concentration of target analytes in the calibration standards is listed
in Section 4 of L-42151.  The concentration of the continuing
calibration standard is also less than the PRQL, as specified in the
same section.

B3-7g	Completeness

Laboratory completeness shall be expressed as the number of samples
analyzed with valid results as a percent of the total number of samples
submitted for analysis.  Valid results are defined as results that meet
the data useability criteria based upon application of the Quality
Control Criteria specified in Tables B3-6 and B3-7 and meet the
detection limit, calibration, representativeness, and comparability
criteria within this section.  The laboratory procedure L-42151 includes
strict QC controls to ensure that valid results are obtained for all
sample analyses.  The QC controls are described in the laboratory
procedure.  During the validation of Batch Data Reports by procedure
L-4039, WIPP Data Review and Validation for Semivolatile Organic
Compounds in Solid Samples1 (referred to in this section as L-4039)
completeness is checked and compared to the criteria listed in Table
B3-6.  If the observed completeness is not compliant, corrective action
is taken.  The laboratory will attempt to resolve the problem causing
the non-compliance.  If not possible, a nonconformance will be written.

For RFETS waste analyzed at INEEL, laboratory completeness is evaluated
by the RFETS TWCP Site PQAO. If the observed completeness is not
compliant, corrective action is taken.

B3-7h	Comparability

Consistent use and application of uniform procedures (e.g., standardized
methods traceable standards, etc.) as specified in Section B1 of this
document, and application of data usability criteria [refer to EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999); and EPA 540-R-01-008,
USEPA Contract Laboratory Program National Functional Guidelines for
Inorganic Data Review (EPA 2002)] should ensure that analytical data are
comparable between different analytical facilities.

The laboratory achieves comparability by following standardized methods:

The laboratory analysis is performed by following procedures L-4214
(preparation); and L-42151 (analysis).  These procedure are based upon
SW-846 Methods 3540, 8270, and Method 8082, and meets the QC
requirements listed in Table B3-7.  The most recent promulgated version
of SW-846 may be used.  Changes to SW-846 methodology that result in the
elimination of sample preparation or analytical methods in use at RFETS
are addressed as a corrective action to address the comparability of
data before and after the SW-846 modification.

Batch Data Report verification and validation is performed by following
procedure L-40391 which follows the process outlined in B3-10 of the
WAP.  Completeness is checked and compared against the QAOs listed in
Table B3-6.

Using traceable standards;  As part of the procedure L-42151 the
laboratory uses certified, traceable standards to prepare all QC
standards and solutions.  The source of standards is documented and the
certificates of analysis maintained in the certified standards notebook.

Successful participation in the PDP.

B3-7i	Representativeness

Representativeness for SVOC analysis is achieved by collecting unbiased
samples, which is addressed in Section B1-2.

B3-8	Total or TCLP Metal Analysis

B3-8a	Quality Assurance Objectives

The QAOs for the TWCP are listed in Table B3-8.  The specified QAOs
represent the required quality of data necessary to draw valid
conclusions regarding TWCP objectives.  QC measurements are used to
demonstrate acceptable method performance and to trigger corrective
action when control limits are exceeded.  A summary of Quality Control
Samples and the associated acceptance criteria are provided in Table
B3-9.  Table B-1 contains a synopsis of the site-specific procedures
used for total metals analysis.  The site-specific processes used to
ensure that the QAOs are met and to assess the data quality indicators
for compliance with the QAOs are discussed below.

Procedures implemented to ensure total metals analysis conducted at
INEEL meets quality assurance objectives are described in the Attachment
to the SOW for the INEEL TWCP (DOE 2003a).

B3-8b	Precision

Precision is assessed through the analysis of laboratory sample
duplicates or laboratory matrix spike duplicates, replicate analyses of
laboratory control samples, and PDP blind-audit samples.  The results of
QC samples are compared to the criteria listed in Tables B3-8 and B3-9.
These QC measurements are used to demonstrate acceptable method
performance and to trigger corrective action when control limits are
exceeded.

Initially, precision is assessed for WIPP samples by preparing and
analyzing a minimum of 7 replicate method performance samples prior to
using the metals analytical procedures L-4150, Total Metals Acid
Digestion Procedure of Solid, Liquid, and TCLP Extract Sampler; L-4151,
Waste Analysis by Atomic Absorption Spectroscopy1; L-4152, Mercury
Analysis in Waste (Cold-Vapor Technique)1; and L-4153, Trace Metals by
ICP Spectrometry (Solids, Liquids, and TCLP Extracts)1 (referred to in
this section as L-4150, L-4151, L-4152, and L-4153, respectively).  The
percent Relative Standard Deviation (%RSD) is calculated for the
replicate analyses and compared to the precision criteria in Table B3-8.
 The %RSD must comply with the criteria before the procedure can be used
to analyze WIPP samples.  These initial analyses fulfill the requirement
for “Method Performance Samples” listed in Table B3-9.

With every sample batch, a MS/MSD sample pair is analyzed.  The
precision within a sample batch is assessed by calculating a relative
percent difference (%RPD) between the MS and MSD results.  The %RPD must
comply with the criteria in Table B3-8.  If the %RPD is not within the
criteria, corrective action is taken.  If the poor precision is traced
to the sample matrix, sample data is flagged with a “Z”, as directed
in WAP Section B3-10 (a nonconformance report is not required when the
problem is traced to the matrix, as specified in Table B3-9).

As implied in Table B3-9, a separate laboratory duplicate analysis is
not required when a MS/MSD pair is analyzed; hence laboratory duplicates
are not used to assess precision.

Laboratory control samples are analyzed with each batch of samples.   On
a semi-annual basis, the precision of the procedure is assessed by
calculating a %RSD using the data from the last four laboratory control
samples analyzed.  The %RSD must comply with the criteria in Table B3-8.
 If the precision is not acceptable, the cause must be determined and
corrective action performed.  Further analyses cannot be performed until
acceptable precision is demonstrated through additional replicate
analyses of a laboratory control sample.  These analyses fulfill the
requirement for “Method Performance Samples” listed in Table B3-9.

The laboratory also analyzes PDP blind audit samples.  If notified that
the precision of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
precision is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

B3-8c	Accuracy

Accuracy is assessed through the analysis of laboratory matrix spikes,
PDP blind-audit samples, serial dilutions, interference check samples,
and laboratory control samples.  The results of QC samples are compared
to the criteria listed in Tables B3-8 and B3-9.  These QC measurements
are used to demonstrate acceptable method performance and to trigger
corrective action when control limits are exceeded.

Initially, accuracy is assessed prior to using the analytical procedures
L-4150, L-41511, L-41521, and L-41531 for WIPP samples by preparing and
analyzing a minimum of seven replicate method performance samples.  The
average percent recovery (%R) is calculated for the replicate analyses
and compared to the accuracy criteria in Table B3-8.  The %R must comply
with the criteria before the procedure can be used to analyze WIPP
samples.  These initial analyses fulfill the requirement for “Method
Performance Samples” listed in Table B3-9

With every sample batch, a MS/MSD sample pair is analyzed.  The accuracy
within a sample batch is assessed by calculating the %R for the MS and
MSD result.  The %R must comply with the criteria in Table B3-8.  If a
%R is not within the criteria, corrective action is taken.  If the poor
accuracy is traced to the sample matrix, sample data is flagged with a
“Z”, as directed in WAP Section B3-10 (a nonconformance report is
not required when the problem is traced to the matrix, as specified in
Table B3-9).

