2. Waste Generated Prior to Site Implementation of a Formal Certification Program. Payload packages in this category ( designated " 200 Series") are characterized based on process knowledge. An independent verification of compliance shall be performed prior to transport for 200 Series waste using visual examination, RTR, measurement, etc., under a statistical sampling program.

NOTE: All waste currently at RFETS was generated after a formal certification program was established at the Site in the mid 1980s and so is categorized as " 100 Series" waste.

A summary of the methods of compliance used, individually or together, for TRUPACT II payload control is provided in the following subsections.

<IP_ADDRESS> Visual Examination Visual examination at the time of waste generation may be used to qualify waste for transport ( e. g., 100 Series waste). The operator( s) of a waste generating area shall visually examine the physical form of the waste according to site/ equipment specific procedures, and remove all prohibited waste forms, prior to its placement in the payload package. Observation of the waste generation process by an independent operator may be used as an independent verification of the compliance prior to closure of the payload package. Visual examination under a sampling program may be used to verify the absence of prohibited items ( e. g., 200 Series waste). See the TWCP QAPjP, Section B 3c for details.

<IP_ADDRESS> Visual Inspection Visual inspection may be used to evaluate compliance with specific restrictions ( e. g., visual inspection of payload package type, marking, number of filters, etc.). Visual inspection by a second operator may be considered independent verification.

<IP_ADDRESS> Real Time Radiography RTR may be used as an independent verification to qualify waste for transport. RTR shall be used to nondestructively examine the physical form of the waste, and to verify the absence of prohibited waste forms, after the payload package is closed. Site/ equipment specific QA and QC procedures should ensure that RTR operator( s) are properly trained and qualified. See Section <IP_ADDRESS>.2 for additional details. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 141 <IP_ADDRESS> Records and Database Information Information obtained from existing site records and/ or databases or knowledge of process may be used as a basis for reporting the absence of prohibited waste forms within waste packages. This information can be verified using RTR and/ or a waste sampling program.

<IP_ADDRESS> Administrative and Procurement Controls Site specific administrative and procurement controls may be used to show that the payload package contents are monitored and controlled, and to demonstrate the absence of prohibited items.

<IP_ADDRESS> Sampling Programs Sampling programs may be used as an independent verification of the compliance ( e. g., for 200 Series waste). A site specific sampling program designed to address all payload requirements needing verification is recommended.

<IP_ADDRESS> Measurement Direct measurement or evaluation based on analysis using the direct measurement may be used to qualify waste ( e. g., direct measurement of the weight or analysis of assay data to determine decay heat).

6.1.5 TRUCON Document The TRUCON document is a catalog of authorized contents for the TRUPACT II and provides specific information on the transportation parameters for each RFETS authorized content code. Content codes in TRUCON describe how a particular waste form complies with the TRAMPAC. Each code is assigned to one or more payload shipping categories. A shipping category places restrictions on the transportation parameters that are discussed in this TRAMPAC Compliance Plan.

A content code begins with a two letter abbreviation to identify the shipping site ( i. e., RF denotes RFETS). This is followed by a three digit number: AXX. If A is " 1," this indicates that the waste was generated after a formal certification program was established at the Site. If A is " 2" this indicates that the waste was generated before a formal certification program was established at the Site. Note: The vast majority of waste currently at RFETS was generated after a formal certification program was established at the Site in the mid 1980s and so is categorized as " 100 Series waste." TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 142 6.1.5 TRUCON Document ( continued)

The XX is a number representing a general waste form ( glass, metals, combustibles, filter waste, etc.). The TRUCON document provides descriptions for these general waste form codes. For the RFETS content codes, a letter suffix is added to identify different packaging configurations.

The content codes defined in TRUCON fully characterize the waste and provide descriptions for compliance with the following parameters:

  Content Description   Storage Site ( if applicable)

  Generating Site   Waste Description   Generating Source( s)

  Waste Form   Waste Packaging   Assay   Free Liquids   Explosives/ Compressed Gases   Pyrophorics   Corrosives   Chemical Compatibility   Payload Package Venting and Aspiration   Additional Criteria   Shipping Category.

  Maximum Allowable Wattage TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 143 6.1.5 TRUCON Document ( continued)

All payload packages must have an approved TRUCON code to be eligible for shipment in the TRUPACT II. Table 6 7 lists the RFETS content codes. If RFETS requires the transportation of TRU waste in the TRUPACT II that is not listed in Table 6 7, the revision or addition of a content code must be requested in writing and submitted to the TRUPACT II Cognizant Engineer. The process for requesting a new or revised content code is outlined in Section 1.5 of the TRAMPAC. Specifically, a shipping site is required to perform the following actions to add or revise a TRUCON code:

1. The Site prepares in writing a draft TRUCON code containing sufficient information to satisfy all of the necessary elements of a TRUCON code, previously identified. If the request is for a TRUCON code revision, only the revised elements require preparation and documentation. The site shall ensure that the information submitted in the form of a TRUCON code addition or revision accurately describes the waste and waste generating processes to the best of their knowledge.

2. The site submits the draft TRUCON code or TRUCON code elements in writing to the TRUPACT II Cognizant Engineer for review.

3. If the request is approved, a site may begin using the new or revised TRUCON code once official notification is received from the TRUPACT II Cognizant Engineer. Sites may not use proposed TRUCON code additions or revisions to make shipments in the TRUPACT II prior to receipt of written notification from the TRUPACT II Cognizant Engineer. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 144 6.1.6 Compliance Program RFETS documents and demonstrates compliance with the TRAMPAC in a site/ equipment specific set of procedures for payload control as identified and described in this TRAMPAC Compliance Plan. The TRAMPAC Compliance Plan is submitted to CBFO for approval. This TRAMPAC Compliance Plan has been prepared in accordance with the TRAMPAC.

<IP_ADDRESS> Transportation Certification Official ( TCO)

The TCO is responsible for administratively verifying the compliance of payload packages and the payload assembly with transportation requirements. The TCO approves by signature on the transportation certification documents every payload for transport.

A similar position ( i. e., WCO) is responsible for verifying that all waste prepared for shipment to the WIPP meets the specified WIPP WAC. The functions of the two positions may be performed by the same or different official( s).

<IP_ADDRESS> Carlsbad Field Office ( CBFO)

The CBFO is responsible for the performance of compliance verification audits, which are conducted prior to the first shipment and periodically thereafter, to evaluate TRUPACT II payload compliance. Audit activities include document review and interview of operators on a job function basis relative to meeting the applicable criteria. The audit team will grant or deny waste certification and waste transportation authorization based on objective findings.

6.1.7 Quality Assurance The QA requirements applicable to the use of the TRUPACT II packaging are Title 10, Code of Federal Regulations ( CFR), Part 71, Subpart H. The use, operation, and maintenance of the TRUPACT II are conducted under a QA program approved by the DOE field office. The compliance of a payload to be transported in the TRUPACT II is determined by the user under a QA program approved by the CBFO. The packaging QA program is described in Section 4.6. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 145 6.2 Container and Physical Properties Requirements 6.2.1 Container Descriptions <IP_ADDRESS> Requirements Only the following payload packages are authorized for shipment in the TRUPACTII ( see the TRAMPAC, Section 2.1):

  55 Gallon Drum ( including standard, S100, or S200 POCs)

  100 Gallon Drum   SWB   TDOP All packages transported within the TRUPACT II shall comply with the specifications in the TRAMPAC, Appendix 2.1. The maximum number of packages per TRUPACT II and authorized packaging configurations are as follows:

  Fourteen 55 gallon drums   Fourteen standard POCs   Fourteen S100 POCs   Fourteen S200 POCs   Six 100 gallon drums TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 146 <IP_ADDRESS> Requirements ( continued)

  Two SWBs   Two SWBs, each SWB containing up to four 55 gallon drums1   Two SWBs, each SWB containing one bin   One TDOP   One TDOP, containing up to ten 55 gallon drums1   One TDOP, containing up to six 85 gallon drums each overpacking one 55 gallon drum1   One TDOP, containing one SWB   One TDOP, containing up to four 55 gallon drums within an SWB1   One TDOP, containing one bin within an SWB.

NOTE: Use of all payload configurations above may not currently be implemented ( e. g., bin). Prior to using a payload configuration not currently in use, procedures must be developed and implemented. Mention of all payload package types is for information only.

<IP_ADDRESS> Methods of Compliance and Verification Compliance is accomplished using administrative and procurement controls demonstrating that payload packages have been procured to the specifications of the TRAMPAC, Appendix 2.1 ( see Packaging QA Program Plan  Section 4.6).

As required by 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, waste packaging materials ( e. g., drums, SWBs, and POCs) are inspected upon receipt from vendors, if required, in accordance with PRO J44 RC& I 6600, Procured Items Inspection and Certification, by the appropriate receiving certification and inspection organization( s) to ensure conformance to procurement specifications. Waste packages, hardware, package liners, and ancillary equipment are procured in accordance with MAN 134 PPM, Procurement Program Manual. Procurement specifications are prepared in accordance with the 1 V51 COEMDES 210, Site Engineering Process Procedure, and PRO 1034 PEQA, Procurement Engineering and Quality Assurance.

1 Empty packages or spacers are required if fewer packages are overpacked. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 147 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Procedure 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, and applicable WGIs, that are prepared in accordance with procedure 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging, include instructions for inspecting the integrity of the drum or SWB before loading, packaging, or use.

Procedure PRO 1045 WI 001, Solid Radioactive Waste Inspection, provides instruction for the performance of a final inspection of each payload package prior to certification and shipment. Procedure PRO X05 WC 4018, Transuranic ( TRU) Waste Certification, provides instructions for verifying the integrity of the payload package as part of the waste certification process.

Payloads are created in the e TRAMPAC system in WWIS. Software controls in the e TRAMPAC system ensure that created payloads comply with one of the authorized payload configurations. A PATCD is generated from e TRAMPAC for each payload and the PATCD specifies the exact composition of each payload configuration. The payload configuration as specified on the PATCD is verified in accordance with instructions in procedure PRO X05 WC 4018, Transuranic ( TRU) Waste Certification.

6.2.2 Dunnage <IP_ADDRESS> Requirements A shipper shall use empty 55 gallon drums, 100 gallon drums, or an SWB as dunnage to complete a payload configuration if too few payload packages are available that meet transportation requirements. Dunnage must meet the specifications of the TRAMPAC, Appendix 2.1, with the exception that dunnage shall have open vent ports ( i. e., not filtered or plugged).

Dunnage shall be marked in accordance with Section 6.2.4. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 148 <IP_ADDRESS> Methods of Compliance and Verification Dunnage drums may be assembled into a seven pack ( 55 gallon) or three pack ( 100 gallon) of only dunnage drums, or they may be assembled into a seven pack or three pack with drums of waste that meet all applicable requirements. In the latter case, the dunnage drum( s) must be labeled with a unique package identification number like the waste drums because of requirements associated with the WWIS. All dunnage packages must be labeled " EMPTY" or " DUNNAGE." Waste Operations is responsible for preparing dunnage drums for shipment, which is discussed in the TRUPACT II loading procedures. WEMS initiates and tracks dunnage drums used for TRUPACT II shipments in accordance with 4 K47 WEMWP1210 WEMS Offsite Shipping Module.

Dunnage containers are visually inspected to verify compliance with the dunnage requirements in accordance with procedure PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 149 6.2.3 Container/ Assembly Weight and Center of Gravity <IP_ADDRESS> Requirements <IP_ADDRESS>.1 Requirements for Package/ Assembly Weight NOTE: Actual payload assembly weights are limited by " as built" TRUPACT II weights and DOT requirements for a loaded tractor/ trailer.

Each payload package, payload assembly, and loaded TRUPACT II shall comply with the following weight limits:

  328 pounds per 6 inch diameter standard POC   547 pounds per 12 inch diameter standard POC   650 pounds per S100 POC   547 pounds per S200 POC   1,000 pounds per 55 gallon drum ( Note: The RFETS limit is 800 lbs.)

