PAGE 1 Rocky Flats Environmental Technology Site 1 MAN 008 WM 001 VERSION 7 TRANSURANIC ( TRU) WASTE MANAGEMENT MANUAL APPROVED BY: G. A. O'Leary / / S/ 2/ 10/ 04 Print Name Date Responsible Organization: TRU Waste Programs Effective Date: 02/ 12/ 2004 Review/ concurrence documentation is contained in the Document History File.

ISR review not required. Exempt from Classification Review SES review not required. Exemption Number: CEX 032 00 This manual supersedes 1 MAN 008 WM 001, Revision 6.

Periodic review frequency: 1 year from the effective date TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 2 APPROVALS The approvals listed below apply to Version 7 of this document.

Approved by:

D. C. Gadbury for Kerry W. Watson / S/ 2/ 10/ 04 CBFO Assistant Manager, Office of National TRU Program Date ( Kerry W. Watson)

Ava L. Holland / S/ 2/ 10/ 04 CBFO Quality Assurance Manager Date ( Ava Holland)

Lam Xuan / S/ 1/ 28/ 04 DOE Rocky Flats Field Office Date ( Lam Xuan)

G. A. O'Leary / S/ 1/ 28/ 04 RFETS TWCP Site Project Manager Date ( G. A. O'Leary)

C. L. Ferrera / S/ 1/ 28/ 04 RFETS TWCP Site Project Quality Assurance Officer Date ( C. L. Ferrera) TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 3 TABLE OF CONTENTS Section Page TITLE PAGE .................................................................................................................. 1 APPROVALS PAGE....................................................................................................... 2 TABLE OF CONTENTS................................................................................................. 3 VERSION CHANGE SUMMARY.................................................................................. 9 1. OVERVIEW ................................................................................................................. 13 1.1 Purpose.............................................................................................................. 14 1.2 TRU Waste Programs ........................................................................................ 14 2. REQUIREMENTS FOR CH TRU WASTE CERTIFICATION AND TRANSPORTATION TO WIPP ................................................................................... 16 2.1 CBFO Requirements Documents ........................................................................ 16 2.2 RFETS Program Documents .............................................................................. 16 2.2.1 Waste Certification Plan....................................................................... 16 2.2.2 Certification QA Plan........................................................................... 17 2.2.3 Quality Assurance Project Plan ( TWCP QAPjP)................................... 17 2.2.4 Graded Approach Procedure................................................................ 17 2.2.5 Sampling Plan...................................................................................... 18 2.2.6 TRAMPAC and Associated QA Plan ................................................... 18 2.2.7 Packaging QA Plan.............................................................................. 18 3.0 CERTIFICATION AND TRAMPAC QUALITY ASSURANCE PROGRAMS............. 24 3.1 Management Requirements................................................................................. 24 3.1.1 Organization & QA Program................................................................ 24 3.1.2 Personnel Training & Qualification....................................................... 49 3.1.3 Quality Improvement ........................................................................... 50 3.1.4 Document Control ............................................................................... 55 3.1.5 Records ............................................................................................... 56 3.2 Performance Requirements ................................................................................. 58 3.2.1 Work Processes ................................................................................... 58 3.2.2 Design Control..................................................................................... 69 3.2.3 Procurement ........................................................................................ 70 3.2.4 Inspection & Testing............................................................................ 75 3.3 Assessment Requirements................................................................................... 81 3.3.1 Management Assessments.................................................................... 81 3.3.2 Independent Assessments..................................................................... 81 3.4 Sample Control Requirements ............................................................................ 84 3.4.1 Sample Control Requirements.............................................................. 84 3.4.2 Sample Identification ........................................................................... 84 3.4.3 Handling, Storage And Shipping Samples............................................. 84 3.4.4 Disposition Of Sample Nonconformance .............................................. 84 3.5 Scientific Investigation Requirements ................................................................. 84 3.6 Software Requirements ...................................................................................... 85 3.6.1 Software Quality Assurance ( SQA)...................................................... 85 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 4 TABLE OF CONTENTS ( continued) Section Page 4.0 RFETS TRU WASTE PACKAGING & CERTIFICATION.......................................... 86 4.1 Characterization Process .................................................................................... 86 4.2 TRU Waste Certification Official ( WCO) ........................................................... 88 4.3 Waste Packaging and Documentation Requirements ........................................... 89 4.3.1 Waste/ Residue Traveler ....................................................................... 89 4.3.2 Waste and Environmental Management System ( WEMS)..................... 91 4.3.4 Backlog Waste Reassessment Baseline Book ( BWRBB) ...................... 93 4.4 Shipment Certification Statements ...................................................................... 94 4.5 RFETS IDCs Certifiable to WIPP Operations and Safety Criteria and TRUPACT II Payload Control Criteria ........................................................ 94 4.6 Packaging QA Program Plan .............................................................................. 96 4.6.1 Organization ........................................................................................ 96 4.6.2 Quality Assurance Program.................................................................. 97 4.6.3 Design Control..................................................................................... 97 4.6.4 Procurement Document Control........................................................... 98 4.6.5 Instructions, Procedures, and Drawings................................................ 99 4.6.6 Document Control ............................................................................. 101 4.6.7 Control of Purchased Material, Equipment, and Services.................... 102 4.6.8 Identification and Control of Materials, Parts, and Components.......... 103 4.6.9 Control of Special Processes .............................................................. 103 4.6.10 Inspection Control ............................................................................. 104 4.6.11 Test Control ...................................................................................... 105 4.6.12 Control of Measuring and Test Equipment ......................................... 105 4.6.13 Handling, Storage, and Shipping ........................................................ 106 4.6.14 Inspection, Test, and Operating Status ............................................... 106 4.6.15 Control of Nonconforming Materials, Parts, or Components .............. 107 4.6.16 Corrective Action .............................................................................. 107 4.6.17 Quality Assurance Records ................................................................ 108 4.6.18 Audits................................................................................................ 109 5.0 RFETS CERTIFICATION TO WIPP WASTE ACCEPTANCE CRITERIA ............... 110 5.1 General ............................................................................................................ 110 5.1.1 DOE Operations and Safety Requirements ......................................... 112 5.1.2 NRC Transportation Safety Requirements for the TRUPACT II ........ 112 5.1.3 NMED Hazardous Waste Facility Permit Requirements ..................... 113 5.1.4 EPA Compliance Certification Decision Requirements ....................... 113 5.1.5 Land Withdrawal Act Requirements................................................... 114 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 5 TABLE OF CONTENTS ( continued) Section Page 5.2 Container Properties......................................................................................... 116 5.2.1 Description ........................................................................................ 116 5.2.2 Weight Limits and Center of Gravity.................................................. 118 5.2.3 Assembly Configurations.................................................................... 119 5.2.4 Removable Surface Contamination..................................................... 119 5.2.5 Identification/ Labeling ....................................................................... 120 5.2.6 Dunnage ............................................................................................ 121 5.2.7 Filter Vents........................................................................................ 121 5.3 Radiological Properties..................................................................................... 122 5.3.1 Radionuclide Composition ................................................................. 122 5.3.2 Pu 239 Fissile Gram Equivalent ......................................................... 123 5.3.3 TRU Alpha Activity Concentration .................................................... 124 5.3.4 Pu 239 Equivalent Activity ................................................................ 125 5.3.5 Radiation Dose Rate .......................................................................... 126 5.3.6 Decay Heat ........................................................................................ 126 5.4 Physical Properties ........................................................................................... 127 5.4.1 Residual Liquids ................................................................................ 127 5.4.2 Sealed Containers .............................................................................. 127 5.5 Chemical Properties.......................................................................................... 128 5.5.1 Pyrophoric Materials.......................................................................... 128 5.5.2 Hazardous Waste............................................................................... 129 5.5.3 Chemical Compatibility ...................................................................... 130 5.5.4 Explosives, Corrosives, and Compressed Gases.................................. 130 5.5.5 Headspace Gas Concentrations .......................................................... 131 5.5.6 Polychlorinated Biphenyls .................................................................. 132 5.6 Data Package Contents..................................................................................... 132 5.6.1 Characterization and Certification Data .............................................. 132 5.6.2 Shipping Data .................................................................................... 133 6.0 TRUPACT II AUTHORIZED METHODS FOR PAYLOAD CONTROL ( TRAMPAC) COMPLIANCE PLAN................................................................................................ 138 6.1 Introduction ..................................................................................................... 138 6.1.1 Scope ................................................................................................ 138 6.1.2 Purpose ............................................................................................. 138 6.1.3 Requirements..................................................................................... 139 6.1.4 Methods of Compliance ..................................................................... 139 6.1.5 TRUCON Document ......................................................................... 141 6.1.6 Compliance Program.......................................................................... 144 6.1.7 Quality Assurance .............................................................................. 144 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 6 TABLE OF CONTENTS ( continued) Section Page 6.2 Container and Physical Properties Requirements............................................... 145 6.2.1 Container Descriptions....................................................................... 145 6.2.2 Dunnage ............................................................................................ 147 6.2.3 Container/ Assembly Weight and Center of Gravity............................. 149 6.2.4 Container Marking............................................................................. 152 6.2.5 Filter Vents........................................................................................ 153 6.2.6 Liquids............................................................................................... 155 6.2.7 Sharp or Heavy Objects ..................................................................... 157 6.2.8 Sealed Containers .............................................................................. 158 6.3 Nuclear Properties Requirements...................................................................... 159 6.3.1 Nuclear Criticality.............................................................................. 161 6.3.2 Radiation Dose Rates......................................................................... 166 6.4 Chemical Properties Requirements.................................................................... 168 6.4.1 Pyrophoric Materials.......................................................................... 168 6.4.2 Explosives, Corrosives, and Compressed Gases.................................. 169 6.4.3 Chemical Composition ....................................................................... 172 6.4.4 Chemical Compatibility ...................................................................... 174 6.5 Gas Generation Requirements........................................................................... 175 6.5.1 Payload Shipping Category ................................................................ 175 6.5.2 Compliance With Flammable ( Gas/ VOC) Concentration Limits.......... 187 6.5.3 Venting and Aspiration ...................................................................... 200 6.6 Payload Assembly Requirements....................................................................... 203 6.6.1 Requirements..................................................................................... 203 6.6.2 Methods of Compliance and Verification............................................ 204 6.7 Quality Assurance ............................................................................................ 227 6.7.1 QA Requirements for Payload Compliance......................................... 227 6.7.2 QA Compliance and Verification........................................................ 227 7. RECORDS PROCESSING.......................................................................................... 272 8. REFERENCES............................................................................................................ 274 8.1 External References.......................................................................................... 274 8.2 RFETS References ........................................................................................... 281 9. GLOSSARY................................................................................................................ 294 9.1 Definitions........................................................................................................ 294 9.2 Acronyms......................................................................................................... 305 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 7 APPENDICES Appendix 1, RFETS Organizational Charts............................................................... 307 Appendix 2, Waste Certification Flow Diagram........................................................ 309 Appendix 3, Payload Package Integrity Checklist...................................................... 312 Appendix 4, Nondestructive Assay ........................................................................... 317 Appendix 5, Numeric Payload Shipping Category Worksheet ................................... 345 Appendix 6, Payload Assembly Transportation Certification Document ( PATCD) .... 349 Appendix 7, Payload Package Transportation Certification Document ( PPTCD) ( Analytical Payload Shipping Category) ................................................ 351 Appendix 8, Payload Package Transportation Certification Document ( PPTCD) ( Test Payload Shipping Category)......................................................... 352 Appendix 9, Overpack Payload Container Transportation Certification Document ( OPCTCD) ........................................................................................... 353 Appendix 10, TRUPACT II Transportation Requirements Matrix for RFETS ............ 355 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 8 TABLES AND FIGURES Table 2 1, Summary of RFETS Program Documents ..................................................... 19 Figure 2 1, CBFO Requirements Flowdown Characterization......................................... 20 Figure 2 2, CBFO Requirements Flowdown Certification............................................... 21 Figure 2 3, CBFO Requirements Flowdown Quality Assurance...................................... 22 Table 5 1, Payload Package Assembly Configurations.................................................. 134 Table 5 2, Weight Limits.............................................................................................. 134 Table 5 3, Pu 239 FGE Limits ..................................................................................... 135 Table 5 4, PE Ci Limits ............................................................................................... 136 Table 6 1, Pu 239 Fissile Gram Equivalent, Decay Heat, and Specific Activity of Many Radionuclides................................................................................................... 228 Table 6 2, Allowable Materials   Greater Than 1 Weight Percent................................. 233 Table 6 3, Summary of Payload Waste Types............................................................... 238 Table 6 4, CH TRU Waste Material Types and G Values............................................. 239 Table 6 5, Alpha numeric Shipping Category Notation for Payload Package Configurations.................................................................................................. 240 Table 6 6, Alpha numeric Shipping Category Notation for Layers of Confinement in Payload Packages ............................................................................................. 240 Table 6 7, RFETS TRUCON Content Codes, Correlating IDCs, Shipping Categories, and Decay Heat Limits............................................................................................ 241 Table 6 8, Decay Heat Criteria for Drum Selection ...................................................... 265 Table 6 9, Maximum Total Gas Release Rates for Test Categories............................... 265 Table 6 10, Flammable Volatile Organic Compounds ................................................... 266 Figure 6 1, TRUPACT II Gas Generation Requirements   RFETS Compliance Logic Flow Diagram .................................................................................................. 267 Figure 6 2, Payload Selection....................................................................................... 268 Figure 6 3, TRUPACT II Payload Assembly Criteria ................................................... 269 Figure 6 4, Assignment of Shipping Categories ............................................................ 270 TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 9 VERSION CHANGE SUMMARY The following changes were necessary to maintain compliance with RFETS procedure PRO 815 DM 01, Developing and Maintaining Documents. This procedure requires changes to contolled documents to result in the issue of new version of the document.