The accuracy within a sample batch is also assessed by calculating the
%R for the LCS, which is analyzed with each batch of samples.  The %R
must comply with the criteria in Table B3-8.  If the %R is not within
the criteria, corrective action is taken.  Samples associated with the
poor LCS must be re-analyzed when the problem is corrected, if the
usability of the results is impacted by the poor LCS recovery.
Additionally, on a semi-annual basis, the accuracy of the procedure is
assessed by calculating a %R using the data from the last four
laboratory control samples analyzed.  The %R must comply with the
criteria in Table B3-8.  If the accuracy is not acceptable, the cause
must be determined and corrective action performed.  Further analyses
cannot be performed until acceptable accuracy is demonstrated through
additional replicate analyses of a laboratory control sample.  These
analyses fulfill the requirement for “Method Performance Samples”
listed in Table B3-9.

For ICPES analyses, serial dilution and interference check samples are
analyzed and the accuracy of the results assessed.  The %D between the
results from a sample and its serial dilution is calculated.  It
provides an indication of matrix effects on accuracy.  If the %D values
do not meet the criteria listed in L-41531 a matrix effect is inferred
and the data is flagged with a “Z”.  The criteria listed in L-41531
are based upon the criteria listed in SW-846, Method 6010.  A
nonconformance report is not required because the problem is due to the
matrix.  The %R for target compounds in the interference check sample is
calculated and compared to the criteria listed in L-41531, which are
based upon the criteria listed in SW-846 Method 6010.  The %R values
must be acceptable.  If not, the problem must be corrected and the
affected samples re-analyzed.  If data is reported from an analytical
run with unacceptable %R values, a nonconformance report must be
prepared.

The laboratory also analyzes PDP blind audit samples.  If notified that
the accuracy of the PDP analyses is not acceptable, corrective action
will be taken.  Further analyses cannot be performed until acceptable
accuracy is demonstrated through additional replicate analyses of a
laboratory control sample, or acceptable analysis of additional PDP
samples.

Laboratory blanks and calibration blanks shall be assessed to determine
possible laboratory contamination and are evaluated as specified in
Table B3-9.  These QC measurements will be used to demonstrate
acceptable levels of laboratory contamination and to trigger corrective
action when control limits are exceeded.

B3-8d	Calibration

Mass tunes (for ICP MS only), standards calibration, initial calibration
verifications, and continuing calibrations are performed and evaluated
using the procedures and criteria specified in Table B3-8 and Table
B3-9.  These criteria are used to demonstrate acceptable calibration and
to trigger corrective action when control limits are exceeded.

Initial and continuing calibration are performed as specified in L-4151,
L-41521, and L-41531.  These methods follow the guidance provided in
SW-846 Methods 7742, 7471, and 6010, respectively.  The methods include
acceptance criteria and corrective action to demonstrate that the
calibration for an analytical run is acceptable (Section 5 in each
site-specific L procedure).

B3-8e	Program Required Detection Limits

The IDLs for each of the target metals are determined semi-annually by
the appropriate method, as described in L-41511 (Se), L-41521 (Hg), and
L-41531 (Ag, As, Ba, Be, Cd, Cr, Ni, Pb, Sb, Se, Tl, V, Zn).  The IDLs
must be less than or equal to the PRDLs listed in Table B3-8.  If not,
the metal cannot be reported from that method.  An exception is made for
selenium determined by L-41531.  If the selenium concentration is
greater than 5 times the L-4153 IDL, it can be reported from L-4153.

B3-8f	Program Required Quantitation Limit

The laboratory meets the PRQL requirement by following the analytical
procedures L-41511, L-41521, and L-41531.  At least one of the
calibration standards is set at a concentration less than the PRQLs
listed in Table B3-8 (corrected for nominal dilution).  Procedure
L-41531 (Section 5.7) specifies that a CRDL standard be analyzed with
each analytical run, which has target concentrations set at less than
the PRQL (corrected for nominal dilution).

B3-8g	Completeness

Laboratory completeness shall be expressed as the number of samples
analyzed with valid results as a percent of the total number of samples
submitted for analysis.  Valid results are defined as results that meet
the data useability criteria based upon application of the Quality
Control Criteria specified in Tables B3-8 and B3-9 and meet the
detection limit, calibration, representativeness, and comparability
criteria within this section.  The laboratory procedures L-41511,
L-41521, and L-41531 include strict QC controls to ensure that valid
results are obtained for all sample analyses.  The QC controls are
described in the laboratory procedure.  During the validation of Batch
Data Reports by procedure L-4035, Metals Data Verification and
Validation Data Generation Level1 (referred to in this section as
L-4035), completeness is checked and compared to the criteria listed in
Table B3-8.  If the observed completeness is not compliant, corrective
action is taken.  The laboratory will attempt to resolve the problem
causing the non-compliance.  If not possible, a nonconformance will be
written.

For RFETS waste analyzed at INEEL, laboratory completeness is evaluated
by the RFETS TWCP Site PQAO. If the observed completeness is not
compliant, corrective action is taken.

B3-8h	Comparability

Consistent use and application of uniform procedures (e.g., standardized
methods traceable standards, etc.) as specified in Section B1 of this
document, and application of data usability criteria [refer to EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999); and EPA 540-R-01-008,
USEPA Contract Laboratory Program National Functional Guidelines for
Inorganic Data Review (EPA 2002)] should ensure that analytical data are
comparable between different analytical facilities.

The laboratory achieves comparability by following standardized methods:

The laboratory sample preparation and analysis is performed by following
procedures L-4108, L-41501, L-41511, L-41521, and L-41531.  These
procedures are based upon SW-846 Methods 1131, 3050, 7742, 7741, and
6010, and meet the QC requirements listed in Table B3-8.  The most
recent promulgated version of SW-846 may be used.  Changes to SW-846
methodology that result in the elimination of sample preparation or
analytical methods in use at RFETS are addressed as a corrective action
to address the comparability of data before and after the SW-846
modification.

Batch Data Report verification and validation is performed by following
procedure L-40351, which follows the process outlined in B3-10 of the
WAP.  Completeness is checked and compared against the QAOs listed in
Table B3-9.

Using traceable standards;  As part of the procedures L-41511, L-41521,
and L-41531, the laboratory uses certified, traceable standards to
prepare all QC standards and solutions.  The source of standards is
documented and the certificates of analysis maintained in the certified
standards notebook.

Successful participation in the PDP program.

B3-8i	Representativeness

Representativeness for metals analysis is achieved by collecting
unbiased samples and the preparation of samples in the laboratory using
representative and unbiased methods.  Samples are collected as described
in Section B1-2.