  1,000 pounds per 100 gallon drum   4,000 pounds per SWB   6,700 pounds per TDOP   7,265 pounds per payload of up to 14 55 gallon drums or up to 6 100 gallon drums, including pallet, guide tubes, slip sheets ( optional), banding material and reinforcing plate, OR   7,265 pounds per payload of two SWBs, including adjustable sling ( optional) AND   19,250 pounds for payload and TRUPACT II package ( as built weight of TRUPACT II is approximately 13,050 lbs.).

<IP_ADDRESS>.2 Requirements for Center of Gravity The total weight of the top seven 55 gallon drums, three 100 gallon drums, or SWB of the payload assembly shall be less than or equal to the total weight of the bottom layer of drums or the bottom SWB. The total weight of the top five drums in a TDOP shall be less than or equal to the total weight of the bottom five drums. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 150 <IP_ADDRESS> Methods of Compliance and Verification <IP_ADDRESS>.1 Methods of Compliance and Verification for Package/ Assembly Weight Weighing of Individual Payload Packages Compliance is verified by measurement. Each payload package ( or dunnage) is weighed on a calibrated scale in accordance with approved procedures PRO 1411 WO WASTE, Waste Receiving, Transfer and Handling and/ or PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( VV) and Data Review. The weight and the measurement error of each payload package is recorded in the TRUPACT II PCTCD. RFETS uses a measurement error of one standard deviation or greater for all weight measurements.

One of two methods is used to calculate the total weight of the TRUPACT II payload:

  If total payload weight is obtained by summing the weights of the individual payload packages or dunnage ( plus 265 pounds for pallets, reinforcing plates, slip sheets, guide tubes, banding material, etc.), it includes the square root of the sum of the squares of the individual measurement errors.

  If the total payload is weighed as an assembly, the measurement includes the error.

The weight and the measurement error is reported in accordance with the PATCD.

The scale calibrations are performed in accordance with the National Institute for Standards and Technology ( NIST) Handbook 44 or an equivalent standard. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 151 <IP_ADDRESS>.1 Methods of Compliance and Verification for Package/ Assembly Weight ( continued)

The document 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, defines gross weight limits for payload packages. 55 gallon drums ( without POC) have a limit of 800 lbs. The gross weight of each payload package is recorded on the W/ RT and in WEMS. The recorded weight of the payload package includes the addition of the error and is verified as part of the " Radioactive Verify" function as described in procedure 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification. A payload package that does not comply with the weight limit or container certification weight ( allowable Type A test weight limit) is segregated for repackaging or other corrective action. WEMS ensures compliance with TRUPACT II limitations. Procedure PRO 1045 WI 001, Solid Radioactive Waste Inspection, provides instructions for final inspection to verify that the acceptance criteria for the weight of the waste packages are not exceeded; and also contains the instructions for final loading of waste packages. These procedures, as well as Traffic Management procedure, PRO T43 Traffic 528, TRUPACT II Operations, address verification that the weight of waste packages does not exceed the acceptance criteria.

Trained and qualified personnel calibrate and maintain the scale and document those actions in accordance with formal operating and QA procedures. Calibration is in accordance with NIST Handbook 44. Metrology is responsible for oversight of the RFETS Calibration program. Procedure MAN 092 M& TEM, Measuring and Test Equipment Management, describes the process and instructions used for the calibration of measurement and test equipment such as scales.

<IP_ADDRESS>.2 Methods of Compliance and Verification for Center of Gravity The weight and measurement error of each payload package and of the total TRUPACT II payload is calculated and reported in the PATCD as generated through the e TRAMPAC system in WWIS. The e TRAMPAC system, in conjunction with procedure DOE/ WIPP 02 3184, CH Packaging Operations Manual ensures compliance with the total TRUPACT II payload weight, center of gravity restrictions, and all applicable DOT weight restrictions. The total weight includes the square root of the sum of the squares of the individual measurement errors or, if weighed as an assembly, includes the error in the measurement. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 152 6.2.4 Container Marking <IP_ADDRESS> Requirements Each payload package and dunnage shall be labeled with a unique container identification number.

If an empty 55 or 100 gallon drum or SWB is used as dunnage to complete a payload configuration, the dunnage package shall be labeled with the following information:

  Unique container identification number   " EMPTY" or " DUNNAGE."

If a seven pack of only dunnage 55 gallon drums, a three pack of only dunnage 100 gallon drums, or a dunnage SWB is used in the TRUPACT II, the package( s) will be labeled " EMPTY" or " DUNNAGE." The unique container identification number is not required for these configurations.

<IP_ADDRESS> Methods of Compliance and Verification Labeling and marking is performed in accordance with instruction in PRO T13 Traffic 306, Labeling and Marking TRUPACT Packages.

Compliance is demonstrated through a visual inspection of each payload and dunnage package in accordance with PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. The package is recorded ( through the use of the unique package identification number) on the PCTCD. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 153 6.2.5 Filter Vents <IP_ADDRESS> Requirements Each payload package to be transported in the TRUPACT II, including all payload packages that are overpacked in other payload packages, shall have one or more filter vents that meet the specifications of the TRAMPAC, Appendix 2.5. Filter vents in plastic bags used as confinement layers within payload packages shall also meet the specifications in the TRAMPAC, Appendix 2.5. Filters procured and used comply with the applicable efficiency, flow, and hydrogen diffusion requirements specified in the TRAMPAC, Appendix 2.5. The minimum number of filter vents required is as follows:

  One filter per heat sealed plastic bag   One filter per filtered metal can   One filter per 55 gallon drum   One filter per 55 gallon drum overpacked in an SWB   One filter per 100 gallon drum   Two filters per SWB   Two filters per Bin   Nine filters per TDOP   One filter per standard, S100, or S200 POC. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 154 <IP_ADDRESS> Methods of Compliance and Verification Compliance is demonstrated by one, or a combination, of the following methods:

  Administrative and procurement controls demonstrating that filter vents have been procured to the specifications of the TRAMPAC, Appendix 2.5.

  Visual inspection to the specifications of the TRAMPAC, Appendix 2.5.

  Sampling by measurement of filter characteristics to the specifications of the TRAMPAC, Appendix 2.5.

Site specific QA and procurement procedures provide verification that filters meet the specifications. Visual inspection provides verification that the correct number of filters has been installed on each payload package.

Filters are procured in accordance with MAN 134 PPM, Procurement Program Manual. Procurement specifications for filters are prepared in accordance with 1 V51 COEM DES 210, Site Engineering Process Procedure, and PRO 1034 PEQA, Procurement Engineering and Quality Assurance.

Procedure PRO 1045 WI 001, Solid Radioactive Waste Inspection, provides instructions for ensuring that the minimum number of filters are installed in the drums and the SWBs. In addition, 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, and associated WGIs provide instructions for ensuring that the minimum number of filters are installed in the drum and SWB at the time of waste packaging. Procedure 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, also provides specifications for the filters. These filters meet the criteria specified in the TRAMPAC, Appendix 2.5.

Verification that the correct number and type of filters are installed on payload packages is accomplished by visual inspection per procedure PRO 1045 WI 001, Solid Radioactive Waste Inspection. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 155 6.2.6 Liquids <IP_ADDRESS> Requirements NOTE: 49 CFR allows no free liquids in solid material packages.

Liquid waste is prohibited in payload packages, except for residual amounts in welldrained inner containers. The total volume of residual liquid in a payload package is restricted to less than 1 volume percent of the payload package ( e. g., drum or SWB).

<IP_ADDRESS> Methods of Compliance and Verification Compliance is demonstrated by one, or a combination, of the following methods:

  Review of records and database information, which may include knowledge of process   RTR   Visual examination   Sampling program.

Documents 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Radioactive Waste Packaging Procedure; and wastespecific WGIs are used to specify packaging requirements to the waste generators or operators, defining those waste items and materials that are prohibited from the waste. These instructions identify methods for ensuring that free liquids are not present in the payload package. RFETS prohibits the presence of free liquids in the payload packages for both on site transfers and off site shipments, as defined in 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 156 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Verification of compliance is accomplished using visual examination, in process inspection, and/ or RTR. Specifically, verification of compliance with the physical form restrictions in each payload package is accomplished using the following methods:

1. Documented independent visual examination of the waste contents at the time of packaging per 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( V2) and Data Review; associated WGI( s); and/ or the appropriate Residues repackaging procedures as referenced in the TWCP QAPjP; and/ or 2. Radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP.

Independent visual examination of the waste contents at the time of packaging involves using a second operator ( or QA inspector), other than the operator who filled the payload package, to inspect the waste and verify that the physical waste form is in compliance with applicable requirements. This second operator documents the verification by signature on the W/ RT.

Payload packages rejected at RTR for non compliance with the physical form criteria are identified and controlled as nonconformances in accordance with PRO U76 WC 4030, Control of Waste Nonconformances. RFETS RTR operators are trained in accordance with 5 NDT TC 1A, Training, Qualification, and Certification of Nondestructive Testing Personnel. Training and certification of mobile vendor RTR operators is in accordance with the mobile vendor training plan ( refer to the TWCP QAPjP). Additional RFETS training that orients mobile vendor RTR personnel to the RFETS TWCP is required per the TWCP TIP.

Compliance for previously packaged TRU waste is verified by periodic visual examination of a random sample of previously packaged waste in accordance with PRO 1358 440 VERP, Glovebox and C Cell Waste Operations; PRO 1471 VE 771, Visual Examination for Confirmation of RTR1; PRO 1608 VECRTR 371, RTR Visual Examination Confirmation, Building 3712; and/ or 4 H80 776 ASRF 007, Visual Examination for Confirmation of RTR3.

1 This procedure is inactive as of November 14, 2003. 2 This procedure is inactive as of August 12, 2003. 3 This procedure is inactive as of November 6, 2001. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 157 6.2.7 Sharp or Heavy Objects <IP_ADDRESS> Requirements Sharp or heavy objects in the waste shall be blocked, braced, or suitably packaged as necessary to provide puncture protection for the payload packages containing these objects.

<IP_ADDRESS> Methods of Compliance and Verification Compliance is demonstrated by one, or a combination, of the following methods:

  Review of records and database information, including knowledge of process   RTR   Visual examination   Sampling program.

Documents 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; and the use of WGIs per 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging, where applicable, provide packaging and documentation instructions to ensure that sharp or heavy objects are suitably blocked, braced, or packaged to preclude damage to the payload package.

Compliance for previously packaged transuranic waste is verified by radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP. Additionally, compliance is also verified through periodic visual examination of a random sample of previously packaged waste performed in accordance with PRO 1358 440 VERP, Glovebox and C Cell Waste Operations; PRO 1471 VE 771, Visual Examination for Confirmation of RTR1; PRO 1608 VECRTR 371, RTR Visual Examination Confirmation, Building 3712; and/ or 4 H80 776 ASRF 007, Visual Examination for Confirmation of RTR3.

1 This procedure is inactive as of November 14, 2003. 2 This procedure is inactive as of August 12, 2003. 3 This procedure is inactive as of November 6, 2001. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 158 6.2.8 Sealed Containers <IP_ADDRESS> Requirements Sealed containers greater than 4 liters are prohibited except for Waste Material Type II. 2 packaged in a metal container; Waste Material Type II. 2 in metal cans does not generate any flammable gas ( see the TRAMPAC, Appendix 5.1).

NOTE: The type II. 2 exception is not allowed for shipments to WIPP per the WIPP WAC, Section 3.4.2.

<IP_ADDRESS> Methods of Compliance and Verification Compliance is demonstrated by one, or a combination, of the following methods:

  Review of records and database information, including knowledge of process   RTR   Visual examination   Sampling program.

