analytical QA documentation along with batch data reports, to the AMWTP Records Storage Facility. Raw data obtained by testing, sampling, and analyzing TRU waste in support of this document is identifiable, legible, and provides documentary evidence of quality. Refer to MPDOCS 18.2, AMWTP Records Management and MP TRUW 8.28 Project Administrative Controls for the Analytical Laboratories Department for a detailed description of records management procedures.

An electronic records system, [ the equivalent of a CBFO required Records Inventory and Disposition Schedule ( RIDS)] has been prepared, approved, and implemented by the AMWTP. All records relevant to an enforcement action under the WIPP Permit, regardless of disposition, will be maintained at the AMWTP until NMED determines that the records are no longer needed for enforcement action. The records will then be dispositioned as specified in the approved implementing procedure. All waste characterization data and related QA/ QC records in the AMWTP Records Storage Facility for TRU waste to be shipped to the WIPP facility are designated as either Lifetime Records or Non Permanent Records. Records that are designated as Lifetime Records are maintained for the life of the AMWTP waste characterization program plus six years. These records will then be offered to the WIPP facility for permanent archival of information of the records in the appropriate form, or transferred to the appropriate Federal Records Center ( FRC). Waste characterization records designated as NonPermanent Records are maintained for ten years from the date of ( record) generation and then dispositioned according to the requirements defined in MP DOCS 18.2, AMWTP Records Management. If the AMWTP ceases to operate, all records will be transferred before closeout. Table B 7 provides a listing of records designated as Lifetime Records and Non Permanent Records. Nothing in this QAPjP is intended to nor should it be interpreted to require the disclosure of any U. S. Department of Energy classified information to persons without appropriate clearance to view such information. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

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

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

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

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

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

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

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

  Generator/ storage site name and EPA Idaho ( ID)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Date of audit approved by NMED: ( 4)

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

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

( 5)

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

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

List applicable EPA Hazardous Waste Codes: 2 ( 13)

Applicable TRUCON Content Codes: ( 14)

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

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

Waste identification/ categorization schemes: ( 15)

Types and quantities of waste generated: ( 15)

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

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

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

Waste generating process description for each building: ( 16)

Process flow diagrams: ( 16)

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

( 16)

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

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

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

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

Waste Stream Profile Form Certification:

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

( 21)

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

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

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

47 Package Waste

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

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

Does HSG data support acceptable knowledge hazardous waste designation?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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