B3-9	Acceptable Knowledge

Acceptable knowledge documentation provides primarily qualitative
information that cannot be assessed according to specific data quality
goals that are used for analytical techniques.  QAOs for analytical
results are described in terms of precision, accuracy, completeness,
comparability, and representativeness.  Appropriate analytical and
testing results are used to confirm the characterization of wastes based
on acceptable knowledge (refer to Section B4-3 and Section B4-4). To
ensure that the acceptable knowledge process is consistently applied,
RFETS to complies with the following data quality requirements for
acceptable knowledge documentation:

Precision - Precision is the agreement among a set of replicate
measurements without assumption of the knowledge of a true value.  The
qualitative determinations, such as compiling and assessing acceptable
knowledge documentation, do not lend themselves to statistical
evaluations of precision.  However, the acceptable knowledge information
will be addressed by the independent review of acceptable knowledge
information during internal and external audits.

Accuracy - Accuracy is the degree of agreement between an observed
sample result and the true value.  The percentage of waste containers
which require reassignment to a new Waste Matrix Code and/or designation
of different hazardous waste codes based an the reevaluation of
acceptable knowledge and sampling and analysis data will be reported as
a measure of acceptable knowledge accuracy.

Completeness - Completeness is an assessment of the number of waste
streams or number of samples collected to the number of samples
determined to be useable through the data validation process.  The
acceptable knowledge record must contain 100 percent of the required
information (Permit Attachment B4-3).  The usability of the acceptable
knowledge information will be assessed for completeness during audits.

Comparability - Data are considered comparable when one set of data can
be compared to another set of data.  Comparability is ensured through
the various sites meeting the training requirements and complying with
the minimum standards outlined for procedures that are used to implement
the acceptable knowledge process.  All sites must assign hazardous waste
codes in accordance with Permit Attachment B4-4 and provide this
information regarding its waste to other sites that store or generate a
similar waste stream.

Representativeness - Representativeness expresses the degree to which
sample data accurately and precisely represent characteristics of a
population.  Representativeness is a qualitative parameter that will be
satisfied by ensuring that the process of obtaining, evaluating, and
documenting acceptable knowledge information is performed in accordance
with the minimum standards established in Permit Attachment B4.  Sites
also must assess and document the limitations of the acceptable
knowledge information used to assign hazardous waste codes (e.g.,
purpose and scope of information, date of publication, type and extent
to which waste parameters are addressed).

RFETS complies with the nonconformance notification and reporting
requirements of Section B3-1 if the results of confirmatory analytical
techniques specified in Section B are inconsistent with acceptable
knowledge documentation.

RFETS addresses quality control by tracking its performance with regard
to the use of acceptable knowledge by: 1) assessing the frequency of
inconsistencies among information, and 2) documenting the results of
acceptable knowledge confirmation through RTR, visual examination,
headspace gas analyses, and solidified waste analyses.  In addition, the
acceptable knowledge process and waste stream documentation are
evaluated through internal assessments by quality assurance
organizations and assessments by auditors external to the organization.

B3-10	Data Review, Validation, and Verification Requirements

Procedures exist for the review, validation, and verification of data at
the data generation level and the validation and verification of data at
the project level.

As described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a), the INEEL TWCP conducts the data generation level data review,
validation, and verification activities for RFETS waste solid sampled
and analyzed at INEEL.

Data review determines if raw data have been properly collected and
ensures raw data are properly reduced.  Data validation confirms that
the data reported satisfy the requirements of the WIPP-WAP and is
accompanied by signature release.  Data verification authenticates that
data as presented represent the sampling and analysis activities as
performed and that the data have been appropriately reviewed.

Data from testing, sampling, and analytical operations is compiled at
the generation level, and reported to the TWCP Project Office as
testing, sampling, or analytical batch reports.  Batch Data Reports are
generated for data validation, verification, and quality assurance
activities.

There are three types of Batch Data Reports validated at the project
level as follows:

A Testing Batch Data Report or equivalent includes all data pertaining
to any of the following:

	Radiography

Visual Examination (to Confirm RTR)

Visual Verification of AK

Radioassay [refer to the TWMM, Appendix 4]

Note:  Radioassay Batch Data Reporting requirements are specified in the
WIPP-WAC.  RFETS compliance with these requirements for NDA are
addressed in the TWMM.

A Testing Batch Data Report or equivalent includes all data for up to 20
waste containers without regard to waste matrix.  Table B3-11 lists the
information required in Testing Batch Data Reports (identified with an
“X”), and lists other information that is necessary for data
validation, but is optional in Testing Batch Data Reports (identified
with an “O”).

A Sampling Batch Data Report or equivalent includes all sample
collection data pertaining to a group of no more than 20 headspace gas
or homogeneous waste samples that were collected for chemical analysis.
Table B3-12 lists the information required in Sampling Batch Data
Reports (identified with an “X”), and lists other information that
is necessary for data validation, but is optional in Sampling Batch Data
Reports (identified with an “O”).

B3-10	Data Review, Validation, and Verification Requirements
(continued)

An Analytical Batch Data Report or equivalent includes analytical data
from the analysis of TRU-mixed waste for up to 20 headspace gas or
homogeneous waste samples.  Analytical Batch Data Reports or equivalent
that contain results for composited headspace gas samples must contain
sufficient information to identify the containers that were composited
for each composite sample and the sample volume that was taken from each
waste container.  Because Analytical Batch Data Reports are generated
based on the number of samples analyzed, an Analytical Batch Data Report
may contain results that are applicable to more than 20 containers
depending on how many composite samples are part of the report, but may
not exceed a total of 20 samples analyzed. Table B3-13 lists the
information required in Analytical Batch Data Reports (identified with
an “X”), and lists other information that is necessary for data
validation, but is optional in Analytical Batch Data Reports (identified
with an “O”).

Raw analytical data need not be included in Analytical Batch Data
Reports, but must be maintained in project files and be readily
available for review upon request.  Raw data may include all analytical
bench sheet and instrumentation readouts for all calibration standard
results, sample data, QC samples, sample preparation conditions and
logs, sample run logs, and all re-extraction, re-analysis, or dilution
information pertaining to the individual samples. Raw data may also
include calibration records and any qualitative or semi-quantitative
data collected for a sample and that has been recorded on a bench sheet
or in a logbook.

On-line Batch Data Reports or equivalent contain the combined
information from the Sampling Batch Data Report and Analytical Batch
Data Report that is relevant to the on-line method used. An On-Line
Sampling Data Report or equivalent includes all field data pertaining to
a group of  samples collected within a 12-hour period using the same
on-line integrated analysis system.  An On-Line Analytical Batch Data
Report or equivalent includes analytical and on-line data from the
sampling and analysis of samples collected within a 12-hour period using
the same on-line integrated analysis system.

B3-10a	Data Generation Level

The following are the minimum requirements for raw data collection and
management:

All raw data are signed and dated in reproducible ink by the person
generating the data, or an unalterable electronic signature is used.
For instrument printouts, the data generator is identified on the
printout.

All data are recorded clearly, legibly, and accurately in field and
headspace or laboratory records (bench sheets, logbooks, or qualified
electronic format), and include applicable sample identification numbers
(for sampling and analytical labs).

Any changes to original data are lined out, initialed, and dated by the
individual making the change; a justification for changing the original
data may also be included (if not readily apparent); the original data
is not obliterated or otherwise disfigured so as not to be readable; and
data changes are made by the individual who originally collected the
data or an authorized supervisory representative from the same
department.