Verification of compliance is accomplished using visual examination, and/ or RTR. Specifically, verification of compliance with the sealed containers restrictions in each payload package is accomplished using the following methods:

1. Documented independent visual examination of the waste contents at the time of packaging per 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( V2) and Data Review; associated WGI( s); and/ or the appropriate Residues repackaging procedures as referenced in the TWCP QAPjP; and/ or 2. Radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 159 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Compliance for previously packaged transuranic waste is verified by periodic visual examination of a random sample of previously packaged waste performed in accordance with PRO 1358 440 VERP, Glovebox and C Cell Waste Operations; PRO 1471 VE 771, Visual Examination for Confirmation of RTR1; PRO 1608 VECRTR 371, RTR Visual Examination Confirmation, Building 3712; and/ or 4 H80 776 ASRF 007, Visual Examination for Confirmation of RTR3. Containers with volumes greater than four liters may be present in the waste only if there is verifiable evidence that they are not sealed ( e. g., documented or visible absence of cap, presence of a puncture in the container, or test data that demonstrates that the container is not sealed).

6.3 Nuclear Properties Requirements The nuclear properties' requirements outlined in this section require a knowledge of isotopic composition and quantity of fissile material. The four major product material isotopic compositions are:

  Weapons grade plutonium ( Pu) ( primarily Pu 239)

  Fuel grade plutonium ( primarily Pu 239)

  Heat source plutonium ( primarily Pu 238)

  Other transuranic isotopes.

RFETS process areas usually only handle product materials of specific isotopic composition ( e. g., weapons grade plutonium composition is shown in Section <IP_ADDRESS>). Therefore, the isotopic composition in the waste from specific process areas remains constant since product isotopic composition is closely controlled to meet production isotopic specification requirements.

Plutonium is also recovered from scrap material to produce product material. TRU wastes generated from scrap recovery operations are assigned the same plutonium isotopic composition as the product material. The recovery operation removes the non plutonium radionuclides [ e. g., 241Am] from the scrap material. The removed radionuclides are concentrated in the recovery operation's waste streams, and additional analyses ( e. g., gamma ray pulse height analysis) are performed on the waste streams, to determine their isotopic composition.

1 This procedure is inactive as of November 14, 2003. 2 This procedure is inactive as of August 12, 2003. 3 This procedure is inactive as of November 6, 2001. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 160 6.3 Nuclear Properties Requirements ( continued)

Other product material mixtures are occasionally produced by special request, and the isotopic compositions of these special mixtures [ e. g., varying ratios of 241Am, 244Cm, and 252Cf] are thoroughly characterized by the production facility.

Research and development facilities provide support to the plutonium production facilities and utilize a production facility's product specification data [ determined by mass spectrometry ( MS)] when assigning the radioisotopic composition to their waste.

Facilities that produce or utilize special ( non plutonium) TRU radionuclides have more variability in the isotopic distribution in the waste. There is less reliance on production records and specifications for determining isotopic distribution.

Facilities that examine special reactor fuels have the most detailed and traceable data regarding the isotopic composition of the waste. The quantity of waste generated from these activities is very small and highly characterized. The initial isotopic composition of the fuel, neutron flux, irradiation time, and cooldown time are measured and documented. The isotopic composition of the irradiated fuel is calculated based on the data mentioned above, or the isotopic composition of the irradiated fuel is confirmed by radiochemical analysis. The isotopic composition of the waste shall be determined by either referencing the irradiated fuel analysis or by direct measurement of the waste by segmented gamma scan. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 161 6.3.1 Nuclear Criticality <IP_ADDRESS> Requirements NOTE: Pu 239 fissile gram equivalent ( FGE) measurement error refers to standard error ( i. e., FGE measurement error at one standard deviation = 1 sigma).

A payload package shall be acceptable for transport only if the Pu 239 FGE plus two times the measurement error is less than 200 grams for a 55 or 100 gallon drum, 200 grams for a standard, S100, or S200 POC, 325 grams for an SWB, or 325 grams for a TDOP. Note: If a payload package will be overpacked, FGE limits apply only to the outermost payload package of the overpacked configuration.

A TRUPACT II shall be acceptable for transport only if the Pu 239 FGE plus two times the measurement error is less than or equal to 325 grams for a TRUPACT II with a payload of 14 55 gallon drums, 6 100 gallon drums, 2 SWBs, or 1 TDOP; or 2,800 grams for a TRUPACT II with a payload of 14 standard, S100, or S200 POCs.

The above limits additionally require that each payload package contain no more than trace quantities ( less than or equal to 1 percent by weight of the contents) of beryllium. Payloads that contain greater than trace quantities of beryllium shall be acceptable for transport in a TRUPACT II only if the Pu 239 FGE plus two times the measurement error is less than or equal to 100.

<IP_ADDRESS> Methods of Compliance and Verification Compliance with the FGE requirements involves the following steps:

  Determination of the isotopic composition   Determination of the quantity of radionuclides   Calculation of the FGE and compliance evaluation Each of these steps is discussed in detail in the following. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 162 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Isotopic Composition The isotopic composition of the waste may be determined from direct measurements taken on the product material during the processing or post process certification, analysis of the waste, or from existing records. The isotopic composition of the waste need not be determined by direct analysis or measurement of the waste unless process information is not available.

Pu 239 FGE for other fissile or fissionable isotopes, including special actnide elements, shall be obtained using the American National Standards Institute ( ANSI)/ American Nuclear Society ( ANS) method ANSI/ ANS 8.15 1981, Nuclear Criticality Control of Special Actinide Elements, or an equivalent method.

The two allowed analytical methods for determining isotopic composition are:

  Mass Spectrometry ( MS)

  Gamma ray pulse height analysis Depending on the mixture of radionuclides present in the waste, one or both of the methods may be required. These assay methods are described in greater detail in the TRAMPAC.

MS is a primary method for determining the radioisotopic composition in product material ( e. g., plutonium isotopic composition). The plutonium isotope analyses shall be performed in accordance with the following American Society for Testing and Materials ( ASTM) MS methods: ASTM C 696 80, Methods for Chemical, Mass Spectrometric, and Spectrochemical Analysis of Nuclear Grade Uranium Dioxide Powders and Pellets; ASTM C 697 86, Methods for Chemical, Mass Spectrometric, and Spectrochemical Analysis of Nuclear Grade Plutonium Dioxide Powders and Pellets; ASTM C 759 79, Methods for Chemical, Mass Spectrometric, and Spectrochemical, Nuclear, and Radiochemical Analysis of Nuclear Grade Plutonium Nitrate Solutions; and ASTM C 853 82, Standard Test Methods for Nondestructive Assay of Special Nuclear Materials Contained in Scrap and Waste, or equivalent methods.

Gamma ray pulse height analysis or MS is used to determine the isotopic composition for gamma emitting radionuclides. Gamma ray pulse height analysis shall be performed in accordance with ASTM C 1030 84, or an equivalent method. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 163 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

The isotopic composition of the waste streams generated at RFETS is well characterized through destructive measures performed on product material during processing and this acceptable knowledge ( AK) is documented in an auditable record. Therefore, the isotopic composition of a particular waste stream need not be determined by direct methods of analysis or measurement unless process information is not available.

All nondestructive assay ( NDA) equipment used for assaying TRU waste is equipped with the ability to determine the isotopic composition of wastes for which the counters are qualified to assay. If isotopic information is measured, then this information supercedes the isotopic compositions determined by AK as described above.

The plutonium used at the RFETS is weapons grade ( WG) plutonium. The isotopic distribution has been well characterized and was routinely checked and verified during operations at the RFETS using one of the two allowed analytical methods identified previously ( gamma ray pulse height analysis or MS). The standard isotopic distribution for WG plutonium is as follows:

Isotope Weight% Pu 238 0.016 Pu 239 93.737 Pu 240 5.872 Pu 241 0.332 Pu 242 0.043 Table 6 1 lists the Pu 239 FGE, as well as the decay heat and specific activity, of many additional radionuclides.

AK is utilized to determine the possible presence of radionuclides other than weapons grade plutonium in TRU waste. Specifically, AK as described in RF/ RMRS 97 018, RFETS TRU Waste Acceptable Knowledge Supplemental Information, provides information by which waste packages can be identified to contain radionuclides other than weapons grade plutonium based on the area and date of generation of the waste. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 164 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Quantity of Radionuclides The quantity of the radionuclides in each payload package is estimated by either a direct measurement or records of the individual payload package, a summation of assay results from individual packages in a payload package, or a direct measurement on a representative sample of a waste stream ( such as solidified inorganics). An assay refers to one of several radiation measurement techniques that determine the quantity of nuclear material in TRU wastes. In certain cases, AK is used to quantify radionuclides. If assay is performed to quantify radionuclides, then, one or a combination of the following allowed assay methods is used:

  Passive Gamma [ e. g., Tomographic Gamma Ray Scanner ( TGS)]

  Radiochemical assay ( alpha and gamma spectroscopy)

  Passive neutron coincidence counting ( PNCC)   including high efficiency neutron counting   Passive active neutron assay ( PAN)

  Calorimetry.

Appendix 4 provides a description of the currently used and planned NDA methods and compliance of these methods with applicable requirements. These methods comply with the assay methods described in the TRAMPAC, Attachment B.

General assay requirements that apply for determination and control of radionuclide quantity are:

  The selection and use of an assay method( s) must be identified in this document as an allowable method( s) with prescribed controls implemented.

  The applicable waste content code descriptions list the specific assay method( s) and their applications( s).

  Operating and QA procedures describe the assay method( s) and the controls imposed on the assay operations. The controls include performing calibration and background measurements. The calibration and background measurements must fall within the stated acceptable ranges before assays are performed.

  QA plans and procedures include oversight of assay methods and controls.

  A specialized training program for assay operators must be provided. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 165 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Calculation of the FGE and Compliance Evaluation The FGE of each payload package is calculated from the isotopic composition and quantity of radionuclides to ensure that the FGE plus two times the measurement error is less than or equal to the applicable limit for each payload package. The Pu 239 FGE of each payload package is recorded in the PCTCD and OPCTCD, as applicable.

The total Pu 239 FGE for a TRUPACT II payload is calculated and recorded in the PATCD. The total Pu 239 FGE error is the square root of the sum of the squares of twice the individual Pu 239 FGE errors. This error is added to the calculated TRUPACT II payload FGE to determine compliance with the applicable payload FGE limit.

Associated WEMS software specifications define the methods and controls that WEMS uses to calculate the FGE for each payload package. The e TRAMPAC software system in the WWIS also calculates FGE for each payload package and verifies compliance with the FGE limits prior to WWIS approval. Furthermore, the e TRAMPAC system provides the methods and controls used for calculation of FGE for assembled TRUPACT II payloads. These software specifications/ systems provide the methodology used to ensure compliance with the FGE limits and verify that the FGE limits are not exceeded.

Verification that correct data is input and used by WEMS for calculation of FGE is performed during the " WIPP Verify" and " Radioactive Verify" functions described in 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification.

Verification of compliance with FGE restrictions for each individual payload package is performed as part of the waste certification process as described in procedure PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. Verification of calculated payload FGE values are performed by the TCO prior to transport in a TRUPACT II package in accordance with PRO T43 Traffic 528, TRUPACT II Operations.

Pu 239 FGE is obtained using American National Standards Institute/ American Nuclear Society ( ANSI/ ANS)  8.15 1981. The total TRUPACT II Pu 239 FGE error is calculated using the square root of the sum of the squares of twice the individual payload package Pu 239 FGE errors. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 166 6.3.2 Radiation Dose Rates <IP_ADDRESS> Requirements The external radiation dose rates of individual payload packages shall be less than or equal to 200 mrem/ hr at the surface. The external radiation dose rates of the TRUPACT II shall be equal to or less than 200 mrem/ hr at the surface and equal to or less than 10 mrem/ hr at 2 meters.

Internal payload package shielding shall not be used to meet the above requirement, except for POC configurations as shown in the TRAMPAC, Appendices 2.2 through 2.4. Payload packages that meet the above radiation dose rate requirements may be shielded to levels that are ALARA.

NOTE: Any payload package ( except for the POC configurations) that exceeds the 200 mrem/ hr surface reading without shielding shall not be transported.

In addition, S100 and S200 POC payloads shall meet the curie limits in the TRAMPAC, Appendices 2.3 and 2.4, respectively.