Page Section Description of Change 1 Cover Page Changed " Revision 6" to " Version 7." Replaced list of required concurrence organizations with " Review/ concurrence documentation is contained in the Document History File." Revised to indicate this manual supersedes Revision 6.

2 Approvals Added following sentence, " The approvals listed below apply to Version 7 of this document."

3 TOC Deleted List of Effective Pages, moved up and updated the Table of Contents.

9 VCS Added Version Change Summary.

100 4.6.6 Added " version( s) or " to 1st and last sentence.

Entire Document Revised header on every page from " Revision 6" to " Version 7" and updated the effective date.

The following changes were made as part of document maintanenance.

Page Section Description of Change 25 <IP_ADDRESS>.2 Replaced " of data approval" with " for sample release" in 2nd sub bullet of 7th bullet.

31 Changed Quality Assurance Manager to Quality Program Manager.

34 <IP_ADDRESS>.3 Replaced " Initiating" with " Initiates" in 4th bullet.

45 <IP_ADDRESS>.4 Revised 1st bullet for LPQAOs since position no longer matrixed. Deleted 6th bullet since this is conducted by TWCP Site PQAO.

307 Changed Quality Assurance to Quality Program. Added LPQAO under Remediation, Industrial D& D, and Site Services. Deleted Procurement QA under Procurement Systems.

308 Appendix 1 Revised Material Stewardship organizational chart to delete the LPQAO from under Material Stewardship Quality Assurance.

The following changes were made as part of document maintanenance and consist of replacing, or footnoting superseded documents referenced throughout this TWMM.

Page Description of Change Replaced or deleted reference to PRO T20 Traffic 505, Certifying Authorized Payloads for TRUPACT II with PRO T43 Traffic 528, TRUPACT II Operations.

L 4231, Headspace Gas Sampling and Analysis Using an Automated Manifold superseded by PRO 1676 HGAS S& A, Headspace Gas Sampling and Analysis Using an On Line Integrated System. 42, 66, 99, 103, 105, 150, 164, 188, 193, 195, 197, 209, 210, 217, 222, 224, 280, 284, 310 311, 355, 357, 359 361 PRO 1205 MLA 008, Metrology Control of Measuring and Test Equipment, superseded by MAN 092 M& TEM, Measuring and Test Equipment Management. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 10 VERSION CHANGE SUMMARY ( continued)

Page Section Description of Change 77 <IP_ADDRESS> Modified 2nd paragraph to demonstrate that calibrations formerly conducted per PRO 1205 MLA 008, Metrology Control of Measuring and Test Equipment, are now conducted under MAN 092 M& TEM, Measuring and Test Equipment Management.

84 3.6.1 Replaced reference to PRO 1327 Services, Requisitioning Services with MAN 134 PPM, Procurement Program Manual.

The following changes were made as part of document maintanenance and consist of adding notes to deactivated documents referenced throughout this TWMM.

Page Referenced Documents RS 012 005, Cone and Quartering Method   Solid Sampling and Analysis Plan.

L 4031, Software Quality Assurance.

PRO 1471 VE 771, Visual Examination for Confirmation of RTR.

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

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

00 NDA TGS 002, Qualification Plan for the 371TGS02 Tomographic Gamma Scanner ( TGS) Building 371.

00 NDA TGS 004, Qualification Plan for the 371TGS05 Tomographic Gamma Scanner ( TGS) Building 371.

CALG PD 00005, Calorimeter/ Gamma Spec Lower Limit of Detection.

KH NDA2001 CAL 371TGS02, Calibration and Qualification Report for the ANTECH Tomographic Gamma Scanning ( TGS) Can Counter 371TGS02 After Installation of ANTECH MasterScan and MasterAnalysis Software.

KH NDA2001 CAL 371TGS05, Calibration and Qualification Report for the ANTECH Tomographic Gamma Scanning ( TGS) Can Counter 371TGS05.

KH NDA2001 RECAL 371TGS03, Calibration and Qualification Report for the Conversion of the ANTECH TGS Can Counter 371TGS03 from DAC. TGS Data Acquisition to MasterScan Data Collection Software.

PRO 1072 NDA MSQ, Matrix Specific Qualification for NDA Can Counters.

PRO 1290 TRIFID 371, TRIFID Gamma Ray Isotopic Analysis System Qualification.

PRO 1297 CLC& RPT 371, Calorimetry/ Gamma Ray Assay Calculation and Reporting of Results.

PRO 1298 ISOAN 371, Gamma Ray Isotopic Analysis of Plutonium Bearing Solids in Building 371 Cal/ Gamma Laboratory.

PRO 1299 AIRBATH 371, Calorimetry Using the ANTECH Airbath System in Building 371 Cal/ Gamma Laboratory.

PRO 1302 WIPPDATA 371, Data Review and Validation for Calorimetric Assay for WIPP TRU Waste Characterization Program in Building 371 Cal/ Gamma Laboratory.

PRO 1386 TGS 371, Setup and Calibration of Building 371 Can Tomographic Gamma Scanner ( TGS).

PRO 1392 TGS 371, Operating Building 371 Tomographic Gamma Scanning ( TGS) Can Counters. 17, 84, 155 156, 158, 170, 184, 201, 276, 278 280, 282 286, 322 323, 327, 334, 356, 359 Determination of the Total Measurement Uncertainty for the RFETS Skid Mounted TGS and Can TGS. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 11 Rocky Flats Environmental Technology Site Non Destructive Assay Calorimetry and Gamma Spectrometry Laboratories Calorimeter Qualification Plan TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 12 VERSION CHANGE SUMMARY ( continued)

The following changes were made as part of document maintanenance and consist of revising the document numbers and or titles of documents referenced throughout this TWMM.

Page Referenced Documents MAN 092 M& TEM, Measuring and Test Equipment Management Manual.

PRO T43 Traffic 528, TRUPACT II Operations Flow.

Replaced reference to 4 T30 Traffic 515, Preparation and Retention of Shipping Papers with PRO T30 Traffic 515, Preparation and Retention of Hazardous Materials Shipping Documents.

4 G83 WEM WP 1209, WEMS Waste Package Verification for and Certification.

PRO 1569 SAP 001, Polymerized Organic and Inorganic Liquid Process   Sampling and Analysis Plan 17, 77 78, 97, 99, 103 105, 113, 150, 277, 281, 285 286, 311, 355 PRO 1668 SQA, TRU Waste Characterization ProjectProgram ( TWCP) Software Quality Assurance.

The following changes were made as part of document maintanenance and consist of documents deleted throughout this TWMM.

Page Referenced Documents KH NDA2000 QUAL 371TGS01( DRUM), Qualification Report for the Determination of Plutonium 239 Combustible Waste Packaged in 55 Gallon Drums Using the Reconfigured Skid Mounted TGS Drum Counter 371TGS01( DRUM).

KH NDA2001 QUAL 569TGS04, Calibration and Qualification Report for the Determination of Plutonium 239 Combustible Waste Packaged in 55 Gallon Drums Using the ANTECH TGS Drum Counter 569TGS04.

PRO 1326 Commodities, Requisitioning Commodities.

PRO 1327 Services, Requisitioning Services.

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

L 4048, Radiological Laboratories Quality Assurance Plan.

PRO 687 TGS 371, Operating the Tomographic Gamma Scanner ( TGS).

PRO 701 TGS 371, Setup and Calibration for the Skid Mounted Tomographic Gamma Scanner ( TGS)

PRO 1006 TGS 569 01, Setup and Calibration of Building 569 Drum Tomographic Gamma Scanner ( TGS).

PRO 1007 TGS 569 02, Operating Building 569 Drum Tomographic Gamma Scanner ( TGS). 69 71, 101, 278 280, 282 284, 286, 323, 334 PRO T20 Traffic 505, Certifying Authorized Payloads for TRUPACT II. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 13 VERSION CHANGE SUMMARY ( continued)

The following changes were made as part of document maintanenance and consist of adding references to the following documents throughout this TWMM.

Page Documents Referenced PRO 1730 903 001, 903 Pad Soil Removal/ Repack and Characterization Plan KH NDA2003 CALVER 440PADC01, Calibration Verification Plan for the Newly Relocated Building 440 Imaging Passive/ Active Neutron Drum Counter ( PADC), Instrument Control Number 440PADC01. 17, 280, 286, 322, 333 KH NDA2003 CALVER RPT 440PADC01, Calibration Verification Report for the Newly Relocated Building 440 Imaging Passive/ Active Neutron Drum Counter ( PADC), Instrument Control Number 440PADC01.

The following change was made to update KH Traffic and Transportation organization related information, and active NDA system information, and document TRUCON content codes for new IDCs.