B3-10a	Data Generation Level (cont)

All data are transferred and reduced from field and headspace or
laboratory records completely and accurately.

All field and headspace or laboratory records are maintained in
permanent files as specified in Table B-7 of this document.

Data are organized into a standard format for reporting purposes (Batch
Data Report), as outlined in specific sampling and analytical
procedures.

All electronic and video data are stored appropriately to ensure that
waste container data, sample data, and associated QC data are
retrievable.  In the case of classified information, additional security
provisions may apply that could restrict retrievability.  The additional
security provisions are documented in RFETS procedures as outlined in
this QAPjP in accordance with 1-MAN-026, Rocky Flats Environmental
Technology Site Security Manual.

Data review, validation, and verification at the data generation level
involves scrutiny and signature release from qualified independent
technical reviewer(s), technical supervisor(s), and a QA Officer (or
designee) as specified below.  Nonconformances identified during data
validation and verification at the generation level are documented using
1-A65-ADM-15.01, Control of Nonconforming Items.  Individuals conducting
this data review, validation, and verification must use approved
checklists that address all of the items included in this section.
Checklists contain or reference tables showing the results of sampling,
analytical or on-line batch QC samples, if applicable.  Checklists
reflect review of all QC samples and quality assurance objective
categories in accordance with criteria established in Tables B3-2
through B3-9 (as applicable to the methods validated).  Completed
checklists are forwarded with Batch Data Reports to the project level.
Analytical data must be available and reviewed by the data generation
level reviewer.

Changes to Batch Data Reports, occurring after submittal to the Waste
Records Center, which impact characterization data will require
re-evaluation.  Inconsistencies, mistakes, or omissions identified in
Batch Data Reports that do not impact characterization data do not
require re-verification by the data generation level QA Officer (or
designee). Inconsistencies, mistakes, or omissions identified in Batch
Data Reports that impact characterization data (this includes
Nonconformances with a use-as-is disposition) shall be re-evaluated by
the Technical Supervisor and data generation level QA Officer (or
designee).  Nonconformances with rework disposition issued to Batch Data
Reports shall be revalidated by an Independent Technical Reviewer,
Technical Supervisor, and data generation level QA Officer (or
designee).  Nonconformances with scrap disposition issued to Batch Data
Reports do not require data generation level revalidation.

Data generation level review, validation, and verification for RFETS
waste sampled and analyzed at INEEL is conducted as described in the
Attachment to the SOW for the INEEL TWCP (DOE 2003a).  Batch Data Report
and raw analytical data submittal to the RFETS TWCP, and changes to
Batch Data Reports, are transmitted in hard copy format.

Table B-1 provides a list of procedures used to implement the
requirements of this section.  The list is not comprehensive.
Additional procedures are found in Section D-2, RFETS References.

B3-10a(1)	Independent Technical Review

The independent technical review ensures by review of raw data that data
generation and reduction are technically correct; calculations are
verified correct; deviations are documented; and QA/QC results are
complete, documented correctly, and compared against WIPP-WAP criteria.
This review validates and verifies all of the work documented by the
originator.

One hundred percent of the Batch Data Reports receive a documented
independent technical review.  This review is performed by an
individual, other than the data generator, who is qualified to have
performed the initial work.  This review is performed as soon as
practicably possible in order to determine and correct negative quality
trends in the sampling or analytical process.  However, at a minimum,
the independent technical review must be performed before any waste
associated with data reviewed is shipped to the WIPP facility.  The
reviewer(s) release the data as evidenced by signature.  This signature
release ensures the following:

Data generation and reduction were conducted in a technically correct
manner in accordance with the method used (procedure with revision or
version).  Data was reported in the proper units and correct number of
significant figures.

Calculations have been verified by a valid calculation program, a spot
check of verified calculation programs, and/or 100% check of all hand
calculations.  Values that are not verified to within rounding or
significant difference discrepancies must be rectified prior to
completion of the independent technical review.

The data were reviewed for transcription errors.

The testing, sampling, or analytical data QA documentation for Batch
Data Reports is complete and includes, as applicable, raw data, DAC and
equilibrium calculations and times, calculation records, COC forms,
calibration records, QC sample results, and copies or originals of the
gas canister sample tags.  Corrective action is taken to ensure that all
Batch Data Reports are complete and include all necessary raw data prior
to completion of the independent technical review.

QC sample results were within established control limits and, if not,
the data were appropriately qualified in accordance with the data
usability criteria.  Data outside of established control limits will be
qualified as appropriate, assigned an appropriate qualifier flag,
discussed in the case narrative, and included as appropriate in
calculations for completeness.

For RFETS waste sampled and analyzed at INEEL, data useability criteria
and laboratory completeness is evaluated at the project level.

Reporting flags were assigned correctly (refer to Table B3-14).

Sample holding time and preservation requirements were met, or
exceptions documented (as applicable).

RTR tapes were reviewed (independent observation), on a waste container
basis at a minimum of once per testing batch, or once per day of
operation, whichever is less frequent [Section B1-3b(2)].  The RTR tape
will be reviewed against the reported data on the RTR form to ensure
that the data are correct and complete.

Field sampling records are complete (if applicable).  Incomplete or
incorrect field sampling records will be subject to re-submittal prior
to completion of the independent technical review.

Table B-1 provides a list of procedures used to implement the
requirements of this section.  The list is not comprehensive.
Additional procedures are found in Section D-2, RFETS References.

B3-10a(2)	Technical Supervisor Review

The technical supervisor review ensures that the independent technical
review was performed completely, that the Batch Data Report is complete,
and verifies that the results are technically reasonable.  This review
validates and verifies that the characterization performed in this area
is ready for QA office review.

One hundred percent of the Batch Data Reports receive technical
supervisory signature release.  The technical supervisory signature
release occurs as soon as practicably possible after the independent
technical review in order to determine and correct negative quality
trends in the sampling or analytical process.  However, at a minimum,
the technical supervisory signature release must be performed before any
waste associated with data reviewed is shipped to the WIPP facility.
This signature release ensures the following:

The data are technically reasonable based on the technique used.

The data received independent technical review with the exception of RTR
tapes, which receive periodic technical reviews as specified above
(refer to Section B1-3b(2) of this document).

The testing, sampling, or analytical data QA documentation for Batch
Data Reports is complete and includes as applicable, raw data, DAC and
equilibrium calculations and times, calculation records, COC forms,
equipment calibration records, QC sample results, and original or copies
of the gas sample canister tags.

Sample holding time requirements were met, or exceptions documented (if
applicable).

Field sampling records are complete (if applicable).

B3-10a(3)	QA Officer Review

The data generation level QA review ensures that the Batch Data Report
is complete, that QC checks  meet the acceptance criteria, and that the
appropriate QAOs have been met.  This review verifies and validates that
the characterization results meet the program QA/QC, that instrument
performance criteria have been met, and that QAOs for the subject
characterization area have been met.

Each functional area that generates data for the TWCP (e.g., headspace,
laboratories, Radiography, etc.) designates a QA Officer.  One hundred
percent of the Batch Data Reports receive QA officer (or designee)
signature release.  The QA Officer signature release occurs as soon as
practicably possible after the technical supervisory signature release
in order to determine and correct negative quality trends in the
sampling or analytical process.  However, at a minimum, the QA Officer
signature release must be performed before any waste associated with
data reviewed is shipped to the WIPP facility. This signature release
ensures the following:

Independent technical and supervisory reviews were performed as
evidenced by the appropriate signature releases.