Maximum surface, 1 meter and 2 meter dose rates are measured and recorded on the Contamination Dose Information Required for Shipment of TRUPACT II form in accordance with PRO 497 RSP 09.7, TRUPACT II Contamination and Radiation Survey Requirements. The information is transferred to the WEMS system. Payload packages that have neutron contribution are noted on the package label. Surface dose rate must not exceed 200 mrem/ hr and 1 meter ( or 2 meter) dose rate must not exceed 10 mrem/ hr. The document 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, specifies the requirements associated with the TRUPACT II dose rate restrictions. Neutron dose rates of individual payload packages are transmitted to the WWIS using WEMS in accordance with 4 K47 WEM WP1210, WEMS Offsite Shipping Module. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 167 <IP_ADDRESS> Methods of Compliance and Verification The document 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, also requires that the payload package be measured before using lead shielding. This value is recorded on the W/ RT in accordance with 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions, as well as documenting that shielding is being used. The W/ RT is an in process control document that provides objective evidence of radiation monitoring activities associated with the packaging of radioactive waste and radioactive mixed waste.

The TRUPACT II surface is surveyed before shipping, and the highest combined gamma and neutron reading is recorded in WEMS and reported on the PATCD. The PATCD is generated from WEMS and is used by Traffic Management to ensure that the TRUPACT II payload meets all of the requirements of the TRAMPAC, Section 6. TRUPACT II loading procedures ensure that each loaded TRUPACT II is surveyed for radiation dose rates as part of the overall TRUPACT II loading operation and process.

Monitoring/ surveying is performed according to the applicable Radiological Safety Practices procedures and with instruments whose calibration is traceable to a national standard. WEMS, supplemented with 100% verification by the WCO and TCO, provides assurance that the surveyed value meets the TRUPACT II restrictions. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 168 6.4 Chemical Properties Requirements The chemical properties of waste are controlled and restricted so that all payload packages are safe for handling and transport. Chemical constituents in a payload shall not be in a form that could be reactive during transport.

6.4.1 Pyrophoric Materials A pyrophoric ( solid) is defined as:

Any solid material, other than one classed as an explosive, which under normal conditions is likely to cause fires through friction, retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious transportation, handling, or disposal hazard. Included are spontaneously combustible and water reactive materials.

Examples of pyrophoric radionuclides are metallic plutonium and americium. Examples of nonradioactive pyrophorics are organic peroxides, sodium metal, and chlorates.

All waste generating sites administratively control the procurement, distribution, use, and disposal of nonradioactive pyrophoric materials. In general, pyrophoric materials are not permitted in TRU process areas. The quantity of pyrophoric materials that does enter any process is strictly limited and controlled by site safety considerations.

<IP_ADDRESS> Requirements for Control of Pyrophoric Materials Pyrophoric radioactive materials shall be present only in small residual amounts ( less than 1% by weight) in payload packages. Radioactive pyrophorics in concentrations greater than 1% by weight and all nonradioactive pyrophorics are reacted ( or oxidized) and/ or rendered nonreactive prior to placement in the payload package. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 169 <IP_ADDRESS> Methods of Compliance and Verification Compliance is demonstrated by one, or a combination, of the following methods:

  Review of records and database information, which may include knowledge of process   Administrative and procurement controls, and   the appropriate residues repackaging procedures as referenced in the TWCP QAPjP.

The documents 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( V2) and Data Reporting, and associated WGIs provide instructions for excluding all pyrophoric materials from being packaged with the waste by referring to AK characterization. AK documentation verifies that pyrophoric radionuclides are less than 1% by weight in the waste forms. This documentation is contained in an auditable record and summarized in RF/ RMRS 97 018, RFETS TRU Waste Acceptable Knowledge Supplemental Information.

6.4.2 Explosives, Corrosives, and Compressed Gases An explosive is defined as:

Any chemical compound, mixture, or device, the primary or common purpose of which is to function by explosion ( i. e., with substantial instantaneous release of gas and heat).

Examples of explosives are ammunition, dynamite, black powder, detonators, nitroglycerin, urea nitrate, and picric acid.

Corrosives are defined as:

Aqueous materials ( i. e., water based liquids), which have a pH less than or equal to 2, or greater than or equal to 12.5.

The physical form of the waste and waste generating procedures at the sites ensure that the waste is in a nonreactive form. All waste generating sites control the procurement, distribution, use, and disposal of explosives. Most sites have lists of restricted materials that include explosives. Typically, the TRU waste generating and storage sites do not allow explosives in the same facility as TRU waste. In addition, sampling programs for pH of inorganic sludges have shown that the sludges consistently meet the limitation on corrosives. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 170 <IP_ADDRESS> Requirements for Control of Explosives, Corrosives, and Compressed Gases Explosives, corrosives, and compressed gases ( pressurized containers) are prohibited from the payload.

<IP_ADDRESS> Methods of Compliance and Verification Compliance shall be by one, or a combination, of the following methods:

  Visual examination of the waste   Administrative and procurement controls   RTR   Sampling program   Review of records and database information, which may include knowledge of process.

Waste generating processes are assessed for safety hazards such as potential explosion hazards and potential inadvertent production of explosive materials. Documents 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; and any associated WGIs strictly prohibit explosives from the packaged waste.

The Site Transportation Safety Manual prohibits explosives in TRU waste generating areas at RFETS. Traffic Management must be notified before the arrival of any explosives, and Transportation personnel will move and/ or escort any explosives.

The document MAN 071 IWCP, Integrated Work Control Program Manual, describes the process, called the Integrated Safety Management process, used to plan, control, and perform RFETS work. This process includes procedures and instructions on hazard identification and analysis. If potential explosive hazards, among others, are identified, then actions and procedures are planned and executed to control the hazard. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 171 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Specifically, verification of the absence of free liquid, and thus corrosive material, for each payload package is accomplished using the following methods:

1. Documented independent visual examination of the waste contents at the time of packaging per 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( V2) and Data Review; associated WGI( s); and/ or the appropriate Residues repackaging procedures as referenced in the TWCP QAPjP; and/ or 2. Radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP.

Compressed gases ( pressurized containers) are prohibited by waste generating instructions.

Verification of the absence of compressed gases ( pressurized containers) for each payload package is accomplished using the following methods:

1. Documented independent visual examination of waste contents at the time of packaging per 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( V2) and Data Review; associated WGI( s); and/ or the appropriate Residues repackaging procedures as referenced in the TWCP QAPjP; and/ or 2. Radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP.

Compliance for previously packaged transuranic waste is verified by periodic visual examination of a random sample of previously packaged waste performed in accordance with PRO 1358 440 VERP, Glovebox and C Cell Waste Operations; PRO 1471 VE 771, Visual Examination for Confirmation of RTR1; PRO 1608 VECRTR 371, RTR Visual Examination Confirmation, Building 3712; and/ or 4 H80 776 ASRF 007, Visual Examination for Confirmation of RTR3.

1 This procedure is inactive as of November 14, 2003. 2 This procedure is inactive as of August 12, 2003. 3 This procedure is inactive as of November 6, 2001. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 172 6.4.3 Chemical Composition The chemical constituents allowed in a given waste material type ( e. g., concreted inorganic particulate waste) are restricted so that a conservative bounding G value can be established for the gas generation potential in each waste material type.

Compliance with the allowable chemical lists in the TRAMPAC Tables 4 1 through 4 8 ( reproduced here as Table 6 2) has been demonstrated for all chemical lists corresponding to TRUCON Content Codes. The assignment of any content code to a waste material type will also be conservative with respect to G values. For example, if an inorganic solid waste material type contains materials that do not comply with the materials listed in TRAMPAC Table 4 4 ( e. g., solid organics excluding packaging), it shall be classified as Waste Material Type III. 1 ( solid organics), which has twice the bounding G value.

<IP_ADDRESS> Requirements Chemical constituents in a payload shall conform to the allowable chemical lists in Table 6 2. Total quantity of the trace chemicals/ materials ( materials that occur individually in the waste in quantities less than 1 percent [ weight]) not listed as allowed materials for a given waste material type in any payload package is restricted to less than 5 percent ( weight).

<IP_ADDRESS> Methods of Compliance and Verification Compliance shall be by one, or a combination, of the following methods:

  Review of records and database information, which may include knowledge of process   Administrative and procurement controls   Sampling program.

AK ( process knowledge) is the primary basis for compliance and verification to the restrictions associated with chemical properties. AK documentation, in the form of WSRIC process descriptions and Backlog Waste Reassessments, and waste packaging instructions are used to verify compliance with chemical property restrictions. A detailed description of the RFETS AK process and controls used is presented in the TWCP QAPjP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 173 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

Only waste containers with approved TRUCON codes are shipped in the TRUPACT II. In certain cases sampling/ analysis ( i. e., a sampling program) may be used to demonstrate compliance to the allowable chemical lists for an approved TRUCON code. Typically, these situations involve demonstrating that a certain chemical ( water for instance) exists as a trace constituent and does not exceed one weight percent in the waste matrix. In these circumstances, a representative sampling program of a waste stream ( or waste stream lot) is conducted in accordance with a sampling and analysis plan. The results from the sampling program are statistically evaluated to determine the upper 95% confidence limit ( UCL95) for the sample mean. The UCL95 is then compared to the applicable chemical composition limit for a given constituent. If the UCL95 is less than the applicable limit, then, the evaluated chemical constituent is considered to be below the limit in the waste matrix for the waste stream/ waste stream lot. If the UCL95 is greater than the limit, then, the concentration of the evaluated chemical constituent is considered to be potentially above the limit for the waste stream/ waste stream lot.

Content codes approved in the TRUCON document ( DOE/ WIPP 89 004) comply with the chemical composition requirements. Any proposed change in process technology at RFETS for a given content code shall be evaluated for compliance with the chemical lists of Table 6 2. This change shall be evaluated and approved by the TRUPACT II Cognizant Engineer for compliance with existing waste material type restrictions. All changes in the chemical characteristics of the waste shall be recorded, and the date of the new process, description of the process, and list of new chemicals submitted to the TRUPACT II Cognizant Engineer as described in Section 6.1.5. The WCO verifies that the assigned content code for a payload package to be shipped off site is listed in the TRUCON document during certification of the payload package as described in PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 174 6.4.4 Chemical Compatibility The allowable chemical/ materials listed in Table 6 2 restrict the chemical composition of the TRUPACT II payload. The basis for evaluating chemical compatibility is contained in the EPA document " A Method for Determining the Compatibility of Hazardous Wastes" ( EPA 600/ 2 80 076). This method provides a systematic means of analyzing the chemical compatibility for specific combinations of chemical compounds and materials. Any incompatibilities between the payload and the packaging shall be evaluated separately if not covered by the EPA method. As described in the TRUPACT II SAR, Appendix 2.10.12, the EPA method classifies individual chemical compounds into chemical groups and identifies the potential adverse reactions resulting from incompatible combinations of the groups.

<IP_ADDRESS> Requirements Chemical compatibility shall be ensured for the following four conditions:

  Chemical compatibility of the waste form within each individual payload package.

  Chemical compatibility between contents of payload packages during hypothetical accident conditions.

  Chemical compatibility of the waste forms with the TRUPACT II Inner Containment Vessel ( ICV).

  Chemical compatibility of the waste forms with the TRUPACT II O ring seals.

<IP_ADDRESS> Methods of Compliance and Verification Compatibility of all waste material types has been demonstrated for transport in the TRUPACT II using the chemicals listed in Table 6 2. The restrictions imposed on the chemical constituents of the content codes ensure compliance with the compatibility requirements. Only RFETS content codes approved in the TRUCON document ( DOE/ WIPP 89 004) are shipped. The WCO verifies that the assigned content code for a payload package to be shipped off site is listed in the TRUCON document during certification of the payload package as described in PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. The WCO also verifies that no chemicals or materials are incompatible and only wastes that meet the approved TRUPACT II chemical lists, Table 6 2, are in the package. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 175 6.5 Gas Generation Requirements Gas generation, concentrations, and pressures during transport of CH TRU wastes in a TRUPACT II payload are restricted as follows:

  For any package containing water and/ or organic substances that could radiolytically generate combustible gases, determination must be made by tests and measurements or by analysis of a representative package such that the following criterion is met over a period of time that is twice the expected shipment time: The hydrogen generated must be limited to a molar quantity that would be no more than 5 percent by volume of the innermost layer of confinement ( or equivalent limits for other inflammable gases) if present at standard temperature and pressure ( STP) ( i. e., no more than 0.063 gram moles/ cubic foot at 14.7 pounds per square inch absolute and 32oF).