Page Section Description of Change 41, 42 <IP_ADDRESS>. 4 Revised Traffic Management Manager and Certification Official responsibilities based on Traffic and Transportation comments. 75 <IP_ADDRESS> Replaced reference to PRO T28 Traffic 513, Waste Package Inspections and Shipments with PRO T95 OSTP 002, Off Site Transportation Procedure. 99 <IP_ADDRESS> Replaced " Traffic Management" with " Traffic and Transportation." 105 286 <IP_ADDRESS> 8.2 Deleted reference to PRO T28 Traffic 513, Waste Package Inspections and Shipments 169 <IP_ADDRESS> Replaced " Transportation Security Officers" with " Transportation personnel" and added "/ or" following " move" in 4th paragraph. 243, 255 258 Table 6 7 Corrected decay heat limit for numeric shipping category 30 0340 0034 to 0.4173 for TRUCON RF116F. Added new IDCs 532A, 532B, 532C, and 532D to TRUCON content code RF130.. 286 8.2 Added reference PRO T95 OSTP 002, Off Site Transportation Procedure. 311 App. 2 Replaced " Trans. Sec. Off." with " Trans. Personnel." 319 320 A4.1 Revised 1st, 2nd, 3rd, and 4th paragraphs to demonstrate additional NDA systems now inactive. 322 Table A4.1 1 Deleted cal/ gamma related data including footnote a.

325 A4.2.1 Revised 2nd paragraph and deleted last paragraph since cal/ gamma systems are inactive. 328 Table A4.2 1 Deleted cal/ gamma related data.

330 A4.3 Deleted last sentence from the 3rd paragraph. Added notes to Calorimeter Specific Qualification Reports and Calorimetric Assay Total Measurement Uncertainty and Total Bias to indicate they are cancelled, and the systems are no longer active. 333, 334 Table A4.3 2 Deleted reference to Calibration and Qualification Report for Tomographic Gamma Scanning ( TGS) Skid Mounted Can Counter 371TGS01. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 14 1. OVERVIEW 1.1 Purpose The purpose of the Rocky Flats Environmental Technology Site ( RFETS) TRU Waste Management Manual ( TWMM) is to describe how requirements to ship waste to the Waste Isolation Pilot Plant ( WIPP) are met and to provide some of the sitespecific program documents.

Section 2.4 of the Contact Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant ( DOE/ WIPP 02 3122; hereafter referred to as the WIPPWAC requires that each participating site develop and implement site specific transuranic ( TRU) waste program documents that address applicable requirements and criteria pertaining to packaging, characterization, and certification of each defense TRU waste package to be shipped to WIPP. The WIPP WAC describes the site specific program documents that must be prepared and approved in response to Carlsbad Field Office ( CBFO) requirements. Section 2 of this document describes the site specific program documents required and identifies RFETS documents that have been created to meet the requirements.

DOE Order 435.1, Radioactive Waste Management ( U. S. DOE, 1999), requires that a TRU waste generator and/ or storage site prepare certification plan( s) identifying how the site will ensure compliance with the waste transportation and disposal criteria/ requirements applicable to the WIPP facility. The RFETS certification plan is the same as the Waste Certification Plan required by CBFO. Section 2 further describes compliance with this requirement.

1.2 TRU Waste Programs All RFETS processes producing transuranic wastes are required to operate in accordance with the requirements and implementing procedures provided in this document and in 95 QAPjP 0050, Rocky Flats Environmental Technology Site TRU Waste Characterization Program Quality Assurance Project Plan ( hereafter referred to in this document as the TWCP QAPjP). This TWMM addresses overall QA activities pertaining to the TWCP, WIPP WAC requirements, TRUPAC II Authorized Methods for Payload Control ( TRAMPAC), and TRUPACT II Safety Analysis Report ( SAR) requirements ( e. g., waste characterization using nondestructive assay, waste certification requirements, and shipping requirements). The TWCP QAPjP addresses the requirements of the WIPP RCRA Hazardous Waste Permit, Attachment B, Waste Analysis Plan ( WIPP WAP), such as RCRA waste characterization requirements, acceptable knowledge, and quality assurance records. The requirements of the CBFO Quality Assurance Program Document ( known as the QAPD) are met jointly through the implementation of the requirements located in the TWMM and in the TWCP QAPjP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 15 1.2 TRU Waste Programs ( continued)

Process specific controls, such as those for the Residues Projects, are referenced in applicable Process Control Plans ( PCPs) and/ or Process Qualification Plans ( PQPs). These plans are prepared in accordance with 1 M60 WPC 001, Waste Process Control, and are referenced as applicable requirements documents in this document and the TWCP QAPjP.

Procedure 1 M60 WPC 001, Waste Process Control, directs all RFETS management responsible for the development of new TRU waste generation, packaging, or characterization operations to assess these operations to determine if additional controls are required. If additional controls are required, responsible management is required to characterize process attributes in order to define and document process parameter values that produce process outcomes in compliance with WIPP requirements. Operations are then required to comply with the stated process parameter settings and allowable values as stated in the PCP and/ or the PQP and implemented in referenced operational procedures. The PCPs are typically directed at waste generation operations, while the PQPs are typically directed at waste characterization and waste treatment operations that produce data for waste certification. Responsible operations management may elect to prepare both plans if they deem they are necessary.

The PCPs/ PQPs are prepared by organizations responsible to develop new processes and are reviewed and approved for adequacy and completeness against WIPP requirements by involved management, the TWCP Site Project Manager ( TWCP Site PM), the TWCP Site Project Quality Assurance Officer ( TWCP Site PQAO), and the TRU Waste Certification Official ( WCO). The following PCPs provide controls for recently developed processes; this listing will be updated annually to indicate the new operations developed or in development. Refer to the TWCP QAPjP, Section A 4, Project Description, for a description of residue activities. Current PCPs include the following:

  RS 020 021, Salt Residue Repack, Buildings 371 and 707 Process Control Plan   RS 020 006, Salt Residue Stabilization, Building 707 Process Control/ Qualification Plan1   RS 020 012, Ash Residue Repack Process Control Plan   RS 020 018, Combustible Residue Repackaging Process Control Plan   RS 020 013, Dry Residue Repackaging Process Control Plan 1 The Salt Residue stabilization/ repack activity that utilized this PCP was completed in June 2000. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 16 2. REQUIREMENTS FOR CH TRU WASTE CERTIFICATION AND TRANSPORTATION TO WIPP 2.1 CBFO Requirements Documents Criteria and requirements that must be complied with by RFETS before TRU waste may be shipped to WIPP are derived from the following sources:

  The WIPP WAC   The WIPP WAP   The QAPD   The TRAMPAC   The WIPP Transportation Plan ( DOE/ CAO 98 3103)

  Performance Demonstration Program Plans The flowdown of regulatory and DOE requirements to these documents and to sitespecific program documents is shown in Figures 2 1, 2 2, and 2 3.

2.2 RFETS Program Documents RFETS program documents have been developed and implemented in response to CBFO program requirements. The following sections ( 2.2.1 through 2.2.7) describe the documents required by CBFO and identify the RFETS document( s) that provide compliance. A summary of these documents and approval requirements is provided in Table 2 1.

2.2.1 Waste Certification Plan The purpose of this plan is to identify how compliance with each requirement of the WIPP WAC is accomplished. Section 5 of the TWMM provides the site specific Waste Certification Plan. Section 5 identifies the implementing procedures that provide compliance with the waste acceptance criteria requirements of the WIPPWAC Appendix 4, of this document, addresses the procedures implemented to the Non Destructive Assay requirements of the WIPP WAC, Appendix 4. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 17 2.2.2 Certification QA Plan The purpose of the Certification QA Plan is to document site compliance with the QAPD requirements for the site certification program. Section 3 of the TWMM documents the QA program that has been implemented at RFETS to comply with certification QA requirements.

2.2.3 Quality Assurance Project Plan ( TWCP QAPjP)

A site specific QAPjP is required to document the procedures and methods that are used for waste characterization. The RFETS site specific QAPjP is the TWCP QAPjP. The TWCP QAPjP uses the same format as the WIPP WAP and documents how RFETS complies with WIPP WAP requirements. PCPs and/ or PQPs implement CBFO requirements, as applicable, at the process level.

2.2.4 Graded Approach Procedure The QAPD requires that each site prepare a Graded Approach Procedure. The procedure is to be used to determine the appropriate controls necessary to manage the items, systems, and activities under the cognizance of CBFO. Procedure PRO 486 WIPP 006, TRU Waste Characterization Project QA Grading, has been developed and implemented at RFETS to comply with this requirement.

The steps leading to identifying realistic process controls are to: ( 1) identify the RFETS procedures that implement WIPP requirements, ( 2) designate each WIPPrelated procedure as Quality Level ( QL) Major or QL Minor, and 3) cross correlate each WIPP related procedure to a corresponding QAPD QA element. Procedure PRO 486 WIPP 006, TRU Waste Characterization Project QA Grading, contains this list of RFETS WIPP related procedures that implement QAPD requirements. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 18 2.2.5 Sampling Plan The document 95 WP/ SAP 001, Transuranic ( TRU/ TRM) Waste Sampling Plan, supports the WIPP WAP and the TRAMPAC sampling requirements. It outlines the strategy to be used by the site in the sampling of TRU waste that will be shipped to WIPP for disposal. The contents of 95 WP/ SAP 001, Transuranic ( TRU/ TRM) Waste Sampling Plan, correspond to requirements given in the WIPP WAP. Compliance with the WIPP WAP is accomplished through the use of the TWCP QAPjP and the TWMM.

Individual Sampling Plans that support various processes are:

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

  RS 012 005, Cone and Quartering Method  Solid Sampling and Analysis Plan1;

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

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

2.2.6 TRAMPAC and Associated QA Plan The site specific TRAMPAC is required to describe, in technical detail, how compliance with requirements of the TRAMPAC and Certificate of Compliance will be met. Section 6 of the TWMM is the RFETS TRAMPAC. Section 6 references RFETS procedures that pertain to loading and unloading the TRUPACT II and that provide compliance with the requirements of the TRAMPAC. Section 3 of the TWMM provides the QA Plan that is associated with the TRAMPAC.

2.2.7 Packaging QA Plan The Packaging QA Plan describes the site QA program for TRU Waste Packaging. The requirements for packaging are contained in 10 CFR 71, Subpart H. Existing QA programs may be used if they meet the requirements of 10 CFR 71 requirements. Section 4.6 provides the Packaging QA Plan for the TRU Waste Characterization Project.