The QA documentation for Batch Data Reports is completed as appropriate
for the point of data generation.

Sampling and headspace or laboratory QC checks were properly performed.
QC criteria that were not met are documented.

The applicable QAOs have been met (refer to the methods outlined in
Section B3-11).

B3-10b	Project Level

Data review, validation, and verification at this level involves
scrutiny and signature release from the TWCP Site PM (or designee) and
the TWCP Site PQAO (or designee). The procedure PRO-940-WIPP-010, Waste
Characterization Project Level Data Review and Reporting, describes this
process in detail.  Any nonconformance identified during this process
shall be documented on a nonconformance report (refer to Section B3-13).

The TWCP Site PM and TWCP Site PQAO ensure that a repeat of the data
generation level review, validation, and verification is performed on
the data for a minimum of one randomly chosen waste container quarterly
(every three months).  This exercise documents that the data generation
level review, validation, and verification is being performed according
to implementing procedures.

Changes to Batch Data Reports, occurring after submittal to the Waste
Records Center, which impact characterization data will require
re-evaluation.  Upon identification, all inconsistencies, mistakes, or
omissions in Batch Data Reports shall be reported to the data validation
level QA Officer (or designee).  Corrections of inconsistencies,
mistakes, or omissions to Batch Data Reports that do not impact
characterization data shall be verified by the TWCP Site PQAO (or
designee). Corrected inconsistencies, mistakes, or omissions that impact
characterization data (this includes Nonconformances with a use-as-is
disposition) shall be re-evaluated by the TWCP Site PQAO (or designee)
and the TWCP Site PM (or designee).  Nonconformances with rework
disposition issued to Batch Data Reports shall be revalidated by the
TWCP Site PQAO (or designee) and the TWCP Site PM (or designee).
Nonconformances with scrap disposition issued to Batch Data Reports
shall be revalidated by the TWCP Site PQAO (or designee).

B3-10b(1)	TWCP Site PQAO Review

The TWCP Site PQAO review ensures that the Batch Data Reports received
from the data generation level is complete, validates and verifies that
the QC checks were done properly and meet program criteria, and ensures
that the QAOs have been met.

One hundred percent of the Batch Data Reports receive TWCP Site PQAO
signature release.  The TWCP Site PQAO signature release occurs as soon
as practicably possible in order to determine and correct negative
quality trends in the sampling or analytical process.

However, at a minimum, the TWCP Site PQAO signature release must be
performed before any waste associated with the data reviewed is shipped
to the WIPP facility.  This signature release ensures the following:

Batch Data Reports are complete and data are properly reported (i.e.,
data are reported in correct units, with correct significant figures,
and with correct qualifying flags).

Sampling batch QC checks (e.g., equipment blanks, field duplicates,
field reference standards) were properly performed, and meet the
established QAOs, and are within established data usability criteria.

Testing batch QC checks (e.g., replicate scans, measurement system
checks) were properly performed.  Radiography data are complete and
acceptable based on evidence of videotape review of one waste container
per day or once per testing batch, whichever is less frequent, as
specified in Section B1-3b(2).

Analytical QC checks (e.g., laboratory duplicates, laboratory blanks,
matrix spikes, matrix spike duplicates, laboratory control samples) were
properly performed and meet the established QAOs, and are within
established data usability criteria.

On-line QC checks (e.g., field blanks, on-line blanks, on-line
duplicates, on-line control samples) were properly performed and meet
the established QAOs and are within established data usability criteria.

Proper procedures were followed to ensure representative samples for
headspace gas and homogeneous solids and soil/gravel were taken.

B3-10b(2)	TWCP Site PM Review

The TWCP Site PM review is the final validation that all of the data
contained in Batch Data Reports have been properly reviewed as evidenced
by signature release and completed checklists.

One hundred percent of the Batch Data Reports have a TWCP Site PM
signature release.    The TWCP Site PM signature release occurs as soon
as practicably possible after the TWCP Site PQAO signature release in
order to determine and correct negative quality trends in the sampling
or analytical process.  However, at a minimum, the TWCP Site PM
signature release must be performed before any waste associated with the
data reviewed is shipped to the WIPP facility.  This signature release
ensures the following:

The TWCP Site PM or designee determines the validity of the DAC
assignment made at the data generation level based upon an assessment of
the data collection and evaluation necessary to make the assignment.

Data generation level independent technical, technical supervisory, and
QA officer (or designee) review, validation, and verification have been
performed as evidenced by the completed review checklists and
appropriate signature releases.

Batch data review checklists are complete.

Batch Data Reports are complete and data are properly reported (e.g.,
data are reported in correct units, with correct number of significant
figures, and with qualifying flags).

Verify that data are within established data assessment criteria and
meet all applicable QAOs (Section B3-11).

B3-10b(3)	Preparation of theTWCP Site PQAO Summary and the TWCP Site PM
Data Validation Summary

To document the project level validation and verification described
above, the TWCP Site PQAO (or designee) prepares a TWCP Site PQAO
Summary, and the TWCP Site PM (or designee) prepares a Data Validation
Summary.  These reports are combined and incorporated into the TWCP Site
PQAO and TWCP Site PM checklists  to eliminate redundancy.  The TWCP
Site PQAO Summary includes a validation checklist for each Batch Data
Report.  Checklists for the TWCP Site PQAO Summary are sufficiently
detailed to validate all aspects of a Batch Data Report that affect data
quality.

The TWCP Site PM Data Validation Summary provides confirmation that, on
a per waste container basis as evidenced by Batch Data Report reviews,
all data have been validated in accordance with this document.  The Data
Validation Summary identifies each Batch Data Report reviewed (including
all waste container numbers), describes how the validation was performed
and whether or not problems were detected (e.g. nonconformance reports),
and includes a statement indicating that all data are acceptable.
Summaries include release signatures.

B3-10b(4)	Preparation of the Waste Stream Characterization Package

In the event that the WIPP facility requests detailed information on a
waste stream, RFETS will provide a Waste Stream Characterization Package
prepared in accordance with PRO-484-WIPP-003, Collection, Review, and
Confirmation of Acceptable Knowledge Documentation.  The TWCP Site PM
can require each characterization area, data generation level technical
supervisor, and QA Officer to assist in the preparation and review of
the Waste Stream Characterization Package (Section B3-12b(3)) as
necessary to ensure the package will support the TWCP Site PM’s waste
characterization determinations.

B3-10b(5)	Sample Disposition

Once the data have received project level validation and verification or
when the TWCP Site PM decides the sample no longer needs to be retained,
the TWCP Site PM notifies the laboratories; samples must be retained
until this notification is received.  Gas sample canisters may then be
released from storage for cleaning, recertification, and subsequent
reuse.  Sample tags are removed, copied, and the copies are retained in
the project files before recycling the canisters.  If the TWCP Site PM
requests that samples or canisters be retained for future use (e.g., an
experimental holding time study), the same sample identification and COC
forms are used and cross-referenced to documentation which specifies the
purpose for sample or canister retention.