  The gases generated in the payload and released into the ICV cavity shall be controlled to maintain the pressure within the TRUPACT II ICV cavity below the acceptable design pressure of 50 pounds per square inch gauge ( psig).

The analysis presented in the TRUPACT II SAR, Section <IP_ADDRESS>, shows that all payloads authorized for transport in the TRUPACT II will comply with the design pressure limit for both twice the expected shipping period and a one year period.

Specific requirements associated with the restrictions on gas generation during transport of a TRUPACT II payload are described in detail below.

6.5.1 Payload Shipping Category The CH TRU waste at the DOE sites has been classified into " payload shipping categories" to evaluate and ensure compliance with the gas generation requirements.

Shipping Category Definition A shipping category is defined by the following parameters:

  Chemical composition of the waste ( waste type)

  Gas generation potential of the waste material type ( quantified by the " G value" for hydrogen, which is the number of molecules of hydrogen generated per 100 electron volts of energy absorbed)

  Gas release resistance ( type of payload package and type and maximum number of confinement layers used). TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 176 6.5.1 Payload Shipping Category ( continued)

For any given payload package, the shipping category provides a basis to determine the gas generation potential of the contents and the resistance to gas release of the packaging configuration. This enables evaluation of compliance with the gas generation requirements. Two payload shipping category notations are available. Either notation may be used by a shipping site. Descriptions of the two notations are presented below.

Numeric Shipping Category Notation The numeric shipping category notation ( initiated in Revision 17 of the TRUPACT II SAR) is a ten digit code:

XX YYYY ZZZZ where,

XX = The waste type, which indicates the chemical composition of the waste YYYY = The G value, or gas generation potential, of the waste material type multiplied by 102 ZZZZ = The resistance to hydrogen release of the packaging configuration multiplied by 10  4.

A description of each of the parameters follows.

Waste Type Payloads for the TRUPACT II package are subdivided into four ( 4) waste types based on physical and chemical form as shown in Table 6 3. Table 6 3 also shows the shipping category notation denoting each waste type. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 177 6.5.1 Payload Shipping Category ( continued)

Waste Material Type ( G Value)

The four waste types can be further subdivided into waste material types. The waste material types define the gas generation potential of the waste, and a listing of the chemicals/ materials allowed in each waste material type is presented in Table 6 2. An effective bounding G value quantifying the gas generation potential of each waste material type is assigned based on the chemicals allowed. The determination of bounding G values for each waste material type is shown in the TRAMPAC, Appendices 5.1 and 5.2. Table 6 4 presents the waste material types and their respective bounding G values, along with the shipping category notation denoting the bounding G value.

Total Resistance The determination of the total resistance to gas release of a payload package requires a knowledge of the type and maximum number of layers of confinement used to package the waste. CH TRU materials are typically placed in a payload package within multiple layers of plastic and/ or metal cans that act as layers of confinement for radionuclides during waste handling operations. The payload safety analysis considers the layers of confinement as barriers that impede, but do not preclude, the release of gases from inside the layers of confinement ( e. g., plastic bags or metal cans) to the outside of the payload package. Allowable closure methods for confinement layers are specified in the TRAMPAC, Appendix 5.3. The plastic layers of confinement in payload packages are of three types   liner bags, inner bags, and filtered bags. As described in the TRAMPAC, Appendices 2.5 and 2.6, the release rates for these three types of bags have been quantified or presented as specifications. Any other type of confinement layer ( other than the three types of plastic bags or metal cans with filters) used at RFETS shall be shown to be equivalent to one of these for purposes of minimum hydrogen release. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 178 6.5.1 Payload Shipping Category ( continued)

The numeric shipping category notation used to denote the total resistance to hydrogen release of the packaging configuration of a payload package is the sum of the resistances from all confinement layers ( seconds/ mole) multiplied by 10 4, rounded up, and reported as four digits ( ZZZZ). For example, the shipping category notation for a total resistance of 1,395,163 seconds/ mole is " 0140." The shipping category assignment for a 55 gallon drum containing solid inorganic waste packaged within two filtered, plastic liner bag layers is:

20 0170 0140 Where,

20 = Waste Type II 0170 = G value ( 1.7) of Waste Material Type II. 1 ( x 102)

0140 = Total resistance to hydrogen release ( x 10 4) of two filtered liner bags.

Alphanumeric Shipping Category Notation The alphanumeric shipping category notation ( used through Revision 16 of the TRUPACT II SAR) was based on the same parameters as the numeric notation ( initiated in Revision 17 of the TRUPACT II SAR), but conveyed the information through a different set of notations. The alphanumeric shipping category notation is based on the waste material type, the payload package type, and the type and number of confinement layers within a payload package. An example of the alphanumeric shipping category notation is:

II. 1A2af Where,

II. 1 = The Waste Material Type ( solid inorganics in plastic bags, see Table 6 4)

A = The type of payload package ( 55 gallon drum, see Table 6 5)

2 = The number of confinement layers ( 2 bag layers, see Table 6 6)

af = The type of confinement layers ( filter drum liner bags, see Table 6 6) TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 179 <IP_ADDRESS> Requirements Payload Package Shipping Category Notation Each payload package shall be assigned to an approved payload shipping category, and each payload shipping category shall have information on the following components:

  Waste type, which shall match the content code description from the TRUCON   Waste material type, which defines the gas generation potential and shall match the content code description from the TRUCON   Total resistance to gas release by the packaging confinement layers. Total resistance has specific requirements associated with:

Confinement Layers: The inner layers of confinement around the waste materials in the payload packages shall be plastic bags and/ or metal cans that meet the specifications outlined in the TRAMPAC, Appendix 5.3. Any other type of confinement layers used at the sites shall be shown, by testing or analysis, to be equivalent to one of the approved confinement layers described in the TRAMPAC, Appendix 5.3. " Equivalency" shall be established by demonstration of a hydrogen release rate greater than or equal to that of the approved confinement layers. For waste within a given content code, the maximum number of layers of confinement shall comply with that specified in the TRUCON.

Rigid Liners: The rigid liner, if present, in a payload package shall be punctured by a   0.3 inch diameter hole, or fitted with an equivalent filter vent as specified in the TRAMPAC, Appendix 2.1. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 180 <IP_ADDRESS> Requirements ( continued)

Each payload package shall have an assigned shipping category that is included in an approved content code in the TRUCON document. Table 2 of the TRUCON document lists all approved content codes and the corresponding assigned shipping categories.

NOTE: As described in Section <IP_ADDRESS>.1, the payload shipping category notation for waste material type, which denotes effective gas generation potential, is replaced with the notation for dose dependent gas generation potential specified in Table 6 4 when the payload package meets the watt* year criteria ( Waste Material Type II. 1 [ 20] and Waste Type III [ 30] only) of > 0.012.

Complete descriptions of all content codes listed are categorized in the TRUCON document.

Payload Assembly Shipping Category Notation A payload assembly may be made up of payload packages with the same, equivalent, or different ( nonequivalent) shipping categories.

If individual payload packages each assigned the same shipping category are assembled into a single payload, each payload package is limited to the same decay heat limit or gas generation rate limit.

For payload shipping categories to be considered equivalent, the payload packages must be described by the same waste type, but may be described by different waste material types and/ or have different gas release resistance factors, provided that the decay heat or the hydrogen gas generation rate for each payload package is bound by the lowest decay heat limit or hydrogen gas generation rate limit of all payload packages in the assembly. These payload packages are then considered to have shipping categories equivalent to the shipping category of the package with the lowest decay heat limit or hydrogen gas generation rate limit in the assembly. If individual payload packages each assigned to an equivalent shipping category are assembled into a payload, each payload package is limited to the decay heat limit or gas generation rate limit of the " governing" shipping category. An assembly may also be made up of payload packages with different shipping categories as described in Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 181 <IP_ADDRESS> Methods of Compliance and Verification <IP_ADDRESS>.1 Assignment of Shipping Category to an Individual Payload Package TRUCON Content Codes and Approved Shipping Categories The TRUCON ( DOE/ WIPP 89 004) document catalogs content codes, which describe the authorized contents and compliance methods for waste to be transported in the TRUPACT II. Each content code may be assigned multiple shipping categories to describe the variations in waste form and packaging configurations within the content code. One shipping category is assigned to each payload package.

RFETS uses the WEMS to assign a shipping category listed in the TRUCON document for the appropriate RFETS waste form and packaging configuration for the following:

  Payload packages of Waste Type I ( 10) and Waste Material Types II. 2 and II. 3 ( 20)

  Payload packages of Waste Material Type II. 1 ( 20) and Waste Type III ( 30) that do not meet the criteria used to apply dose dependent G values ( watt* year   0.012).

The shipping categories listed in the TRUCON document reflect the application of the effective G value. As defined in the TRAMPAC, payload packages of Waste Material Type II. 1 ( 20) and Waste Type III ( 30) that meet the watt* year criteria shall be assigned a shipping category that uses a dose dependent G value. Table 6 4 provides the dose dependent G values and the four digit notations to be used as the " YYYY" portion of the numeric shipping category for qualifying packages of these Waste Types.

Based on data entered into the WEMS for actual watt loading and age of the payload package, RFETS uses the e TRAMPAC system in WWIS to assign a shipping category that reflects the application of a dose dependent G value for the following:

  Payload packages of Waste Material Type II. 1 ( 20) and Waste Type III ( 30) that meet the criteria for the application of dose dependent G values ( watt* year > 0.012). TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 182 <IP_ADDRESS>.1 Assignment of Shipping Category to an Individual Payload Package ( continued)

Table 6 7 lists the RFETS content codes, correlating item description codes ( IDCs), associated shipping categories as assigned in the TRUCON document ( with effective G value) and, as applicable, associated shipping categories assigned with dosedependent G values, and the applicable decay heat limits for each shipping category.

Waste packaging procedures 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, provide instructions and requirements for the packaging of solid transuranic waste. These procedures require waste to be segregated by physical form as identified by IDCs and require specific WGIs be prepared prior to generation and packaging of transuranic waste. Among other things, the WGIs specify the IDC, the packaging configuration to be used to package waste at the point of generation, and the associated content code to which the waste is being packaged to comply.

Verification of the IDC in a payload package is accomplished using the following methods:

1. Documented independent visual examination of the waste contents at the time of packaging per 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; PRO 1031 WIPP 1112, TRU/ TRM Waste Visual Verification ( V2) and Data Review; associated WGI( s); and/ or the appropriate Residues repackaging procedures as referenced in the TWCP QAPjP; and/ or 2. Radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP.

For previously packaged waste ( i. e., transuranic waste generated prior to WGI implementation), the associated TRUCON content code is assigned to a payload package using the TRUCON document ( DOE/ WIPP 89 004) and information about its packaging configuration and the IDC of the package contents are entered during the " WIPP Verify" function described in procedure 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 183 <IP_ADDRESS>.1 Assignment of Shipping Category to an Individual Payload Package ( continued)

The WCO verifies that the assigned content code for a payload package to be shipped off site is listed in the TRUCON document during certification of the payload package as described in PRO X05 WC 4018, Transuranic ( TRU) Waste Certification. Based upon its assigned content code, the filter model installed into the payload package, its watt loading, and age, WEMS then assigns a shipping category to each payload package.

The shipping category information is recorded in Appendix 7 or 8, as applicable.