1 This document is inactive as of December 2003. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 19 Table 2 1, Summary of RFETS Program Documents RFETS PROGRAM DOCUMENT RFETS DOCUMENT PROVIDING COMPLIANCE DOCUMENT REVIEW/ APPROVAL Waste Certification Plan TWMM, Section 5.0 National TRU Waste Program Team Leader Approves CBFO QA Manager Approves CBFO Transportation Package Manager Reviews DOE Rocky Flats Field Office ( RFFO) Approves RFETS Contractor Review and Approval according to MAN 001 SDRM, Site Document Requirements Manual; PRO 1329 DM 03, Site Document Control; and PRO 815 DM 01, Developing and Maintaining Documents Certification QA Plan TWMM, Section 3.0 Same review/ approval as listed above for the Waste Certification Plan TWCP Quality Assurance Project Plan ( TWCP QAPjP) TWCP QAPjP National TRU Waste Program Team Leader Approves CBFO QA Manager Approves DOE RFFO Approves RFETS Contractor Review and Approval according to MAN 001 SDRM, Site Document Requirements Manual; PRO 1329 DM 03, Site Document Control; and PRO 815 DM 01, Developing and Maintaining Documents Graded Approach Procedure PRO 486 WIPP 006, TRU Waste Characterization Project QA Grading CBFO QA Manager Approves DOE RFFO Approves RFETS Contractor Review and Approval according to MAN 001 SDRM, Site Document Requirements Manual; PRO 1329 DM 03, Site Document Control; and PRO 815 DM 01, Developing and Maintaining Documents Sampling Plan ( no longer a WIPP requirement) 95 WP/ SAP 001, Transuranic ( TRU/ TRM) Waste Sampling Plan RFETS Contractor Review and Approval according to MAN 001 SDRM, Site Document Requirements Manual; PRO 1329 DM 03, Site Document Control; and PRO 815 DM 01, Developing and Maintaining Documents TRAMPAC & Associated QA Plan The TRAMPAC is provided in the TWMM, Section 6; and the associated QA Plan is provided in the TWMM, Section 3.0. Same review/ approval as listed above for the Waste Certification Plan Packaging QA Plan TWMM, Section 4.6 Same review/ approval as listed above for the Waste Certification Plan TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 20 Figure 2 1, CBFO Requirements Flowdown Characterization Site Specific QAPjP ( TWCP QAPjP, 95 QAPjP 0050)

Site Specific Sampling Plan Implementing Procedures WIPP Hazardous Waste Facility Permit Waste Analysis Plan ( WIPP WAP) 40 CFR Parts 260 266, 268, & 270 RCRA TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 21 Figure 2 2, CBFO Requirements Flowdown Certification Implementing Procedures RFETS DATA INPUT TO WWIS Site Specific TRAMPAC ( Section 6 of TRU Waste Management Manual) Site Specific Packaging QA Program Plan ( Section 4.6 of TRU Waste Management Manual) 10 CFR Parts 70 and 71 Packaging DOE/ WIPP 02 3122 CONTACT HANDLED TRANSURANIC WASTE ACCEPTANCE CRITERIA ( WAC) DOE Order 5840.23 WIPP Operations WIPP Safety Analysis Report DOE Order 6430.1A WIPP Design 49 CFR Parts 107, 110, and 171 173 Transportation TRAMPAC Compliance Certification Application 40 CFR Parts 191 & 194 Radiation Standards Site Specific Waste Certification Plan ( Section 5 of TRU Waste Management Manual) TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 22 Figure 2 3, CBFO Requirements Flowdown Quality Assurance DOE Order 414.1a NQA 1 NQA 2a 10 CFR 830.

Site Specific QAPjP ( TWCP QAPjP, 95 QAPjP 0050) Graded Approach Procedure ( PRO 486 WIPP 006, TRU Waste Characterization Project Quality Assurance Grading) TRAMPAC Associated QA Plan ( Section 3, TWMM) Site Specific Certification QA Plan ( Section 3, TWMM)

Implementing Procedures DOE/ CBFO 1012, Quality Assurance Program Document ( QAPD) TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 23 This page is intentionally blank TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 24 3.0 CERTIFICATION AND TRAMPAC QUALITY ASSURANCE PROGRAMS This section describes the TRU Waste Characterization Project QA Program that provides compliance with the Quality Assurance requirements defined in the QAPD. The TRU Waste Characterization Project QA Program is also the QA Program associated with the TRAMPAC for the use, maintenance, and control of the TRUPACT II.

The RFETS QA requirements are identified in the Kaiser Hill Quality Assurance Program Criteria. The QA Program implemented by the TRU Waste Characterization Project is directed towards CBFO QA requirements.

Any payload packages with unresolved discrepancies associated with hazardous waste characterization will not be shipped to WIPP until the discrepancies are resolved. Corrective action reports applicable to WIPP WAP requirements shall be resolved prior to waste shipment.

3.1 Management Requirements 3.1.1 Organization & QA Program This section describes the organizational, managerial and quality assurance structure and responsibilities for the RFET TRU Waste Programs. Generator and originator are titles considered synonymous and used interchangeably throughout this plan.

<IP_ADDRESS> Organization The functional organization charts in Appendix 1, Organizational Charts show the RFETS TRU Waste Programs organizational breakdown and reporting hierarchy, which is updated commensurate with changes to the TWMM. The Kaiser Hill ( KH) Human Resources department maintains the official organizational charts for RFETS.

<IP_ADDRESS>.1 Management Responsibilities The responsibilities listed here are the general responsibilities of the organizations. The specific tasks and responsibilities to be performed by these organizations are defined in the Rocky Flats Closure Project ( RFCP), Project Management Plan ( PMP), work packages, and in specific operating procedures. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 25 <IP_ADDRESS>.1 Management Responsibilities ( continued)

Management delegates TWCP authority and decision making to the organizations described in Sections <IP_ADDRESS>.1 through <IP_ADDRESS>.4. These organizations are responsible for establishing, planning, accomplishing, and assessing TRU waste activities at the lowest appropriate level in the organization.

Kaiser Hill ( KH) is responsible for ensuring the development, implementation, and maintenance of plans, policies, and procedures necessary to assure compliance with all applicable regulations, U. S. Department of Energy ( DOE) orders and requirements applicable to activities subject to the QAPD.

Material Stewardship, TRU Waste Project, provides program management of the TWCP. The Vice President, Material Stewardship, designates the TRU Waste Project Manager. The TRU Waste Project Manager fulfills the functional role of TWCP Site PM.

The TWCP Site PM is responsible for directing the TRU waste generation, characterization, certification and transportation activities across all organizations supporting the program. The TWCP Site PQAO identifies and achieves all management QA responsibilities by developing, implementing and maintaining the quality assurance programs and mechanisms to ensure compliance to specified quality assurance requirements. The following sections of this document describe the specific responsibilities of the Site PM and the Site PQAO.

<IP_ADDRESS>.2 Employee Responsibilities The TWCP Site PM performs the following:

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

  Performs oversight and/ or management of TRU Waste Program characterization activities.

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

  Manages CBFO and New Mexico Environmental Department ( NMED) audit preparations for TRU Waste Program characterization and Residues processing.

  Ensures through the TWCP Site PQAO that surveillances are scheduled and performed. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 26 <IP_ADDRESS>.2 Employee Responsibilities ( continued)

The TWCP Site PM ( continued)

  Ensures development and maintenance of program documents, plans and procedures necessary to implement the TRU Waste Program:

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

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

  Reviews and concurs on TRU Waste Program characterization plans and procedures [ e. g., headspace gas, visual examination ( VE), nondestructive assay ( NDA), Real Time Radiography ( RTR)];

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

  Ensures that projects that support TRU Waste Program activities utilize processes that comply with TRU Waste Program requirements.

  Concurs with appointment of the TWCP Site PQAO and the Project Data Control Officer ( PDCO).

  Designates the Project Training Officer.

  Ensures that applicable personnel are trained and qualified to TRU Waste Program requirements.

  Provides for waste selection and tracking.

  Provides for data validation and verification:

  Approves Batch Data Reports;

  Provides notification to Headspace Analytical Services and the Analytical Laboratory for sample release.

  Provides for data reconciliation with data quality objectives ( DQOs):

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

  Provides direction to the TWCP Site PQAO, PDCO, and project staff regarding analytical data validation and reconciliation with quality assurance objectives ( QAOs) as necessary. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 27 <IP_ADDRESS>.2 Employee Responsibilities ( continued)

The TWCP Site PM ( continued)

  Provides for the assignment of U. S. Environmental Protection Agency ( EPA) Hazardous Waste Codes:

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

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

  Approves Waste Stream Profile Forms ( WSPFs).

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

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

  Provides for data transmission to CBFO:

  Signs transmittal of the final Batch Data Reports;

  Provides for submittal of the required Batch Data Reports [ through Waste Environmental Management System ( WEMS)] to the WIPP prior to each TRU waste shipment ( contains complete package and shipping information).

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

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

  Ensures that operator training is conducted according to requirements;

  Ensures that visual waste characterization data are obtained for appropriate waste containers used in the TRU Waste Program;

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

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

  Ensures that data are recorded and complete;

  Ensures that waste characterization data forms and reports are transmitted to the PDCO as soon as possible after data generation; and   Ensures 100% validation of VE raw data. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 28 <IP_ADDRESS>.2 Employee Responsibilities ( continued)

The PDCO performs the following:

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

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

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

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

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

  Provides training to WIPP records custodians. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 29 <IP_ADDRESS>.2 Employee Responsibilities ( continued)

The Headspace Analytical Services Manager performs the following:

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

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

  Ensures that headspace personnel are trained and qualified.

  Ensures participation in the PDPs for analytical testing.

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

  Coordinates and schedules analytical work to support the TWCP.

  Ensures that corrective and preventive actions have been completed.

  Reviews and approves all Headspace Analytical Services SOPs and reports.

  Assigns headspace staff.

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

  Verifies that analytical requirements of the WIPP WAP and QAPjP have been met TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 30 <IP_ADDRESS>.2 Employee Responsibilities ( continued)

The Measurements Manager is responsible for delegating the following technical, operational, data management and planning, and quality assurance activities:

Technical activities include:

  Establishing and maintaining a Measurement Control Program in accordance to the WIPP WAC;

  Selecting, calibrating, and qualifying RFETS NDA measurement systems;

  Coordinating with the TWCP Site PM, TWCP Site PQAO and Materials Control & Accountability on NDA activities affecting TRU Waste Programs;

  Ensuring that Measurements documents are compliant with TRU Waste Programs requirements;

  Providing expert review, if necessary, of NDA Testing Batch Data Reports;

  Designating and providing supervision of NDA functions;

  Providing oversight of subcontracted NDA services ( if required);

  Implementing a documented program for a measurement facility that specifies qualitative and quantitative acceptance criteria and corrective action processes;

  Investigating measurement problems, and documenting and performing corrective actions;

  Facilitating the implementation of quality related activities, including data interpretation, procedure development and updates, nonconformance reports, and corrective actions; and   Supporting quality control activities of measurement operations and data management. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 31 <IP_ADDRESS>.2 Employee Responsibilities ( continued)

The Measurements Manager ( continued)

Operational activities include:

  Supervising the installation of new NDA equipment that measure radionuclides for Residues, TRU Waste, and low level waste ( LLW);

  Performing calibrations and calibration verifications of NDA equipment to applicable requirements and at specified frequencies;

  Maintaining and repairing RFETS NDA counters and equipment;

  Maintaining configuration control of RFETS NDA counters to meet applicable NDA QC requirements and frequencies;

  Providing subject matter expert ( SME) support for the maintenance and operation of NDA equipment;

  Tracking RFETS NDA standard certification status;

  Establishing and maintaining NDA procedures; and   Qualifying, training and re qualifying NDA personnel to existing industry training standards.

Data management activities include:

  Designating and providing supervision of NDA data quality functions   Establishing and maintaining an inventory of isotopic ratios of prevalent radionuclides for confirmation of AK;

  Designating and providing supervision of Data Generation Level Data Validation and Verification ( V& V) as follows:

  Providing NDA Data V& V;

  Monitoring the measurement control and instrument check data to assure that RFETS NDA counters perform according to quality requirements; and   Resolving Batch Data Report issues related to data quality. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 32 <IP_ADDRESS>.3 Quality Assurance Management & Responsibilities The KH Site Quality Program Manager performs the following:

  Assures QA management has direct access to responsible management at a level where appropriate action can be effected, is sufficiently independent from cost and schedule considerations, has the organizational freedom to communicate with management, and, has no other assigned responsibilities unrelated to the QA program that would prevent full attention to QA matters.

  Identifies and reports quality problems to the TWCP Site PM or Site PQAO.