B3-11	Reconciliation with Data Quality Objectives

Reconciling the results of waste testing and analysis with the DQOs
provides a way to ensure that data is of adequate quality to support the
regulatory compliance programs.  Reconciliation with the DQOs takes
place at both the project level and the WIPP facility.  At the project
level, reconciliation is performed by the TWCP Site PM (or designee),
and submitted to the WIPP facility for review and approval.

B3-11a	Reconciliation at the Project Level

The TWCP Site PM ensures that all data generated and used in decision
making meet the DQOs provided in Section B-4a(1) of this document.  The
TWCP Site PM assesses whether data of sufficient type, quality, and
quantity have been collected.  The TWCP Site PM determines if the
variability of the data set is small enough to provide the required
confidence in the results.

The TWCP Site PM also determines if, based on the desired error rates
and confidence levels, a sufficient number of valid data points have
been determined (as established by the associated completeness rate for
each sampling and analytical process).  In addition, the TWCP Site PM
documents that random sampling of containers was performed for the
purposes of waste stream characterization.

The TWCP Site PM determines if sufficient data have been collected to
determine the following WAP-required waste parameters as applicable:

Waste Matrix Code.

Waste material parameter weights.

If each container of waste contains TRU radioactive waste.

Mean concentrations, UCL90 for the mean concentrations, standard
deviations, and the number of samples collected for each VOC in the
headspace gas of waste containers in the waste stream.

Potential flammability of TRU waste headspace gases.

Mean concentrations, UCL90 for the mean concentrations, standard
deviations, and the number of samples collected for VOCs, SVOCs, and
metals in the waste stream.

Whether the waste stream exhibits a TC under 40 CFR Part 261, Subpart C.

Whether the waste stream is classified as hazardous or nonhazardous at
the 90% confidence limit.

Whether a sufficient number of waste containers were visually examined
(to Confirm RTR) to determine with a reasonable level of certainty that
the UCL90 of the average miscertification rate is less than 14%.

Whether an appropriate packaging configuration and DAC were applied and
documented in the headspace gas sampling documentation, and whether the
drum age was met prior to sampling.

B3-11a	Reconciliation at the Project Level  (continued)

Whether all TICs were appropriately identified and reported in
accordance with the requirements of Section B3-1 prior to submittal of a
WSPF for a waste stream or waste stream lot.

Whether the overall completeness, comparability, and representativeness
QAOs were met for each of the analytical and testing procedures as
specified in Sections B3-2 through B3-9 prior to submittal of a WSPF for
a waste stream or waste stream lot.

Whether the PRQLs for all analyses were met prior to submittal of a WSPF
for a waste stream or waste stream lot.

If the TWCP Site PM determines that insufficient data have been
collected to make the determinations listed above, additional data
collection efforts must be undertaken.  The reconciliation of a waste
stream is performed prior to submittal of the Waste Stream Profile Form
for that waste stream, preventing disposal of TRU mixed waste at WIPP
unless the TWCP Site PM determines that the WAP-required waste
parameters listed above have been met.  For subsequent shipments, data
reconciliation is done on all containers or samples prior to shipment to
WIPP.

The statistical procedure presented in Section B2 of this document and
in 95-WP/SAP-001, Transuranic (TRU/TRM) Waste Sampling Plan, is used to
evaluate and report waste characterization data from the analysis of
homogeneous solids and soil/gravel.  The procedure, which calculates
UCL90 values, is used to assess compliance with the DQOs presented in
Section B-4a(1), as well as with RCRA regulations.  The procedure is
applied to all laboratory analytical data for total VOCs, total SVOCs,
and total metals.

For RCRA regulatory compliance (40 CFR § 261.24), data from the
analysis of the appropriate metals and organic compounds is expressed as
toxicity characteristic leaching procedure (TCLP) values or results may
also be compared to the TC levels expressed as total values.  These
total values are the regulatory threshold limit (RTL) values, and are
obtained by calculating the weight/weight concentration (in the solid)
of a TC analyte that would give the regulatory weight/volume
concentration (in the TCLP extract), assuming 100-percent analyte
dissolution.  The RTLs are presented in Table B3-15.

B3-12	Data Reporting Requirements

Data reporting requirements define the type of information and the
method of transmittal for data transfer from the data generation level
to the project level and from the project level to the WIPP facility.

B3-12a	Data Generation Level to the Project Level

Data are transmitted by hard copy or electronically (hard copy is
available on demand) from the data generation level to the project level
(PDCO).  Transmitted data includes Batch Data Reports, and data review
checklists.

Data generating organizations are responsible to ensure that correct and
current characterization information is forwarded to the TWCP project
office if new or duplicate readings or tests are taken.  This
responsibility includes modifying all Batch Data Reports or WEMS
database records impacted by the changed characterization information.
Data generating organizations are required to document the duplicate
record condition, and the actions that are required to reconcile the
affected records and databases, through specific procedural instructions
and/or a Nonconformance report. In all cases the TWCP Site PQAO shall be
notified in writing, along with the affected record or database
management organizations. The Batch Data Reports and checklists used
contain all of the information required by the testing, sampling, and
analytical techniques described in Sections B1 through B6, as well as
the signature releases to document the review, validation, and
verification as described in Section B3-10.  Batch Data Reports and
checklists are in approved formats as provided in RFETS procedures.

Data for RFETS waste sampled and analyzed at INEEL, including updated
and modified Batch Data Reports are transmitted from the INEEL TWCP in
hard copy format.  The Batch Data Reports and checklists contain all of
the information described in the Attachment to the SOW for the INEEL
TWCP (DOE 2003a).

After review by the TWCP Site PQAO, all Batch Data Reports are forwarded
to the TWCP Site PM.  All Batch Data Reports are assigned serial
numbers, and each page is numbered. The serial number is the same as the
testing, sampling, or analytical batch number.

QA documentation including raw data are maintained in either testing,
sampling, and analytical facility files, or TWCP project files in
accordance with the document storage requirements presented in Section B
and Section B5 of this document. Contract waste characterization
facilities forward their testing, sampling, and analytical QA
documentation along with Batch Data Reports to the TWCP Project Office
for inclusion in TWCP central files.

B3-12b	Project Level to DOE/CBFO Level

The TWCP office prepares a WSPF for each waste stream to be certified
for shipment to WIPP based on information obtained from Batch Data
Reports.  In addition the TWCP office ensures the Characterization
Information Summary and the Waste Stream Characterization Package (when
requested by the WIPP facility) are prepared as appropriate. The TWCP
Site QAO verifies these reports are consistent with information found in
analytical batch reports. Summarized testing, sampling, and analytical
characterization data are included in the Characterization Information
Summary.  The contents of the WSPF, the Characterization Information
Summary, and the Waste Stream Characterization Package are discussed in
the following sections.

B3-12b	Project Level to DOE/CBFO Level (continued)

After approval of a WSPF and the associated Characterization Information
Summary by the WIPP facility, RFETS maintains a cross-reference of
container identification numbers to each Batch Data Report.