Verification of Shipping Category Verification of the shipping category is performed by looking up the authorized shipping category for the appropriate content code of the payload package in the TRUCON document. For Waste Material Type II. 1 ( 20) and Waste Type III ( 30), determine if payload package meets the watt* year criteria of > 0.012. If payload packages of Waste Material Type II. 1 ( 20) or Waste Type III ( 30) meet watt* year > 0.012, look up the numeric shipping category notation for dose dependent G value in Table 6 7. The Numeric Payload Shipping Category Worksheet ( Appendix 5) may be completed as part of verifying the payload package shipping category. Instructions for completing the worksheet are located in the TRAMPAC, Appendix 5.4. Record the shipping category information on the PCTCD or OPCTCD, as appropriate.

Addition of New Shipping Categories Any proposed change in payload packaging configuration resulting in a new payload shipping category for a given content code shall be submitted to the TRUPACT II Cognizant Engineer for evaluation. The procedure for submitting requests to the Cognizant Engineer, in compliance with the TRAMPAC requirements, is described in Section 6.1.5 of this document. RFETS may begin using the new shipping category upon written notification of approval from the Cognizant Engineer. Transport of the waste may also be allowed under a more conservative approved shipping category for the content code ( listed in the TRUCON document) if the waste material criteria and the packaging restriction of both the content code and shipping category are met. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 184 <IP_ADDRESS>.2 Assignment of Shipping Category to a Payload Assembly The assignment of a shipping category for payload assemblies comprised of payload packages with same or equivalent shipping categories is described in Section <IP_ADDRESS> of this document. RFETS mixing of different shipping categories within a payload assembly is described in Section <IP_ADDRESS> of this document.

<IP_ADDRESS>.3 Compliance With Specific Requirements for Total Resistance The following paragraphs outline the methods of compliance and verification for confinement layers and rigid liners.

Confinement Layers RTR, visual examination, administrative and procedural controls, or a combination of these methods are used to demonstrate that the method of closure for each layer of confinement is in accordance with the TRAMPAC, Appendix 5.3. Any other type of confinement layers used at RFETS shall be shown, by testing or analysis, to be equivalent to one of the approved confinement layers described in the TRAMPAC, Appendix 5.3. If necessary, RFETS shall establish " equivalency" by demonstration of a hydrogen release rate greater than or equal to that of the approved confinement layers. The waste generation procedures specify the maximum number of confinement layers for each content code. For previously packaged waste, the maximum number of layers is determined from the waste management practices in use at the time the waste was packaged and available records and database information. This is confirmed as part of a sampling program.

Waste packaging procedures 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging, and 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, provide instructions and requirements for the packaging of solid transuranic waste. These procedures specify waste packaging requirements and require specific WGIs be prepared prior to generation and packaging of transuranic waste. Among other things, the WGIs specify the packaging configuration to be used to package waste at the point of generation and the restrictions on the layers of confinement as specified in the TRUCON document. The WGIs and waste packaging procedures include instructions to ensure that packaging of line and non line generated waste to be transported in the TRUPACT II complies with the descriptions in Table 6 7. Additionally, 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, specifies the allowable method of closure for bags in payload packages. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 185 <IP_ADDRESS>.3 Compliance With Specific Requirements for Total Resistance ( continued)

For previously packaged waste ( i. e., TRU waste generated prior to WGI implementation), the maximum number of layers of confinement ( bags) is known from the waste management techniques in use at the time the waste is packaged. For instance, standard operating practice has always involved double bagging ( i. e., two layers of confinement) any waste items to be removed from a glove box. If a payload waste package was not attached to the glovebox proper, then these doublebagged waste items would be place into a drum that could have contained one or two drum liner bags, depending on the waste management practices in use at the time the waste was generated. Therefore, based on this historical practice, the maximum number of layers of confinement of this waste material would be four ( up to two possible waste item layers and up to two drum liner bags).

Compliance with the restrictions on inner confinement layers is verified by periodic visual examination of a random sample of previously packaged waste in accordance with PRO 1358 440 VERP, Glovebox and C Cell Waste Operations; PRO 1471 VE 771, Visual Examination for Confirmation of RTR1; PRO 1608 VECRTR 371, RTR Visual Examination Confirmation, Building 3712; and/ or 4 H80 776 ASRF 007, Visual Examination for Confirmation of RTR3. Radiography of the waste contents performed in accordance with procedures referenced in the TWCP QAPjP, is used to verify the restrictions for liner bag confinement layers.

Rigid Liner The requirements for the rigid liner shall be met by procurement controls and site QA procedures. Venting of the lid of a liner for newly generated waste shall be controlled administratively ( i. e., buying only punctured liners) or by visual examination of the liner prior to closure. For retrievably stored waste, RTR or sampling programs and existing records shall be used to verify that the liner meets the requirements.

1 This procedure is inactive as of November 14, 2003. 2 This procedure is inactive as of August 12, 2003. 3 This procedure is inactive as of November 6, 2001. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 186 <IP_ADDRESS>.3 Compliance With Specific Requirements for Total Resistance ( continued)

Approved rigid liners for TRU waste drums are specified in 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual, and associated WGIs as either a vented Type III rigid liner, or Type IV rigid liner. Type IV rigid liners may be procured and received from the vendor with puncture holes. Type III rigid liners typically are not received with puncture holes from the vendor. Procedures 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; and associated WGIs require waste generators to ensure that the rigid liner lid is punctured prior to use in packaging waste. The use of a punctured rigid liner for a given drum is documented on the associated drum's W/ RT, in accordance with 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions.

RTR of drums performed in accordance with procedures referenced in the TWCP QAPjP is used to identify/ verify the presence of a rigid liner. Venting and/ or verification of venting of potential unvented rigid liner lids is accomplished during headspace gas sampling performed in accordance with procedures referenced in the TWCP QAPjP.

TRU waste that was previously supercompacted was packaged inside of a Type V rigid liner. The Type V rigid liner, like the Type IV, was typically procured and received from the vendor with a puncture hole. The use of a punctured Type V rigid liner for supercompacted waste drums is documented on each applicable drum W/ RT.

For legacy waste, puncturing of unvented rigid liners is accomplished in compliance with the venting and aspiration requirements as described in Subsection 6.5.3.

Verification that rigid liners are punctured or vented is accomplished visually through in process inspections ( PRO 1045 WI 001, Solid Radioactive Waste Inspection) or waste characterization headspace gas sampling activities conducted in accordance with the TWCP QAPjP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 187 <IP_ADDRESS>.4 Alphanumeric Shipping Category Notation For the alphanumeric shipping category notation ( used through Revision 16 of the TRUPACT II SAR), verification of the shipping category requirements shall be by comparison of the shipping category for the payload package with the allowable shipping categories from the information in the TRUCON. This is performed as part of the WEMS WIPP Verification function in accordance with procedure 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification. The shipping category information is also recorded in Appendix 7 or 8, as applicable.

6.5.2 Compliance With Flammable ( Gas/ VOC) Concentration Limits TRU wastes to be transported in the TRUPACT II are restricted so that no flammable mixtures can occur in any layer of confinement during shipment. While the predominant flammable gas of concern is hydrogen, the presence of methane and flammable VOCs is also limited along with hydrogen to ensure the absence of flammable ( gas/ VOC) mixtures in TRU waste payloads.

Payload packages to be transported in the TRUPACT II can be classified into one of two categories based on compliance with the flammable ( gas/ VOC) limits:

  Analytical Category  Under the analytical category, a conservative analysis is used to impose decay heat limits on individual payload packages to ensure that flammable ( gas/ VOC) limits are met. Specifically, flammable VOCs are restricted to less than or equal to 500 parts per million ( ppm) in the payload package headspace ( to ensure that their contribution to flammability is negligible), and a bounding G value is used to conservatively estimate the potential for flammable gas generation due to radiolysis. This G value accounts for both hydrogen and methane gas generation potential based on the waste type. The 5% limit on hydrogen concentration is then met by imposing a decay heat limit that restricts the amount of radioactive material that can be present in the payload package. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 188 6.5.2 Compliance With Flammable ( Gas/ VOC) Concentration Limits ( continued)

  Test Category  Payload packages that do not meet the analytical category limits are classified as test category. Under the test category, one of two options is used for determining compliance with flammable ( gas/ VOC) limits: ( 1) Measurement of the headspace of payload packages for flammable ( gas/ VOC) concentrations and determination of the potential flammability of the ( gas/ VOC) mixture in the innermost layer of confinement during transportation, and ( 2) Full Drum Testing to determine compliance with flammable ( gas/ VOC) limits for individual payload packages.

VOC absorbing or adsorbing material ( such as granular activated carbon to adsorb carbon tetrachloride) may be placed in a payload package provided that RFETS personnel can verify or demonstrate the following through testing, analysis, or AK:

1. The absorbent/ adsorbent remains effective in retaining VOCs from the time of waste packaging through the end of the maximum shipping period in the TRUPACT II, and 2. A flammable mixture of gases does not exist in the innermost layer of confinement, and 3. The total concentration of potentially flammable VOCs does not exceed 500 ppm in the headspace of a payload package.

Only payload packages that meet the flammable ( gas/ VOC) limits based on these determinations are eligible for shipment in the TRUPACT II. Implementation of compliance methods under the analytical and test categories is described in the following subsections and is summarized in Figure 6 1. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 189 6.5.2 Compliance With Flammable ( Gas/ VOC) Concentration Limits ( continued)

Figure 6 1 presents a logic flow diagram for performing the compliance evaluation for flammable ( gas/ VOC) limits. Figures 5 1 through 5 5 of the TRAMPAC provides expanded logic and detailed descriptions of each step of this compliance. The compliance evaluation by analysis requires data associated with the payload package, which is gathered from one or more of the methods of payload compliance listed in Section 6.1.4 of this document.

NOTE: The e TRAMPAC system in the WWIS will verify compliance with flammable ( gas/ VOC) concentration limits. RFETS will ship only payloads that comply with the flammable ( gas/ VOC) limits as ensured by the e TRAMPAC system in the WWIS.

The evaluation of compliance with flammable ( gas/ VOC) concentration limits under either the analytical category or the test category requires the determination of the flammable VOC concentration. A list of flammable VOCs is provided in Table 6 10.

As applicable, RFETS determines the flammable VOC concentration through AK, which may include results from previous headspace gas sampling data. If a payload package headspace concentration of flammable VOCs cannot be established to be   500 ppm based on the payload package AK data, then the flammable VOC concentration of the payload package headspace must be measured.

Per the requirements of the WIPP WAP, a statistical sample or 100% of all payload packages in each waste stream must be headspace gas sampled and analyzed for VOCs, which includes most of the flammable VOCs listed in Table 6 10. Flammable VOCs not included in the WIPP WAP target analyte list will be detected as tentatively identified compounds ( TICs) as part of the headspace VOC analysis, or will be added to the target analyte list and analyzed as target analytes. Headspace gas sampling and analysis is performed in accordance with PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System; L 4231, Headspace Gas Sampling and Analysis Using an Automated Manifold1; L 4146, Headspace Gas Sampling of Waste Containers2; and L 4111, GC/ MS Determination of Volatile Organics Waste Characterization2.

1 This procedure has been cancelled as of June 18, 2003, superseded by PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System. 2 These procedures are inactive as of October 22, 2002. Headspace gas sampling with SUMMA

canisters has been discontinued at RFETS. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 190 <IP_ADDRESS> Determination of Flammable Volatile Organic Compounds Concentration Analysis data are validated and then input into WEMS and the WEMS software sums the results for the flammable VOCs. WEMS software specifications then ensure that any payload package that exceeds 500 ppm flammable VOCs in the headspace is identified as test category waste as described in procedure 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification.

If a payload package headspace concentration of flammable VOCs can be established to be   500 ppm, then compliance with the flammable ( gas/ VOC) limits is determined under the analytical category as described in Section <IP_ADDRESS>.