  Responsible for site corrective action program   Initiates stop work orders according to 1 V10 ADM 15.02, Stop Work Action, when appropriate.

  Coordinates the identification, evaluation, and resolution of site wide quality issues or quality issues that cross project boundaries.

  Provides an interface between senior management and project QA functions for site wide issues or issues that cross project boundaries. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 33 <IP_ADDRESS>.3 Quality Assurance Management & Responsibilities ( continued)

The Material Stewardship QA Manager performs the following:

  Designates and provides oversight of the TWCP Site PQAO.

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

  Schedules and conducts assessments of the TRU Waste Program.

  Provides day to day guidance on quality related matters to TRU Waste Program staff.

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

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

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

  Provides for technical guidance for RFETS Waste Inspectors.

  Ensures that Waste Inspectors meet responsibilities identified in waste inspection procedures. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 34 <IP_ADDRESS>.3 Quality Assurance Management & Responsibilities ( continued)

The TWCP Site Project Quality Assurance Officer ( TWCP Site PQAO) performs the following:

  Ensure that the TRU Waste Program QA program provides RFETS compliance with the QAPD.

  Schedules, performs, or directs, surveillance of TRU waste characterization, generation, packaging, control, and acceptance activities including assessments of labs and testing facilities.

  Tracks, reviews and approves the disposition of TRU Waste Program nonconformances

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

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

  Verifies data QA documentation through the data validation and verification of Batch Data Reports   Tracks, performs trend analysis, and reports on quality problem areas.

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

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

  Provides QA/ QC reports to the TWCP Site PM for review, transmittal to CBFO, and distribution to the RFFO. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 35 <IP_ADDRESS>.3 Quality Assurance Management & Responsibilities ( continued)

The TWCP Site PQAO ( continued)

  Ensures conformance to QA requirements through:

  Review and approval of procedures that implement the TRU Waste Program QA program;

  Review and concurrence on the TWCP QAPjP, the Gas Generation Testing Program ( GGTP) QAPjP, the TWMM and PRO 486 WIPP 006;

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

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

  Provides day to day guidance on quality assurance related matters, as necessary, to TRU Waste Program staff.

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

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

  Interfaces with generators of TRU Waste Program data and quality related records. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 36 <IP_ADDRESS>.3 Quality Assurance Management & Responsibilities ( continued)

Headspace Analytical Services Quality Assurance Officer ( HASQAO) performs the following:

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

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

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

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

  Provides quality surveillance of headspace TWCP related activities.

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

  Verifies the implementation of project QA requirements.

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

  Initiates, recommends, and tracks corrective actions to closure.

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

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

  Ensures that all headspace requirements of the WIPP WAP and QAPjP have been met. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 37 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities RFETS TRU Waste Programs has communications and interface responsibilities with Technical Operations; Waste Certification & Oversight; Traffic & Transportation; and other supporting groups. The following paragraphs discuss the general responsibilities of each of these groups.

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

Waste Systems performs the following:

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

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

  Maintains the content and accuracy of the Backlog Waste Reassessment Baseline Book ( BWRBB) and coordinates reassessment of characterization information for packaged waste. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 38 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Technical Operations ( continued)

Waste Requirements Group performs the following:

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

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

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

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

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

  Prepares, issues, controls, and maintains waste packaging procedures.

  Specifies labeling and marking of waste packages according to U. S. Department of Transportation ( DOT) and treatment, storage, and disposal facility ( TSDF) requirements in accordance with the appropriate Labeling and Marking Procedures for Radioactive Waste Material Packages.

  Reviews requisitions and approves for WIPP related commodities to ensure project requirements are included. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 39 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Waste Operations The Waste Operations organization performs the following:

  Maintains storage area for off site shipments.

  Stores RCRA regulated wastes in compliance with applicable regulations.

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

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

  Labels and marks packages according to DOT and TSDF requirements ( refer to Labeling and Marking Procedures for Radioactive Waste Material Packages).

  Performs loading operations of TRUPACT II packages.

NDA Operations NDA Operations performs the following:

  Operates NDA equipment located both inside and just outside of Buildings 440 and 664.

  Participate in NDA performance demonstration program ( PDP).

Building 371 Nuclear Operations Building 371 Nuclear Operations performs the following:

  Operates NDA equipment located in Building 371.

  Maintains and repairs Building 371 cal/ gamma counters.

Nondestructive Testing ( NDT)

NDT performs the following:

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

  Reviews and approves the TRUPACT II leak test standard operating procedures ( SOPs);

  Maintain and qualify TRUPACT II leak test equipment to guidelines of ANSI, N14.5 1997, Radioactive Materials   Leakage Tests on Packages for Shipment;

  Responsible for performing RTR of waste packages. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 40 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

NDT ( continued)

  Responsible for the oversight of mobile RTR vendors.

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

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

  Reviews and approves RTR data reports and forms;

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

  Coordinates and schedules NDT work to support the TRU Waste Program;

  Reviews and approves the NDT SOPs and forms and reports;

  Verifies that TWCP QAPjP requirements are met;

  Reviews and concurs with the TWCP QAPjP;

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

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

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

  Assigns NDT personnel;

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

  Ensures the preventive and routine maintenance is conducted in accordance with the requirements of this document; and   Ensures that nonconformances are reported and corrective actions have been completed. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 41 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Waste Certification & Oversight The Waste Certification & Oversight ( WC& O) organization performs the following activities through the Waste Certification Official ( WCO):

  Reports to the Manager of WC& O who reports to the manager of Environmental Compliance.

  Maintains independence from waste generating organizations.

  Reviews and concurs with process and quality controls.

  Reviews and approves NDA Qualification Reports.

  Serves as a point of contact for TRU waste NCRs.

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

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

  Certifies by signature that the TRU waste is properly classified, packaged, marked, labeled, and loaded in the TRUPACT II package, and meets WIPPWAC

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

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

  Reviews and concurs with TRU waste management procedures.

Document Control The Document Control organization conducts information resource management by performing the following:

  Ensures controlled distribution of specific documents related to the TRU Waste Programs.

  Maintains document history files as specified in MAN 001 SDRM, Site Document Requirements Manual ( SDRM). TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 42 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Traffic and Transportation The Traffic and Transportation organization is independent from waste generation, inspection, test and certification organizations. The Traffic Management group supports the Traffic and Transportation organization. Traffic and Transportation organization is responsible for the following:

  All issues concerning on site transfer or off site shipments.

  Compliance to DOT requirements.

  Appointing the Manager of Traffic Management.

The Manager of Traffic Management performs or designates individuals to perform the following:

  Reports to the Manager of Traffic and Transportation.

  Generates and maintains site procedures providing guidance and specifying the DOT marking and labeling requirements for waste packages.

  Prepares shipping papers from shipment data information.

  Delivers and certifies personnel training for DOT hazardous materials transportation, as required in 49 CFR.

  Notifies the TRU waste disposal site ( WIPP) of each shipment prior to departure.

  Interfaces with WIPP, oversight groups, the WCO, and TRU Waste Programs on transportation issues.

  Maintains a records system pertaining to shipments.

  Performs pre loading and post loading vehicle, trailer, and load inspections per Commercial Vehicle Safety Alliance ( CVSA) requirements.

  The Manager of Traffic Management fulfills the Transportation Certification Official ( TCO) duties by appointing the Transportation Certification Official. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 43 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Traffic and Transportation ( continued)

The Transportation Certification Official ( TCO) performs the following:

  Signs the Bill of Lading and the Uniform Hazardous Waste Manifest, and thereby certifying the following:

  Waste package contents are fully and accurately described, classified, and packaged;

  Waste packages are properly marked and labeled;

  Waste shipments are , in all respects, in proper condition for transportation according to the applicable regulations of the Department of Transportation and meet Title 40 and Title 49 CFR hazardous waste and transportation requirements;

  A waste minimization program is in place;

  Approval of payload packages;

  Compliance with packaging and records requirements.

  Verifies the Payload Container Transportation Certification Document ( PCTCD), Overpack Payload Container Transportation Certification Document ( OPCTCD), and the Payload Assembly Transportation Certification Document ( PATCD). Each item on these documents must be verified per PRO T43 Traffic 528, TRUPACT II Operations, and this procedure is consistent with the TRAMPAC).

  Ensures compliance to all requirements before releasing the truck to the carrier.

Procurement Engineering & Quality Assurance The Procurement Engineering & Quality Assurance organization is responsible for the following:

  Evaluates suppliers.

  Maintains Site Evaluated Subcontractors List.

  Investigates supplier issues leading to resolution.

  Represents the Site to the DOE Contractor's Supplier Quality Information Group. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 44 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Procurement Systems Procurement Systems is responsible for the following:

  Solicits and evaluates offers and awards purchase orders.

  Subcontracts for WIPP packagings and supporting items.

Procurement Systems performs the following:

  Maintains appropriate stock levels.

  Pre assembles the Pipe Overpack Component ( POC) in accordance with PRO 284 POC 001, Pipe Overpack Component Initial Assembly Process.

  Prepares and transfers accepted empty waste packaging, including hardware and associated waste packaging items, to various contractors in compliance with the established warehouse transfer operation procedure, PRO Q49 PKG 4040, Warehouse Waste Packaging Operations.

  Conducts essential source and receipt inspection and certification processes ( as required) on new waste packagings, drum rings, hardware, and associated waste packaging materials, to verify that purchased items and services meet all applicable requirements, standards, and specifications of the purchase agreement, prior to the final certification and release to the RFETS warehouse storage facility.

  Records and controls nonconforming items identified by certification and inspection ( C& I) inspection using Receiving Inspection Deficiency Reports, implementing the nonconformance process described in 1 A65 ADM 15.01, Control of Nonconforming Items. This prevents inadvertent or unauthorized use while a technical evaluation of the item's condition is being conducted.

  Maintains inspection records to substantiate item compliance with established requirements, standards and specifications relevant to the Purchase Order agreement. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 45 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Remediation, Industrial D& D, and Site Services ( RISS)

The RISS organization is supported by the Metrology, Laboratory, and Analytical Services groups The Metrology group manages the subcontracted calibration of measuring and test equipment used in the packaging and processing of waste.

The Laboratory group is responsible for the following:

  Provides analytical chemistry services in support of waste characterization.

  Performs the material testing.

  Performs the destructive analysis of wastes and radioactive materials.

  Appointing the Analytical Laboratories Manager.

Analytical Laboratories Manager performs, or delegates to subordinate managers, the following responsibilities:

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

  Ensures that analytical personnel are trained and qualified.

  Ensures participation in the PDPs for analytical testing.

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

  Coordinates and schedules analytical work to support the TRU Waste Program.

  Ensures that corrective and preventive actions have been completed.

  Reviews and approves all Analytical Laboratory SOPs and reports.

  Assigns laboratory staff.

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

  Verifies compliance to analytical requirements of the WIPP WAP and QAPjP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 46 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

RISS ( continued)

The Analytical Services group is responsible for the following:

  Performs evaluations of requisitions for subcontracted analytical services.

  Generates Chain of Custody and unique identification and control numbers for sampling activities.

  Appointing the Analytical Laboratories Project Quality Assurance Officer ( LPQAO).

The LPQAOs perform the following:

  Directs all of the Analytical Laboratories' WIPP related QA activities.

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

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

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

  Provides quality surveillance of analytical laboratory TRU Waste Program related activities.

  Verifies the implementation of project QA requirements.