Prior to shipment of waste to the WIPP facility, RFETS transmits data on
an individual container basis to the WIPP facility using the WIPP Waste
Information System (WWIS).  Procedures PRO-944-WIPP-008, Completion of
Waste Stream Profile Form for Waste to be Disposed of at WIPP;
4-K47-WEM-WP1210, WEMS Offsite Shipping Module; and 4-G83-WEM-WP-1209,
WEMS Waste Package Verification and Certification, describe the method
used to report data from the project level to the CBFO level.

B3-12b(1)	Waste Stream Profile Form

The WSPF (Figure B-1) includes the following information:

Generator/storage site name

Generator/storage site EPA ID

Date of audit report approval by NMED (if obtained)

Original generator of waste stream

The Waste Stream WIPP Identification Number

Summary Category Group

Waste Matrix Code Group

Waste stream name

A description of the waste stream

Applicable EPA hazardous waste codes

Applicable TRUCON codes

A listing of acceptable knowledge documentation used to identify the
waste stream

The waste characterization procedures used and the reference and date of
the procedure

Certification signature of TWCP Site PM, name, title, and date signed

B3-12b(2)	Characterization Information Summary

The Characterization Information Summary includes the following
elements:

Data reconciliation with DQOs.

Headspace gas summary data listing the identification numbers of samples
used in the statistical reduction, the maximum, mean, standard
deviation, UCL90, RTL, and associated EPA hazardous waste codes that
must be applied to the waste stream.

Total metal, VOC, and SVOC analytical results for homogeneous solids and
soil/gravel (if applicable), and demonstration that control charting
cannot be applied effectively, if this option is implemented.

TIC listing and evaluation, and verification that AK was confirmed.

RTR and VE summary to document that prohibited items are not present,
including waste exhibiting the characteristics of ignitability,
corrosivity, and reactivity, to confirm AK; and documentation and
justification for the use of radiography in lieu of or in combination
with VE/VV for newly generated waste (see Section B4-2b).

A complete listing of all container identification numbers used to
generate the WSPF, cross-referenced to each Batch Data Report

Compelete AK Summary including waste stream name, waste stream number,
point of generation, waste stream volume (current and projected),
generation dates, TRUCON codes, Summary Category Group, Waste Matrix
Code(s) and Waste Matrix Code Group, other TWBIR information, waste
stream description, areas of operation, generating processes, RCRA
determinations, radionuclide information, all references used to
generate the AK summary, and any other information required by Section
B4-2b.

Certification through AK or testing and/or analysis that any waste
assigned the hazardous waste number U134 (hydrofluoric acid) no longer
exhibits the characteristic of corrosivity.  This is confirmed by
assuring that no liquid is present in U134 waste.

B3-12b(3)	Waste Stream Characterization Package

The Waste Stream Characterization Package consists of the following:

WSPF (Section B3-12b(1))

Accompanying Characterization Information Summary (Section B3-12b(2))

Complete AK summary (Section B3-12b(2))

Batch Data Reports supporting the confirmation of AK as well as other
Batch Data Reports requested by the WIPP facility

Raw analytical data requested by the WIPP facility

B3-12c	WIPP Waste Information System (WWIS)

The WWIS Data Fields (Table B-8) contain all of the data, the field
format and the limits associated with the data as established by Section
B-1c of this document.  These data are subject to edit and limit checks
that are performed automatically by the database as defined in the WIPP
Waste Information System User’s Manual for Use by Shippers/Generators
(DOE 2001).  If a container was part of a composite headspace gas
sample, the analytical results from the composite sample must be
assigned as the container headspace gas data results, including any
associated TICs, for every waste container associated with the composite
sample.  RFETS coordinates the data transmission with the WIPP facility.

B3-13	Nonconformances and Corrective Actions

The status of TWCP work activities are monitored and controlled by the
TWCP Site PM and the TWCP Site PQAO through the RFETS quality
improvement and corrective action process.  This includes nonconformance
identification, documentation, and reporting, as well as the monitoring
of Nonconformance Reports (NCRs).

The nonconformances and corrective action processes specified in this
section describe site-specific nonconformance procedures and
communication with the WIPP facility concerning nonconformance tracking
and resolution.  RFETS complies with the nonconformance requirements
specified in Section B3-1 of this document.

B3-13a	Nonconformances

Nonconformances are uncontrolled and unapproved deviations from an
approved plan or procedure. Nonconforming items and activities are those
that do not meet the TWCP requirements, procurement document criteria,
or approved work procedures.   RFETS personnel are responsible for
promptly reporting any nonconformance condition identified as adverse to
quality to management.  When a nonconformance related to the TWCP is
observed or detected, the TWCP Site PM and the TWCP Site PQAO are
notified, and involved management review the content of the NCRs and
assist RFETS QA and/or WC&O in processing the TWCP related NCR.

B3-13a	Nonconformances (continued)

RFETS identifies and documents nonconformances in accordance with the
QAPD as follows:

Nonconforming items are addressed in 1-A65-ADM-15.01, Control of
Nonconforming Items.  This procedure describes the methods to identify,
control, and dispose of nonconforming items (nonconforming items are
identified by marking, tagging, or segregating the items).  The
procedure also assigns responsibilities to RFETS organizations and
personnel to identify, report, control, evaluate the nonconformances,
obtain and document a disposition, determine cause, and define
corrective action for reported nonconforming items.  This procedure is
used for nonconformances identified during data generation level data
review.  This procedure refers to PRO-U76-WC-4030, Control of Waste
Nonconformances, for waste package nonconformances.

Waste nonconformances are addressed in PRO-U76-WC-4030, Control of Waste
Nonconformances.  WC&O has the responsibility for reviewing all
nonconformance reports for waste containers.  The procedure assigns
responsibilities to RFETS organizations and personnel to identify,
report, control, evaluate the nonconformances, obtain and document a
disposition, determine cause, and define corrective action for reported
nonconforming items.  This procedure is used for nonconformances
identified during data generation level data review.

Nonconformances identified during project level data review and
reporting are addressed in PRO-940-WIPP-010, WIPP TRU Waste
Characterization Project Level Data Review and Reporting.

1-V10-ADM-15.02, Stop Work Action, describes the stop work methodology
(and its applicability) when the work is not in compliance governing
quality requirements.  Under specified emergency conditions, the TWCP
Site PM or the TWCP Site PQAO, working with appropriate management may
issue stop work orders.  Requirements for the resolution and release of
stop work orders are also defined in the procedure.

Management at all levels fosters a "no-fault" attitude to encourage the
identification of nonconforming items and processes.  Nonconformances
may be detected and identified by anyone performing WAP activities,
including:

Project staff - during field operations, supervision of subcontractors,
data validation and verification, and self-assessment.

Laboratory and Headspace staff - during the preparation for and
performance of testing; calibration of equipment; QC activities; data
review, validation, and verification; and self-assessment.

QA personnel - during oversight activities or audits.

B3-13a	Nonconformances   (continued)

An NCR is prepared for each nonconformance identified.  Each NCR is
initiated by the individual(s) identifying the nonconformance.  The NCR
is processed by knowledgeable and appropriate personnel, includes or
references as appropriate, results of headspace or laboratory analysis,
QC tests, audit reports, internal memoranda, or letters.  The NCR
provides the following information:

Identification of the individual(s) identifying or originating the
nonconformance.

Description of the nonconformance.