The TRAMPAC, Appendix 5.6, specifies drum age criteria ( DAC) ( i. e., minimum number of days) for the measurement of headspace flammable VOCs. If the payload package meets the DAC for the applicable packaging configuration, the measured headspace flammable VOC concentration is evaluated. If the payload package has not yet met the DAC, the 90 percent steady state headspace flammable VOC concentration must be calculated from the measured concentration as described in the TRAMPAC, Appendix 5.6. If the measured headspace flammable VOC concentration or the calculated steady state payload package headspace flammable VOC concentration is less than or equal to 500 ppm, the evaluation of compliance with the flammable ( gas/ VOC) limits is determined under the analytical category as described in Section <IP_ADDRESS>. If the measured or calculated headspace flammable VOC concentration exceeds 500 ppm, the evaluation of compliance with the flammable ( gas/ VOC) limits is determined under the test category as described in Section <IP_ADDRESS>.

The e TRAMPAC system in WWIS applies the appropriate DAC to the headspace flammable VOC concentration measurement, performs any required calculation of the steady state headspace flammable VOC concentration, and identifies any payload package that exceeds the 500 ppm limit.

NOTE: If WIPP WAP requirements pertaining to the DAC are more restrictive than those specified in the TRAMPAC, Appendix 5.6, the application of the DAC will be in accordance with the WIPP WAP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 191 <IP_ADDRESS> Analytical Category Compliance Compliance with the flammable ( gas/ VOC) concentration limits is demonstrated under the analytical category if the payload package meets all of the following conditions:

  The total concentration of potentially flammable VOCs within the payload package headspace is less than or equal to 500 ppm ( as determined in Section <IP_ADDRESS>)

  The payload package is classified as Waste Types I ( 10), II ( 20), or III ( 30).

If the payload package exceeds 500 ppm or is classified as Waste Type IV, compliance with the flammable ( gas/ VOC) concentration limits must be demonstrated under the test category as described in Section <IP_ADDRESS>.

NOTE: The compliance evaluation described in this section assumes that the payload package under consideration is proposed for shipment with payload packages belonging to the same or an equivalent shipping category. If the payload package is proposed for shipment in a payload assembly comprised of payload packages of different shipping categories and/ or dunnage packages, compliance is evaluated as described in Section <IP_ADDRESS>.

If the payload package is proposed for shipment in a payload assembly comprised of payload packages of the same or equivalent shipping category, RFETS evaluates compliance with the analytical decay heat limit. An analytical decay heat limit is established for each payload shipping category such that the hydrogen generated during twice the expected shipping time results in a molar quantity of not more than 5% by volume in any layer of confinement in the payload package. The analytical decay heat limit for Rocky Flats approved shipping categories listed in the TRUCON document are specified in Table 6 7. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 192 <IP_ADDRESS> Analytical Category Compliance ( continued)

The TRUCON document only specifies shipping categories and decay heat limits for overpack configurations in which 55 gallon drums are overpacked into an SWB fitted with two filters. The assignment of shipping categories and decay heat limits for other overpacked payload configurations are determined based on information presented in the TRUPACT II SAR Appendix 3.6.13 as follows:

  Ten 55 gallon drums overpacked in a TDOP is equivalent to 14 55 gallon drums in a TRUPACT II. Therefore, the shipping category and decay heat limit for a 55 gallon drum overpacked in a TDOP is the same as a non overpacked 55 gallon drum listed in the TRUCON document. For example: if the shipping category for a 55 gallon drum of TRUCON code RF116A waste is 3003400041, then, this shipping category ( 3003400041) would also be the shipping category for each of 10 55 gallon drums of TRUCON code RF116A waste overpacked in a TDOP.

  Eight 55 gallon drums overpacked in two SWBs with four filters in each SWB is equivalent to 14 55 gallon drums in a TRUPACT II. Therefore, the shipping category and decay heat limit for a 55 gallon drum overpacked in an SWB fitted with four filters is the same as a non overpacked 55 gallon drum listed in the TRUCON document. For example: if the shipping category for a 55 gallon drum of TRUCON code RF116A waste is 3003400041, then, this shipping category ( 3003400041) would also be the shipping category for each of 4 55 gallon drums of TRUCON code RF116A waste overpacked in a SWB equipped with 4 filters.

  Four 55 gallon drums overpacked in an SWB, overpacked in a TDOP is equivalent to eight 55 gallon drums overpacked in two SWBs with two filters each in a TRUPACT II. Therefore, the shipping category and decay heat limit for a 55 gallon drum overpacked in a SWB, overpacked in a TDOP, is the same as a 55 gallon drum that is overpacked in a SWB with two filters ( i. e., SWB Overpack) listed in the TRUCON document. For example: if the shipping category for an SWB Overpack ( i. e., 55 gallon drums overpacked in an SWB) of TRUCON code RF116A waste is 3003400215, then, this shipping category ( 3003400215) would also be the shipping category for each of 4 55 gallon drums of TRUCON code RF116A waste overpacked in a SWB, overpacked in a TDOP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 193 <IP_ADDRESS> Analytical Category Compliance ( continued)

  One SWB overpacked in a TDOP is equivalent to two SWBs in a TRUPACT II. Therefore, the shipping category and decay heat limit for an SWB overpacked in a TDOP is the same as a non overpacked SWB listed in the TRUCON document. For example: if the shipping category for an SWB of TRUCON code RF117A waste is 2001700041, then, this shipping category ( 2001700041) would also be the shipping category for an SWB of TRUCON code RF117A waste overpacked in a TDOP.

  Six 55 gallon drums in six 85 gallon drums, overpacked in a TDOP, is equivalent to eight 55 gallon drums overpacked in two SWBs with two filters each in a TRUPACT II. Therefore, the shipping category and decay heat limit for a 55 gallon drum overpacked in an 85 gallon drum, overpacked in a TDOP, is the same as a 55 gallon drum that is overpacked in a SWB with two filters ( i. e., SWB Overpack) listed in the TRUCON document. For example: if the shipping category for an SWB Overpack ( i. e., 55 gallon drums overpacked in an SWB) of TRUCON code RF116A waste is 3003400215, then, this shipping category ( 3003400215) would also be the shipping category for each of six 55 gallon drums of TRUCON code RF116A waste overpacked in an 85 gallon drum, overpacked in a TDOP.

The decay heat within each payload package plus the measurement error shall be less than or equal to the decay heat limit shown in Table 6 7 for each authorized payload shipping category.

NOTE: If the payload package meets the watt* year criteria of > 0.012, the shipping category reflecting the dose dependent G value and the associated decay heat limit applies.

The decay heat limit for an authorized shipping category associated with an SWB overpack configuration ( i. e., drums overpacked in SWBs) applies to each overpacked drum within the SWB and not the entire SWB itself. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 194 <IP_ADDRESS> Analytical Category Compliance ( continued)

The total decay heat from all payload packages in a TRUPACT II shall be less than or equal to 40 watts.

NOTE: Decay heat error refers to standard error ( i. e., decay heat error at one standard deviation = 1 sigma).

WEMS and associated software specifications define the methods and controls that WEMS uses to calculate the decay heat for each payload package. The e TRAMPAC software system in the WWIS also calculates decay heat for each payload package and verifies compliance with decay heat restrictions prior to WWIS approval. Furthermore, the e TRAMPAC system provides the methods and controls used for calculation of decay heat for assembled TRUPACT II payloads. These software specifications/ systems provide the methodology used to ensure compliance with the decay heat limits in Table 6 7 and verify that the decay heat limits are not exceeded.

Verification that correct data is input and used by WEMS for calculation of decay heats is performed during the " WIPP Verify" and " Radioactive Verify" functions described in 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification.

Verification of compliance with decay heat restrictions for each individual payload package is performed as part of the waste certification process as described in PROX05 WC 4018, Transuranic ( TRU) Waste Certification. Verification of calculated payload decay heat values are performed by the TCO prior to transport in a TRUPACT II package in accordance with PRO T43 Traffic 528, TRUPACT II Operations.

Compliance with the above criteria is shown by ensuring that the waste is listed in the TRUCON document, and that the restrictions associated with the shipping category assignment are met. Section 6.5.1 of this document describes procedures and methods for meeting shipping category criteria. If the payload package meets the analytical decay heat limit, compliance with the flammable ( gas/ VOC) limits is ensured. If the payload package exceeds the analytical decay heat limit, compliance with the flammable ( gas/ VOC) concentration limits may be demonstrated through mixing the package in a payload assembly of different shipping categories as described in Section <IP_ADDRESS> or by measurement/ test as described in Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 195 <IP_ADDRESS> Test Category Compliance Compliance with the flammable ( gas/ VOC) concentration limits is demonstrated under the test category if the payload package meets one or more of the following conditions:

  The total concentration of potentially flammable VOCs within the payload package headspace exceeds 500 ppm. Waste Types I ( 10), II ( 20), and III ( 30) belong in this category.

  The decay heat loading of the payload package exceeds the analytical limit for the shipping category of that payload package. Waste Types I ( 10), II ( 20), and III ( 30) belong in this category.

  A waste form does not have a fully characterized bounding G value from previous sampling or waste stream analysis. Waste Type IV ( 40) belongs to this category.

The packages classified as test category waste shall meet all other restrictions of this document, including the 40 watt limit on total decay heat from all payload packages in a TRUPACT II.

RFETS qualifies test category payload packages for shipment by the following methods:

  Measurement   Full Drum Testing.

NOTE: The compliance evaluation described in this section assumes that the payload package under consideration is proposed for shipment with payload packages belonging to the same or an equivalent shipping category. If the payload package is proposed for shipment in a payload assembly comprised of payload packages of different shipping categories and/ or dunnage packages, compliance is evaluated as described in Section <IP_ADDRESS>. However, the data obtained from the performance of measurement or testing may be used in the compliance demonstration described in Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 196 <IP_ADDRESS>.1 Measurement If the payload package exceeds the analytical decay heat limit and/ or its headspace flammable VOC concentration exceeds 500 ppm, the compliance evaluation for flammable ( gas/ VOC) limits may be based on measurement of the headspace gas. This method is applicable only to Waste Types I ( 10), II ( 20), and III ( 30).

NOTE: Full drum testing ( Section <IP_ADDRESS>.2) may be implemented instead of measurement to qualify test category waste for shipment.

RFETS performs headspace gas measurements in accordance with L 4146, Headspace Gas Sampling of Waste Containers1; L 4231, Headspace Gas Sampling and Analysis Using an Automated Manifold2; PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System; and L 4111, GC/ MS Determination of Volatile Organics Waste Characterization1. For overpacked payload packages, measurement of the payload package headspace is performed prior to the overpacking. For all payload packages, flammable ( gas/ VOC) concentrations may be conservatively measured in an inner layer of confinement rather than the payload package headspace.

The concentration of methane present in the headspace of the payload package may be estimated in accordance with the Quality Assurance Program Plan for TRUPACT II Gas Generation Test Program ( GGTP QAPP) and RS 020 001, Gas Generation Testing Program Quality Assurance Project Plan ( GGTP QAPjP), or be measured in accordance with PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System; L 4231, Headspace Gas Sampling and Analysis Using an Automated Manifold2; L 4146, Headspace Gas Sampling of Waste Containers1; and L 4111, GC/ MS Determination of Volatile Organics Waste Characterization1. If the payload package headspace methane concentration exceeds 1,250 ppm, the payload package is not eligible for shipment and must be segregated for repackaging, treatment, or other mitigation measures. If the payload package headspace methane concentration is less than or equal to 1,250 ppm, and the payload is to be assembled with payload packages of different shipping categories, compliance shall proceed according to the methodology described in Section <IP_ADDRESS>. Otherwise, the flammable ( gas/ VOC) concentration within the innermost layer of confinement is determined using the measured headspace flammable ( gas/ VOC) concentrations and the time history of the payload package as described in Appendices 5.7 and 5.8 of the TRAMPAC.

1 These procedures are inactive as of October 22, 2002. Headspace gas sampling with SUMMA

canisters has been discontinued at RFETS. 2 This procedure has been cancelled as of June 18, 2003, superseded by PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 197 <IP_ADDRESS>.1 Measurement ( continued)

Using the headspace gas measurement and the time history of the payload package, a mixture lower explosive limit ( MLEL) ( or flammable gas generation rate) is calculated as described in Appendix 5.7 of the TRAMPAC. If the sum of the flammable ( gas/ VOC) concentration in the innermost layer of confinement meets the MLEL, the payload package may be qualified for shipment. If not, the payload package must be subjected to Full Drum Testing as described in Section <IP_ADDRESS>.2.