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

  Initiates, recommends, and tracks corrective actions to closure.

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

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

  Ensures that all analytical laboratory requirements of the WIPP WAP and QAPjP have been met. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 47 <IP_ADDRESS>.4 Communication and Organizational Interface Responsibilities ( continued)

Materials Control & Accountability ( MC& A)

The MC& A organization performs the following:

  Responsible for control and accountability of nuclear material. Controls are described in the Safeguards Accountability Manual.

  Maintains program for the application of tamper indicating devices ( TIDs).

  Generates the DOE/ Nuclear Regulatory Commission ( NRC) 741 form based on the load list for waste shipments to WIPP.

  Updates the RFETS accountability system with measurement results. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 48 <IP_ADDRESS> Implementation of the QA Program The documentation, controls, and training described in this document implement the TRU Waste Program QA program. Section 3 of this document provides an overall description of project activities and the QA Program.

<IP_ADDRESS>.1 Quality Assurance Program Documents The TWMM and the TWCP QAPjP document the plans and procedures that effectively implement the requirements of the QAPD, the WIPP WAP, the WIPPWAC and the TRUPACT II Authorized Methods for Payload Control ( TRAMPAC).

<IP_ADDRESS>.2 Applicability of QAPD Requirements QAPD requirements apply to TRU Waste Program items or activities relative to compliance application, waste characterization, repository performance assessment, waste isolation, waste transportation, nuclear safety, and environmental protection.

<IP_ADDRESS>.3 Grading Items and Activities & Applying Management Controls PRO 486 WIPP 006, TRU Waste Characterization Project QA Grading, provides instructions for implementing the graded approach utilized in implementing the QA program.

<IP_ADDRESS>.4 Planning Work 95 QAPjP 0050, RFETS QAPjP, PRO 486 WIPP 006 and the applicable sections of this document are used in the planning of waste management activities at RFETS. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 49 3.1.2 Personnel Training & Qualification Training development, approval and delivery complies with applicable DOE orders and the WIPP WAP. Personnel associated with the generation, handling, packaging, inspection, testing, processing, certification, and shipment of waste shall be trained and qualified to applicable criteria, in accordance with the Site TPM.

<IP_ADDRESS> Qualification Requirements The Site TPM and TIP document the applicable qualification criteria for TRU Waste Program personnel.

<IP_ADDRESS> Training Requirements The TWCP TIP documents the training requirements for personnel supporting the TRU Waste Program. RFETS management having employees performing tasks directly in support of the TRU Waste Program ( performing to procedures on activities described in this document and the TWCP QAPjP) are responsible for ensuring their employees meet the training requirements in the TWCP TIP.

The Training, Scheduling, and Records database provides the official status of training. Training records are maintained and transferred to the Waste Records Center according to instructions in the Site TPM and TIP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 50 3.1.3 Quality Improvement The RFETS Management organizations are responsible for ensuring compliance to quality improvement requirements by creating a culture of continuous improvement of items, services, activities and processes. Quality Improvement is achieved through the management assessment, surveillance, independent assessment, nonconformance, and corrective action processes.

<IP_ADDRESS> Quality Affecting Problems Quality affecting problems and items, activities, and processes that do not meet established requirements are identified, documented, reported, controlled, and corrected. Quality problems may be identified by RFETS Management organizations or by an external source.

<IP_ADDRESS>.1 Problem Identification RFETS personnel are responsible for promptly reporting to management any problem condition identified as adverse to quality. Management at all levels fosters a " no fault" attitude to encourage the identification of quality affecting problems. Conditions adverse to waste acceptability are identified promptly through inspections, tests, surveillances, and audits and corrected as soon as practical. Corrective actions for quality affecting problems are implemented and characterized, as described in 3 X31 CAP 001, Corrective Action Process, according to their significance based on the greatest potential for:

  Posing adverse risks to the environment and human health;

  Adversely impacting the quality and reliability of waste operations; and   Affecting the ability to meet quality requirements.

<IP_ADDRESS>.2 Problem Types Quality affecting problems may involve:

  Noncompliance with a QA program requirement. A noncompliance is classified as a Condition Adverse to Quality ( CAQ) or Significant Condition Adverse to Quality ( SCAQ).

  Nonconforming items, including suspect/ counterfeit items or data, which do not conform to specified requirements. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 51 <IP_ADDRESS> Nonconformances RFETS organizations ensure compliance to specific quality requirements by identifying, classifying and controlling conditions adverse to quality, and by ensuring adequate control and disposition of nonconforming items.

<IP_ADDRESS>.1 Documenting and Evaluating Nonconforming Items The documentation and evaluation of nonconforming items and data are conducted according to 1 A65 ADM 15.01, Control of Nonconforming Items. Characteristics that do not conform to specified criteria are documented with nonconformance reports ( NCRs) which are reviewed and evaluated by competent personnel for corrective actions. Waste package nonconformances are specifically addressed in PRO U76 WC 4030, Control of Waste Nonconformances, and documented with waste nonconformance reports ( WNCRs).

<IP_ADDRESS>.2 Identifying Nonconforming Items or Data Nonconforming items, data, or nonconforming waste packages are identified by marking, tagging, or segregating as described in 1 A65 ADM 15.01, Control of Nonconforming Items; and PRO U76 WC 4030, Control of Waste Nonconformances.

<IP_ADDRESS>.3 Reporting Nonconformances The TWCP Site PQAO provides written notification to the CBFO QA Manager and National TRU Programs Assistant Manager of all non administrative nonconformances related to applicable WIPP WAP requirements ( i. e., a failure to meet a DQO) first identified during the TWCP Site PM review level within five ( 5) days of identification and validation. The TWCP Site PQAO then provides a nonconformance report to CBFO within thirty ( 30) days of identification. This process is described in PRO 940 WIPP 010, WIPP TRU Waste Characterization Project Level Data Review and Reporting. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 52 <IP_ADDRESS>.4 Segregating Nonconforming Items When a nonconformance is identified, controls are established to prevent further processing, delivery, installation, or use of nonconforming items pending the evaluation and approval of the disposition. Nonconforming items, data, or nonconforming waste packages are identified and segregated according to 1 A65 ADM 15.01, Control of Nonconforming Items and PRO U76 WC 4030, Control of Waste Nonconformances. Nonconforming waste packages are tracked in the WEMS system with controls to prevent the nonconforming waste package from being shipped off site.

<IP_ADDRESS>.5 Disposition of Nonconforming Items or Data Procedure PRO U76 WC 4030, Control of Waste Nonconformances, addresses review and disposition of nonconforming waste packages. Packages not meeting certification requirements may be returned to the waste generating organization for corrective action. Return of the rejected waste package to its originating organization is dependent upon area storage capacity, 90 day storage limitations, and radiation and chemical protective equipment requirements. WNCR dispositions are documented by describing the corrective actions to be taken in the space provided on the WNCR. Independent verification of corrective actions is performed by the WC& O prior to closure.

Nonconforming items or data are controlled according to 1 A65 ADM 15.01, Control of Nonconforming Items. These NCRs are tracked in the Plant Action Tracking System in accordance with 3 X31 CAP 001, Corrective Action Process.

NCRs pertaining to TRUPACT II packages are submitted to the WIPP management and operation ( M& O) contractor per the requirements of DOE/ WIPP 02 3183, CH Packaging Program Guidance, for formal disposition.

<IP_ADDRESS>.6 Quality Trending of Nonconformances TRU waste related nonconformance documentation is periodically analyzed by the TWCP Site PQAO to identify quality trends in accordance with Section <IP_ADDRESS>. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 53 <IP_ADDRESS> Corrective Action <IP_ADDRESS>.1 Identifying Conditions Adverse to Quality ( CAQ)

A CAQ occurs when a QA requirement has not been met.

<IP_ADDRESS>.2 Classification of Conditions Adverse to Quality The TWCP Site PQAO reviews all documented noncompliances to determine if the noncompliance identified impacts the TRU Waste Program according to PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems. Classification of CAQs is based on the effect the CAQ has on compliance to regulatory requirements for operability, TRU waste characterization, TRU waste certification, TRU waste containment and the effective implementation of the QAPD. Any CAQ that is determined to be noncompliant with a WIPP WAP requirement is treated as an SCAQ.

<IP_ADDRESS>.3 Conditions Adverse to Quality The TWCP Site PQAO reviews all documented quality affecting problems to determine if the problem identified impacts the TRU Waste Program and meets the criteria of CAQ according to PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems. Corrective actions for identified CAQs are implemented as determined by the cognizant Responsible Manager according to 3 X31 CAP 001, Corrective Action Process, and completed as soon as practical.

<IP_ADDRESS>.4 Significant Conditions Adverse to Quality The TWCP Site PQAO reviews all documented quality affecting problems to determine if the problem identified impacts the TRU Waste Program and meets the criteria of SCAQ according to PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems. Corrective actions for identified SCAQs are implemented as determined by the cognizant Responsible Manager according to 3 X31 CAP 001, Corrective Action Process. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 54 <IP_ADDRESS>.5 Corrective Action Planning Procedure 3 X31 CAP 001, Corrective Action Process initiates, documents, and tracks corrective actions. SCAQs and associated CAPs are reviewed by the TWCP Site PQAO according to PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems.

Cause analysis is performed when SCAQs are identified ( refer to MAN 062 CAUSEANALYSIS, Cause Analysis Requirements Manual). SCAQs may result in issuance of a stop work order by the Cognizant Responsible Manager in conjunction with the TWCP Site PQAO, and the TRU Program.

<IP_ADDRESS>.6 Work Suspension Stop work orders are issued according to procedure 1 V10 ADM 15.02, Stop Work Action. SCAQs resulting in Stop Work Actions must be corrected prior to resuming waste processing. Completion of corrective actions is verified by the cognizant Project quality organization or Site Quality Program prior to releasing the work suspension.

<IP_ADDRESS>.7 Corrective Action Follow Up As described in PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems, the TWCP Site PQAO verifies corrective actions for SCAQs are completed according to 3 X31 CAP 001, Corrective Action Process.

<IP_ADDRESS>.8 Recurring Conditions Adverse to Quality Recurring conditions are evaluated according to PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems.

<IP_ADDRESS>.9 Quality Trending The TWCP Site PQAO trends TRU Waste Program related quality affecting problems according to PRO 943 WIPP 007, TRU Waste Characterization Program Trending and Analysis of Quality Affecting Problems, and identifies opportunities for improvement.

Periodically TRU Waste Program may review the radioactive waste management activities. This activity could result in the identification of programmatic issues and quality affecting problems, or significant adverse trends, which could affect the certifiability of waste. Follow up actions will include applicable activities defined in 3 X31 CAP 001, Corrective Action Process. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 55 3.1.4 Document Control MAN 001 SDRM, Site Document Requirements Manual, PRO 815 DM 01, Developing and Maintaining Documents and PRO 1329 DM 03, Site Document Control define the RFETS Document Control Program. Procedures and documents supporting the TRU Waste Program are maintained in document control systems that comply with the requirements of the QAPD.

The RFETS Document Control organization ensures compliance to specific document control requirements by controlling the preparation, modification, review, approval, issuance, distribution and use of TRU Waste Program related documents.

<IP_ADDRESS> Document Preparation, Review, Approval, and Issuance PRO 815 DM 01, Developing and Maintaining Documents and PRO 1329 DM 03, Site Document Control define the process by which TRU Waste Program related documents are prepared, reviewed, approved and issued.