The WEMS software evaluates the headspace methane concentration measurement and prevents any payload package that exceeds the 1,250 ppm limit from being verified during the " WIPP Verify" function as described in procedure 4 G83 WEMWP 1209, WEMS Waste Package Verification and Certification.

WEMS and associated software specifications define the methods and controls that WEMS uses to calculate the MLEL for each payload package. These software specifications also provide the methodology used by WEMS to ensure compliance with the applicable MLEL and verify that the MLEL is not exceeded. Additionally, all payload packages are processed through the e TRAMPAC software system in WWIS. The e TRAMPAC system also verifies compliance with the applicable MLEL and verifies that the MLEL is not exceeded.

Verification that correct data is input and used by WEMS for calculation of MLEL is performed during the " WIPP Verify" and " Radioactive Verify" functions described in 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification.

<IP_ADDRESS>.2 Full Drum Testing If the payload package exceeds the MLEL ( as described in Section <IP_ADDRESS>.1) or is Waste Type IV ( 40), the compliance evaluation for flammable ( gas/ VOC) limits may be based on the results of full drum testing, which quantifies the gas generation rate of the payload package. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 198 <IP_ADDRESS>.2 Full Drum Testing ( continued)

Prior to full drum testing, the concentration of methane present in the headspace of the payload package must be estimated in accordance with RS 020 001, GGTP QAPjP, or be measured in accordance with PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On line Integrated System; L 4231, Headspace Gas Sampling and Analysis Using an Automated Manifold1; L 4146, Headspace Gas Sampling of Waste Containers2; and L 4111, GC/ MS Determination of Volatile Organics Waste Characterization2. If the payload package headspace methane concentration exceeds 1,250 ppm, the payload package is not eligible for shipment and must be segregated for repackaging, treatment, or other mitigation measures. If the payload package headspace methane concentration is less than or equal to 1,250 ppm, and the payload is to be assembled with payload packages of different shipping categories, compliance shall proceed according to the methodology described in Section <IP_ADDRESS>. Otherwise, the total gas generation rate is determined from fulldrum testing as described in the TRAMPAC, Appendix 5.7.

RFETS performs full drum testing in accordance with RS 020 001, GGTP QAPjP and the criteria specified in Table 6 8. Full drum testing is accomplished under the QA program defined by RS 020 001, GGTP QAPjP, which ensures compliance with the GGTP QAPP. For overpacked payload packages, full drum testing is to be performed prior to the overpacking.

As applicable, if the determined total gas generation rate exceeds the limit for the appropriate shipping category, mitigation measures must be taken or the payload package may be evaluated for compliance within a payload assembly of different shipping categories as described in Section <IP_ADDRESS>. If the determined total gas generation rate is less than or equal to the limit for the appropriate shipping category as specified in Table 6 9, the flammable gas concentration within the innermost layer of confinement must be determined using the data from the testing as described in the TRAMPAC, Appendices 5.7 and 5.8. A specific MLEL ( or flammable gas generation rate) is calculated for the payload package as described in the TRAMPAC, Appendix 5.7. If the sum of the flammable gas and VOC concentrations exceeds the MLEL, the payload package does not comply with flammable ( gas/ VOC) limits. Either mitigation measures must be taken or the payload package may be evaluated for compliance within a payload assembly of different shipping categories as described in Section <IP_ADDRESS>. If the flammable ( gas/ VOC) concentration is less than or equal to the MLEL, the payload package may be qualified for shipment.

1 This procedure has been cancelled as of June 18, 2003, superseded by PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System. 2 These procedures are inactive as of October 22, 2002. Headspace gas sampling with SUMMA

canisters has been discontinued at RFETS. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 199 <IP_ADDRESS>.2 Full Drum Testing ( continued)

The WEMS software evaluates the headspace methane concentration measurement and prevents any payload package that exceeds the 1,250 ppm limit from being verified during the " WIPP Verify" function as described in procedure 4 G83 WEMWP 1209, WEMS Waste Package Verification and Certification.

Pursuant to the TRAMPAC, for applicable shipping categories, total gas generation rate data are input to WEMS. The WEMS software prevents any payload package that exceeds the total gas generation rate limit for the appropriate shipping category from being verified during the " WIPP Verify" function as described in procedure 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification.

WEMS and associated software specifications define the methods and controls that WEMS uses to calculate the MLEL for each payload package. These software specifications also provide the methodology used by WEMS to ensure compliance with the applicable MLEL and verify that the MLEL is not exceeded. Additionally, all payload packages are processed through the e TRAMPAC software system in WWIS. The e TRAMPAC system also verifies compliance with the applicable MLEL and verifies that the MLEL is not exceeded.

Verification that correct data is input and used by WEMS for calculation of MLEL is performed during the " WIPP Verify" and " Radioactive Verify" functions described in 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification.

<IP_ADDRESS> Mixing of Shipping Categories in a Payload Assembly In accordance with Appendix 6.3 of the TRAMPAC, an assembly may be made up of payload packages with different shipping categories by ensuring that each payload package does not contain a flammable mixture of gases. The flammability index ( FI) is assessed for each payload package, which accounts for the properties of each of the other packages in the assembly. Section <IP_ADDRESS> describes the procedure for qualifying an assembly of payload packages with different shipping categories. Unlimited mixing of shipping categories within a single payload package type is allowed for direct loaded payload configurations, with the FIs calculated based on each payload package in the assembly.

For payload assemblies comprised of overpacked payload configurations, mixing of shipping categories is allowed provided that all payload packages being overpacked meet the lowest decay heat limit or lowest hydrogen gas generation rate limit (" governing limit") of all the payload packages in the payload assembly. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 200 6.5.3 Venting and Aspiration <IP_ADDRESS> Requirements This requirement applies only to unvented payload packages. Payload packages that have been stored in an unvented condition ( i. e., no filter and/ or unpunctured rigid liner) SHALL be aspirated for the specific length of time to ensure equilibration of any gases that may have accumulated in the closed payload package. For payload packages with waste types in packaging configurations that do NOT generate any flammable gas, aspiration is NOT required ( i. e., Waste Material Type II. 2) ( Section 5.9.1 of the TRAMPAC).

<IP_ADDRESS> Methods of Compliance and Verification Three options are available for meeting aspiration requirements as follows:

  Option 1  Aspiration Time Based on Date of Payload Package Closure. Compliance shall be by records and database information. For this option, the steps outlined below shall be implemented to determine the aspiration time for a payload package.

1. The potential shipping category of the payload package shall be known.

2. The duration for which the payload package has been in a closed condition should be computed from a knowledge of the date of closure of the drum. This closure time should be rounded up to the next highest time period listed in the TRAMPAC, Appendix 5.9, Tables 5.9 1 through 5.9 3.

3. The required aspiration time corresponding to this closure time shall then be read from the same table under the column listing the number of layers of confinement associated with the potential shipping category of the payload package.

4. The payload package shall be qualified for shipment only after being aspirated for at least this period of time. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 201 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

  Option 2  Headspace Gas Sampling at the Time of Venting. Compliance shall be by measurement of headspace gas concentrations and records. For this option, the steps outlined below shall be implemented to determine the aspiration time for a payload package.

1. The potential shipping category of the payload package shall be known.

2. At the time of venting, a headspace sample shall be taken from the payload package headspace ( Option 2A) or from the rigid liner headspace ( Option 2B) and analyzed for the hydrogen concentration.

3. The measured headspace concentration of all hydrogen shall be rounded up to the next highest mole percentage listed in the TRAMPAC, Appendix 5.9, Tables 5.9 4 through 5.9 9, determined by Option 2A or 2B, as appropriate.

4. The required aspiration time corresponding to this molar percentage shall then be read from the same table under the column listing the number of layers of confinement associated with the potential shipping category of the payload package.

5. The payload package shall be qualified for shipment only after being aspirated for at least this period of time. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 202 <IP_ADDRESS> Methods of Compliance and Verification ( continued)

  Option 3  Headspace Gas Sampling During Aspiration. Compliance shall be by direct measurement of the headspace gas concentration. For this option, the steps outlined below shall be implemented to determine the aspiration time for a payload package.

1. The potential shipping category of the payload package shall be known.

2. Prior to measuring the hydrogen concentration in the payload package headspace, the drum shall be vented for at least two weeks.

3. The measured headspace concentration of hydrogen shall be rounded up to the next highest mole percentage listed in the TRAMPAC, Appendix 5.9, Tables 5.9 10 through 5.9 12.

4. The required aspiration time corresponding to this molar percentage shall then be read from the same table under the column listing the number of layers of confinement associated with the potential shipping category of the payload package.

5. The payload package shall be qualified for shipment only after being aspirated for this period of time.

Venting and aspiration of unvented payload packages is/ was performed in accordance with procedures PRO 1351 440 SWB, Perma Con Operations; PRO 717 HDGAS 371, Headspace Gas Sampling, Building 3711; or PRO 1141 WP 4701, Waste Characterization Gas Sampling2. Vent/ Puncture dates are entered into WEMS as a start date for determining aspiration time.

Aspiration times are determined in accordance with the applicable aspiration method and are also entered into WEMS per 4 G83 WEM WP 1209, WEMS Waste Package Verification and Certification. WEMS software controls ensure that applicable payload packages aspirate longer than the required aspiration period prior to being certified and shipped.

1 This procedure is inactive as of May 12, 2003. Headspace gas sampling in Building 371 has been discontinued. 2 This procedure is inactive as of October 22, 2002. Headspace gas sampling with SUMMA

canisters has been discontinued at RFETS. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 203 6.6 Payload Assembly Requirements This section presents an overview of the control procedures that shall be used to assemble a payload qualified for transport in the TRUPACT II. The parameters described in previous sections shall be evaluated for selection of a payload. The flowchart of transport requirements for a payload package is shown in Figure 6 2. The container identification ( ID) number shall uniquely identify the payload package. Each payload package shall have an assigned shipping category and content code. Wherever applicable, the measured parameters ( weight, fissile material, and the decay heat) shall be checked against the limits after addition of the measurement error, as detailed in previous sections. If any of the limits are not met by the package, it shall be rejected from transport ( subject to mitigation or repackaging), marked, and segregated.

Assembled payloads shall comply with the authorized payload configurations specified in Section <IP_ADDRESS> of this document. A TRUPACT II payload may be assembled of payload packages belonging to the same shipping category, equivalent shipping categories, or different/ nonequivalent shipping categories ( e. g., payload may consist of several shipping categories and/ or may take credit for void volume provided by dunnage packages). The logic for selecting a payload qualified for transport in the TRUPACT II when all payload packages belong to the same or equivalent shipping category is presented in Figure 6 3. Payload selection shall be made from only those payload packages that have been approved for shipment. A payload comprised of individual payload packages selected from the same or equivalent shipping categories shall meet the requirements for weight, center of gravity, dose rate, fissile quantity limits, and decay heat limits on the total TRUPACT II payload. Payload packages belonging to different/ nonequivalent shipping categories may be assembled in a single payload ( with or without dunnage packages) in accordance with the criteria described in Section <IP_ADDRESS>.

6.6.1 Requirements Once compliance with all transportation parameter requirements is verified and Appendix 7 or Appendix 8 ( and Appendix 9, as applicable) is completed, the TRUPACT II package shall be authorized for shipment by the site TCO by completing and signing the PATCD ( Appendix 6). Shipping records shall be maintained by the shipper for a minimum period of 3 years. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 204 6.6.2 Methods of Compliance and Verification Shipping records are maintained for a minimum period of 3 years in accordance with the applicable Records Inventory Disposition Schedule ( RIDS) and procedure PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center.

NOTE: The text in Sections <IP_ADDRESS> through <IP_ADDRESS> providing instructions for payload packages and assembly qualification is reproduced from the TRAMPAC.

<IP_ADDRESS> Procedure for Certification of Individual Payload Packages ( Analytical Category)