<IP_ADDRESS> Document Distribution and Use PRO 1329 DM 03, Site Document Control defines the process used to distribute TRU Waste Program related documents.

<IP_ADDRESS> Document Changes PRO 815 DM 01, Developing and Maintaining Documents defines the change process of TRU Waste Program related documents. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 56 3.1.5 Records QA records are maintained in order to furnish documented evidence that wastes are generated, packaged, inspected, assayed, analyzed, tested, and shipped according to the applicable requirements.

The RFETS Waste Records Center ensures compliance to specific record maintenance requirements through the effective implementation of the RFETS Records System. The record control system ensures the generation, indexing, classification, retrieval, storage and correction of TRU Waste Program related QA records.

<IP_ADDRESS> Records System 1 V41 RM 001, Records Management Manual, PRO 767 WIPP 001, Waste Records Center Processing, and PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center are used to define the RFETS Records System. The Record System ensures compliance with the QAPD for TRU Waste Program related records.

The RFETS procedure for the control of records, 1 V41 RM 001, Records Management Manual, refers generators of TRU Waste Program records to PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center. This procedure provides instructions for maintenance of TRU Waste Program records in compliance with the QAPD.

<IP_ADDRESS> Generating QA Records PRO 767 WIPP 001, Waste Records Center Processing and PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center define the process used to control TRU Waste Program related QA records. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 57 <IP_ADDRESS> Indexing QA Records PRO 767 WIPP 001, Waste Records Center Processing defines the process used to index TRU Waste Program related QA records.

<IP_ADDRESS> Classifying QA Records Records pertaining to the TRU Waste Program are defined by type and are only considered valid records if they are signed and dated by authorized personnel from the applicable organizations. PRO 767 WIPP 001, Waste Records Center Processing defines the process used to classify TRU Waste Program related QA records.

<IP_ADDRESS> Receiving QA Records PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center provides instructions for receipt of QA records by the Waste Records Center.

<IP_ADDRESS> Storage, Preservation, Safekeeping and Disposition of QA Records Procedure PRO 767 WIPP 001, Waste Records Center Processing, provides instructions for the handling of records in the Waste Records Center. A Records Inventory Disposition Schedule ( RIDS) is developed and maintained. PRO 767 WIPP 001, PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center, and RFETS SOP BACKUP 001, Server Backup Standard Operating Procedure provide instructions for the preservation, storage and safekeeping of TRU Waste Program related QA records.

<IP_ADDRESS> Correcting Information in QA Records PRO 077 WIPP 005, Management of Waste Information Prior to Transmittal to the Waste Records Center provides instructions for correction of QA records. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 58 3.2 Performance Requirements 3.2.1 Work Processes Work on the TRU Waste Program is performed according to established technical standards and administrative controls ( procedures) identified in this document and the TWCP QAPjP. Each person supporting the project is responsible for the quality of his or her work and has the goal of doing work correctly the first time. Management of the project has established processes and procedures to ensure that work is planned and performed under controlled conditions by trained personnel; items are maintained to prevent their damage, loss, or deterioration; and equipment used for process monitoring or data collection are calibrated and maintained.

This section further establishes management involvement in the work processes through their interactions with personnel performing the work and through their review and assessment of ongoing and completed work. This will help ensure that the definition of " acceptable work performance" is clearly communicated and that personnel are provided the necessary training, resources, and administrative controls to properly accomplish their tasks. These processes and procedures are identified in this document and the TWCP QAPjP.

<IP_ADDRESS> Work TRU Waste Program work processes are performed through procedures implemented to meet the requirements of the QAPD. Qualified processes and equipment, approved procedures, qualified personnel, and documentation of operating conditions control waste treatment and packaging operations. This assures that waste processing activities are conducted in a consistent, repeatable, and acceptable manner. Waste treatment process control is the responsibility of operations management with technical support provided by the Waste Requirements Group.

Specific control criteria for treated wastes, untreated wastes, and associated waste processes are addressed in this section. PCPs are developed when required in accordance with 1 M60 WPC 001, Waste Process Control. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 59 <IP_ADDRESS> Work ( continued)

Solid Radioactive Waste Packaging  Untreated Wastes Process controls for untreated solid radioactive waste packaging are:

  Physical control of all TRU waste packages using locking fixtures or limited access cages ( including packages used for room trash collection in Radiation Control Areas);

  Controlled access to TRU waste packages, opening packages only during filling, inspection, or repacking operations;

  Approved, revision controlled solid waste packaging procedures, 1 PRO 079 WGI 001, Waste Characterization, Generation, and Packaging; 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual; 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure; and 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions; the W/ RT, the Drum Label or Box Label; and the NDA count sheets;

  Approved, revision controlled WSRIC Building Books issued to Building Operations management;

  Required waste generator Training and OJT for all waste packaging personnel.

  These controls assure that wastes are properly identified, and comply with WIPP WAC and the WIPP WAP.

Waste Treatment or Packaging Processes  Process Control Plans ( PCPs)

Controls that assure waste treatment and packaging operations produce consistent, acceptable wastes are specified in individual PCPs. The PCP requirements supplement general quality assurance program requirements stated in this document. The PCPs are developed by operations management per 1 M60 WPC 001, Waste Process Control.

Process and Equipment Qualification Waste treatment and characterization operations, processes and equipment are tested and qualified before being put into routine production. The governing document for initial equipment installation acceptance is 1 PRO 072 001, Inspection and Acceptance Test Program. Appendix 1, Application of Inspection and Acceptance Testing, of 1 PRO 072 001, Inspection and Acceptance Test Program, provides the template for identifying specific applications ( e. g., Component Checkout ( CC) Testing or Systems Operability ( SO) Testing). TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 60 <IP_ADDRESS> Work ( continued)

Process and Equipment Qualification ( continued)

Any process determined to be a critical treatment process, a final treatment process, or a special process, and which produces a waste form that must meet a requirement, or whose specified quality and conformance of waste cannot be determined readily by inspection or test before shipment, requires a PCP.

The responsible manager of the process being evaluated must determine the need for a PCP or PQP in accordance with 1 M60 WPC 001, Waste Process Control. If necessary, the responsible manager will then coordinate the development of the PQP, performance of the process qualification, and development of the PCP. The end result is a documented, quantified process capability report. The report specifies the required operating parameters, recommends measuring equipment calibration accuracy and precision, and when appropriate recommends control chart monitoring for critical process parameters.

Radioactive Waste Measurement  NDA The NDA process is controlled through: operator training, approved procedures, calibrated instruments, periodic measurement of measurement control samples and evaluation of data, daily instrument checks, and qualification of NDA systems to meet specific data quality objectives.

When subcontractor NDA equipment services are used on the TRU Waste Program the subcontractor is required through the procurement process to document how their processes meet applicable CBFO requirements and WIPP WAC requirements.

See Appendix 4 of this manual for additional details on NDA systems.

<IP_ADDRESS> Implementing Procedures RFETS implementing procedures are developed and maintained according to MAN 001 SDRM, Site Document Requirements Manual; PRO 1329 DM 03, Site Document Control; and PRO 815 DM 01, Developing and Maintaining Documents. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 61 <IP_ADDRESS> Implementing Procedures ( continued)

Instructions, Procedures, and Drawings TRU wastes are collected, treated, processed, packaged, inspected, certified, and loaded for shipment according to written approved instructions, procedures, and drawings. The Site Document Control Program is designed such that Site documents to prescribe processes, specify requirements, or establish design are prepared, reviewed, approved, issued, and controlled for use by personnel managing or performing work..

Supporting Processes Departmental procedures provide detailed instructions for all routine processes associated with waste generation, inspection, test, certification, and shipping activities. Operations management is responsible to develop procedures that adequately describe and control their operations.

In addition to operations management having procedures for their processes, each building has its own WSRIC Building Book. A WSRIC Building Book has all the routine processes for a building listed in it, along with the waste streams associated with that process. Information about the waste stream also includes whether or not the waste produced is Low Level or TRU.

RFETS work controls are provided in MAN 071 IWCP, Integrated Work Control Program Manual, and MAN 066 COOP, Site Conduct of Operations Manual. No WIPP waste characterization requirements are met through controls in MAN 071 IWCP, Integrated Work Control Program Manual, or through MAN 066 COOP, Site Conduct of Operations Manual.

<IP_ADDRESS> Item Identification and Control Identification and/ or traceability of waste streams, waste packages, involved packaging, testing, analytical results, and other items associated with TRU waste management are required. Items such as waste streams and waste packages are uniquely identified from the initial generation or receipt up to and including use, packaging, storage, and transportation to the WIPP. Specific waste characteristics, waste generation sources, applicable chemical analyses, and any inspections, tests, and certifications for wastes are traceable back to the wastes and packages by documentation records maintained in accordance with the records retention requirements of the QAPD. The TWCP QAPjP identifies quality assurance controls for waste characterization performed at RFETS in accordance with the WIPP WAP. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 62 <IP_ADDRESS> Item Identification and Control ( continued)

The key document that records traceability information is the W/ RT ( refer to 1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions). As described in Section 4.3.1, either an electronic W/ RT or a manual W/ RT may be used for packaging activities. The W/ RT data collection form is generated for each waste package and documents the employee numbers of the waste generators, Waste Inspectors, and test technicians directly involved with processing that waste package. The form also documents inspection and test results, waste generation source ( process number), hazardous constituent number ( if applicable), and package serial number. Waste Management personnel control the development of waste identification and characterization information through 1 PRO 079 WGI 001, Waste Characterization, Generation and Packaging. MAN 955 099, Waste Requirements Group Operations Manual, provides instructions for control of the WGI.

Packaging and Waste Segregation Overview The following provides an overview listing of the quality controls implemented to assure TRU waste meets requirements.

  Controlled procedures for waste packaging, segregation, inspection, assay, transportation, processing, testing, and certification.

  Training and qualification of waste generators and waste handlers involved in repackaging, sampling and visual examination processes, Waste Inspectors, NDA Operators, Nondestructive Test ( NDT) technicians, and other TRU Waste Program personnel.

  Completed, documented, and characterized RFETS waste streams published in the WSRIC Building Books.

  For routinely generated wastes, documented traceability of each item placed in a waste package to the generation point represented by the unique WSRIC process number.

  Accountability of individual waste package segregation, characterization, and traceability documentation to the person( s) responsible.

  Waste reassessments for wastes not identified by a WSRIC process number.

  TRU waste package access control during all phases of waste generation, packaging, and handling using locked packages and qualified package custodians.

  100% verification of package content compliance achieved by utilizing the waste generator and a waste verifier during fill operations. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 63 <IP_ADDRESS> Item Identification and Control ( continued)

Packaging and Waste Segregation Overview ( continued)

  Independent in process sample inspection of waste packages and contents.

  Independent 100% waste package integrity and W/ RT completeness inspections.

  RTR of waste package contents ( when required by the WIPP WAP).

  Routine, systematic surveillance of TRU Waste Program activities.

  Independent audit of TRU Waste Program activities to Quality Assurance Program requirements.

  Sampling and analysis ( as applicable) of TRU waste to demonstrate compliance to the WIPP WAP and the WIPP WAC.

The Uniform Hazardous Waste Manifest records the EPA Hazardous Waste Numbers ( EPA HWNs) and other required information for RCRA regulated hazardous wastes. More specific definitions of traceable control numbers are defined below.

Content Code The content code is a unique, alpha numeric code which identifies the generator site, the generator's waste stream, and the TRUPACT II package contents, to personnel at the WIPP. The content codes are established and controlled by DOE WIPP. A list of all shipping content codes can be found in the TRUCON document, DOE/ WIPP 89 004.

Item Description Code ( IDC) Number The IDC number is a three or four digit number assigned to a waste form type, such as plastics, dry combustibles, light metals, etc. These numbers provide accountability, allow for segregation of wastes into identifiable forms for ease of processing, and when assessing nuclear material content during NDA. The IDCs from each of the ten DOE sites are translated into content codes so that waste streams can be uniformly identified. Approved waste IDCs are documented in 1 M12 WO 4034, Solid Radioactive Waste Packaging Requirements Manual. If a new TRU/ TRM related IDC is created, approval from the Site Nuclear Material Control group is required. A list of RFETS IDCs that have been assigned a content code and that meet the WIPP WAC is contained in Section 6 of this document. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 64 <IP_ADDRESS> Item Identification and Control ( continued)

Process Number The process number designates the unique RFETS location that generated the wastes. Each building has a complete listing of the waste generating processes published in the applicable WSRIC Building Book.

Chemical Constituent Code The Chemical Constituent Code ( CCC) is a two character alpha or numeric designator used to identify chemical constituents associated with a particular waste stream. The numbers are defined by Waste Systems for use by waste generators in identifying and segregating wastes. RCRA CCCs identify constituents in the waste stream which are RCRA regulated. Non RCRA CCCs identify constituents in the waste stream which are not RCRA regulated.

EPA Hazardous Waste Number NOTE: WRG prepares WGIs to communicate waste characterization ( including HWNs) and packaging requirements to waste generators at the floor level. Acceptable Knowledge ( AK) is re evaluated at the Project Level based on confirmatory testing ( e. g., RTR, headspace gas sampling, and/ or solid sampling) as described in the TWCP QAPjP, Section B4. Prior to shipment, waste package information is reviewed and certified by the WCO.

The EPA HWN is required by Title 40 CFR, Part 261, Subparts C and D. This number indicates the characteristic wastes, the nonspecific source wastes, the specific source wastes, and the commercial chemical products that are regulated as hazardous waste under this statute. This number is recorded on each package on the Hazardous Waste Label. The waste generator is responsible for assigning the EPA HWN to all waste packages.

Waste Package Numbers Waste packages are assigned a unique number with bar code as they are issued to waste generator organizations. Three identical bar code labels are attached to the drum under the drum ring approximately 120 degrees apart. Bar codes are applied to the flat sides of the SWBs. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 65 <IP_ADDRESS> Item Identification and Control ( continued)

Tamper Indicating Device ( TID) Number The TIDs are strips of mylar tape imprinted with a unique bar code number. The TIDs are attached to all sealed drums and SWBs containing Special Nuclear Material ( Pu isotopes). The tape cannot be removed without visible damage to the TID. The Nuclear Material Control department controls the issue of TIDs per MAN 010 MCA, Materials Control and Accountability Manual and 4 P16 SA TID 001, Tamper Indicating Devices ( TIDs).

Material Transfer and Storage Label The Material Transfer and Storage Label ( RF 46148, sometimes referred to as a " Checkerboard Label") or an alternate method, as specified in 4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure, is used to identify individual waste items. Each waste item will have a checkerboard label placed on it. The label has a block for an identification number. The waste generator is responsible for assigning and recording this number on the label and on the appropriate block on the W/ RT.

Employee Numbers The unique employee numbers of waste generators, Waste Inspectors, RTR operators, NDA counter operators, Radiation Control Technologists, and others are recorded during each stage of waste processing on the W/ RT and other associated documents. Sub contractor personnel use Site Wide Personnel Locator numbers in lieu of the employee number.

Radioactive Material Tag/ Label The Radioactive Material Tag/ Label ( form RF 46751) is applied to the exterior of waste drums or boxes. Requirements for this label are defined in the Site Radiological Control Manual.

Other Procedures for Item Identification and Control The RFETS procedure providing requirements for controlling items is as follows:

  1 A67 QAP 08.01, Identification and Control of Items. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 66 <IP_ADDRESS> Special Processes Special processes are those processes whose results are highly dependent on control of process, the skill of the operator and/ or processes where inspection or testing of results is not performed easily. Listed below are the applicable special processes associated with the TRU waste programs.

Real Time Radiography ( RTR)

RTR is designated as a " special" process due to the skill required to accurately interpret radiographs of sealed waste packages. The RTR operators must be certified prior to conducting waste package radiography. Training and certification of RFETS RTR operators is conducted by the NDT department in accordance with 5 NDT TC 1A, Training, Qualification, and Certification of Nondestructive Testing Personnel. Training and certification of mobile RTR operators is conducted in accordance with the mobile vendor training plan. RTR procedures contain instructions for performing verifications of waste packages and packages contents using RTR. See the TWCP QAPjP, Sections B1 3, B1 7, B3 4, B3 10, and B3 12 for details.

Leak Testing of the TRUPACT II Package TRUPACT II package helium leak testing is designated as a " special" process since the effectiveness of the test is based on operator knowledge, which is obtained through formalized training. Procedure PRO 1419 WO LKTST, TRUPACT II Shipping Leak Test, contain instructions for performing a verification leak test on the TRUPACT II package. NDA leak test operators are trained and certified by the NDT department in accordance with 5 NDT TC 1A, Training, Qualification, and Certification of Nondestructive Testing Personnel.

<IP_ADDRESS> Handling, Storage and Shipping The following are the primary procedures for controlling the marking, handling, storage, labeling, staging, and shipping of waste packages in order to prevent damage or loss, to minimize deterioration, and to assure safety of operations:

  1 PRO Q11 WO 1221, Controls for Updating Waste Package Information in WEMS   4 D99 WO 1100, Solid Radioactive Waste Packaging Procedure   1 PRO 079 WGI 001, Waste Characterization, Generation and Packaging   1 C80 WO 1102 W/ RT, Waste/ Residue Traveler Instructions   MAN 010 MCA, Materials Control & Accountability Manual TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 67 <IP_ADDRESS> Handling, Storage and Shipping ( continued)

  MAN T91 STSM 001, Site Transportation Safety Manual.

  Waste generators, Waste Inspectors, custodians, field technicians, and certification officials verify and document compliance to these procedures from the initial point of generation to final disposal.

  Marking and labeling requirements for off site shipment are defined in PRO T13 Traffic 306, Labeling and Marking TRUPACT Packages.

Handling and Storage TRU wastes are stored in RFETS approved and designated areas. Mixed TRU waste is stored in RCRA Part B permitted storage areas. Wastes that are scheduled for off site shipment are processed through the Building 664 and Building 440 staging areas by Waste Operations personnel. Nuclear Material Control personnel authorize and track the movement of nuclear material throughout RFETS. Dock inspection, RTR verification, document review, and storage are conducted in accordance with established procedures, drawings, and specifications. Procedure PRO 1418 WO TRUOP, TRUPACT II Operations, describes the physical handling and loading of waste packages into the TRUPACT II for off site shipment.

Waste Shipping The Traffic Management department coordinates the off site shipment of TRU waste to the WIPP disposal site. All TRU waste shipments consigned to the WIPP will be made in accordance with applicable DOT, EPA, WIPP WAP, state, and local hazardous waste regulations, including WIPP transportation requirements and applicable requirements of the Certificate of Compliance. Procedures for waste transfer are specified in MAN T91 STSM 001, Site Transportation Safety Manual and Traffic Management procedures ( e. g., PRO T43 Traffic 528, TRUPACT II Operations).

Regulated wastes are collected in three areas: satellite collection areas, 90 day accumulation areas, and permitted storage areas. Management of RFETS hazardous waste storage areas complies with federal requirements 40 CFR Parts 262, 264, and 265 and the associated Colorado State requirements in 6 CCR 1007 3 Parts 262, 264, and 265. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 68 <IP_ADDRESS> Handling, Storage and Shipping ( continued)

Waste Shipping ( continued)

The satellite and 90 day waste collection areas are managed by KH. A master list of the waste collection areas is maintained. This list includes information on the location of the area, the waste that can be managed in the area, and the responsible individual. Any modification to the existing storage areas should be coordinated with KH.

The CDPHE RCRA Part A and Part B Permits discuss interim status and permitted units that exist at RFETS. These documents give detailed information on the location, material types, and quantities of hazardous wastes that reside at RFETS. KH   Environmental Systems and Stewardship is responsible for ensuring that the Part A and the Part B permits are accurate and contain current information. This responsibility includes drawings of the permitted storage units. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 69 3.2.2 Design Control Design processes are controlled through RFETS procedures and processes identified in 1 V51 COEM DES 210, Site Engineering Process Procedure. The TRU Waste Program does not perform design. See Section 4.6.3 for explanatory information regarding design control as it applies to the POC.

Facilities and Equipment Engineering provides engineering design packages and configuration control of facilities and equipment. This includes maintenance of existing equipment and installation of new equipment and facilities. The Engineering department prepares engineering packages including technical drawings and associated specifications. Engineering maintains and archives associated records. An overview of the engineering process is provided in MAN 027 SERM, Site Engineering Requirements Manual.

Radiation Detection Instruments RFETS does not design radiation detection instruments. However, RFETS does utilize radiation detection instruments in designed systems. The Radiation Instrumentation department maintains control of portable assay equipment and concurs with system design drawing changes when the design includes the use of radiation detection instruments. Design control for the use of radiation detection instruments in designed systems is specified in RFETS engineering documents.

Radioactive Assay Equipment Nondestructive assay equipment is purchased from commercial vendors according to specifications developed by Measurements. Measurements maintains all drawings and maintenance records. See Appendix 4 for additional details on NDA systems.

Design control of NDA equipment is maintained by:

  Facilities Engineering through the use of configuration control and design control procedures; and   Nondestructive Assay through the selection, validation and qualification of NDA counters and associated documentation. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 70 3.2.3 Procurement Procurement documents address design, fabrication, and quality assurance requirements, and are reviewed by appropriate organizations, disciplines, and subject matter experts to assure they contain adequate scope of work, technical requirements, supplier quality assurance program requirements and provisions for acceptance.

The Procurement Engineering and Quality Assurance organization ensures that suppliers of materials and items are evaluated, approved, and continually verified based on adequate criteria. The Procurement organization supports the RFETS TRU Waste Program by establishing a procurement system that ensures materials and items perform as specified and comply with applicable regulatory, technical and quality requirements.

The procurement system ensures compliance to the following specific requirements: control of procurement documentation, procurement planning, supplier selection, proposal/ bid evaluation, supplier performance evaluations, acceptance of items or services, and control of nonconforming and commercial grade items.

<IP_ADDRESS> Procurement Planning MAN 134 PPM, Procurement Program Manual defines the procurement planning activities.

<IP_ADDRESS> Supplier Selection 1 J55 ADM 08.10, Subcontractor Quality Evaluations defines the methods for the performance of quality assurance evaluation activities. TRANSURANIC ( TRU) WASTE 1 MAN 008 WM 001 MANAGEMENT MANUAL VERSION 7 02/ 12/ 2004 PAGE 71 <IP_ADDRESS> Proposal/ Bid Evaluation The procurement initiating organization is responsible for developing procurement requisitions for waste commodities in accordance with MAN 134 PPM, Procurement Program Manual. Metrology reviews requisitions for test and measuring equipment after the procurement specifications are generated per MAN 134 PPM, Procurement Program Manual.