Method(s) or suggestions for correcting the nonconformance (corrective
action).

Schedule for completing the corrective action.

An indication of the potential ramifications and overall usability of
the data, if applicable.

Any approval signatures specified in the RFETS nonconformance
procedures.

The TWCP Site PQAO oversees the NCR process.  The completion
verification of NCRs is delegated to the appropriate quality engineering
or waste inspection organization as defined in implementing procedures.
Nonconformances are tracked and trended as described in
PRO-943-WIPP-007, TWCP Trending and Analysis of Quality-Affecting
Problems.  This process analyzes trends in NCRs month-to-month by point
or process origin and by category.  An evaluation is conducted to
determine if there are significant conditions adverse to quality; if
indicated, additional cause analysis and corrective actions are taken in
accordance with site-specific corrective action procedures.  The TWCP
Site PM ensures that proper project personnel are notified of
nonconformances by review and approval of implementing NCR procedures.
The site-specific NCR procedures designate the organizations responsible
to approve and complete necessary corrective actions.  The TWCP Site
PQAO provides written notification to the WIPP facility of all
non-administrative nonconformances (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.  NCR
documentation is made available to the TWCP Site PM per
PRO-943-WIPP-007, TWCP Trending and Analysis of Quality-Affecting
Problems.

As described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a), the RFETS TWCP is notified of NCRs related to sampling and
analysis of RFETS waste at INEEL.  The NCRs are evaluated by the TWCP
Site PQAO.

B3-13b	Corrective Actions

The quality systems established for corrective action and their
reporting are described in Section 3.1.3 of 1-MAN-008-WM-001,
Transuranic (TRU) Waste Management Manual.  The disposition of
nonconformances is identified and documented.  RFETS implements
corrective action and resolves the identified nonconformance prior to
the shipment of the TRU mixed waste to the WIPP facility.  Completion of
corrective actions for nonconformances is verified by the TWCP Site PQAO
or by independent RFETS QA personnel.

The TWCP Site PQAO coordinates the processing of corrective actions and
NCRs from CBFO.  This process includes:

Entering them into the Plant Action Tracking System (PATS) for tracking
(refer to 3-X31-CAP-001, Corrective Action Process).

Evaluating the extent and cause of the deficiency.

Providing a response (via the TWCP Site PM) to CBFO that addresses
remedial actions and actions to preclude recurrence.

Ensuring that corrective action plans properly address CBFO accepted
remedial actions and actions to preclude recurrence of the condition.

B3-14	Special Training Requirements and Certification

Before performing activities that affect WAP quality, all personnel
receive indoctrination into the applicable scope, purpose, and
objectives of the WAP and the specific QAOs of the assigned task.
Personnel assigned to perform activities for the WAP have the education,
experience, and training applicable to the functions associated with the
work. Evidence of personnel proficiency and demonstration of competence
in the task(s) assigned is demonstrated and documented. All personnel
designated to work on specific aspects of the WAP maintain qualification
(i.e., training and certification) throughout the duration of the work
as specified in this WAP and applicable QAPjPs/procedures. Job
performance is evaluated and documented at periodic intervals, as
specified in the implementing procedures.

Personnel involved in WAP activities receive continuing training to
ensure that job proficiency is maintained.  Training includes both
education in principles and enhancement of skills.  RFETS procedures for
implementing personnel qualification and training include the TWCP TIP,
and 5-NDT-TC-1A, Training, Qualification, and Certification of
Nondestructive Testing Personnel, specifically for RTR personnel.  All
training records that specify the scope of the training, the date of
completion, and documentation of job proficiency are maintained as QA
Records in the TWCP project file.

The Headspace Analytical Services and Analytical Laboratories line
management ensures that analytical personnel are qualified to perform
the analytical method(s) for which they are responsible. The minimum
qualifications for certain specified positions for the WAP are
summarized in Table B3-10.  Section B1-3b specifies the site-specific
title of the personnel who perform the applicable radiography methods as
radiography operators.  For the analytical positions in Table B3-10, the
site-specific titles are presented for each analytical method in the
TWCP TIP, Appendix 4 – Analysis Processes.  The TWCP TIP, Section 7.8,
Records Processing Instructions, contains the requirements for
maintaining records of the qualification, training, and demonstration of
proficiency by these radiography, headspace, and laboratory personnel.

An evaluation of personnel qualifications includes comparing and
evaluating the requirements specified in the job/position description
and the skills, training, and experience included in the current resume
of the person (refer to the TWCP TIP, Section 7.1, Job Analyses and
Training Needs Assessment and Section 7.2, Personnel Selection and
Assignment). This evaluation is also performed for personnel who change
positions because of a transfer or promotion as well as personnel
assigned to short-term or temporary work assignments that may affect the
quality of the WAP.  The TWCP TIP (refer to Section 5, TWCP
Organization, Responsibilities, and Authorities; and Section 7.6,
Continuing Training) identifies the responsible person(s) for ensuring
that all personnel maintain proficiency in the work performed and
identifies any additional training that may be required.

B3-15	This section has been deleted

Section B5-2 addresses RFETS compliance with Section B3-15 of the WAP.

B3-16	Hydrogen and Methane Analysis

This section identifies the required QA elements for the analysis of
hydrogen and methane in gas samples. The site-specific QAOs for hydrogen
and methane analysis are listed in Table B3-16A.  Table B-1 contains a
synopsis of the site-specific procedures used for headspace gas sampling
and for hydrogen and methane analysis.

B3-16a	Methods Requirements

The method used by RFETS Headspace Analytical Services and Analytical
Laboratories for the analysis of hydrogen and methane is described in
PRO-1676-HGAS-S&A, Headspace Gas Sampling and Analysis Using an On-Line
Integrated System; L-4231, Headspace Gas Sampling and Analysis Using an
Automated Manifold; and L-2421, Precision Gas Mass Spectrometry
Operations and Analyses (VG 30-38).  Hydrogen and methane concentrations
are reported as volume percent and calculated from the partial pressures
of hydrogen and methane in a sample.

Primary hydrogen and methane standards are purchased from the best
available source (Scott Specialty Gases or equivalent).  The
manufacturer certifies all commercial standards used in this analysis.

B3-16b	Quality Control

Qualitative and quantitative acceptance criteria for the quality control
checks are specified in PRO-1669-HGAS-V&V, Headspace Gas V&V (Data
Generator Level); L-4053, Headspace Gas V & V (Data Generator Level);
and L-5016, Data Review and Validation for Inorganic Gases for WIPP-TRU
Waste Characterization Program (TWCP) – Data Generation Level2.

The HASQAO or LPQAO is responsible for monitoring and documenting
procedural performance, including the analysis of blanks and duplicates.
 The HASQAO or LPQAO and the technical supervisor are responsible for
the implementation of corrective actions if acceptable performance is
not obtained.  A nonconformance report is required only if the final,
reported QC sample results do not meet acceptance criteria.

Headspace Analytical Services and the Analytical Laboratories operate
under a formal quality control program and maintain records to document
the quality of data generated.  All quality control elements established
by the TWCP are implemented with headspace and laboratory procedures,
including method performance samples, laboratory duplicates, laboratory
blanks, and blind audit samples.  Specific quality control samples and
frequencies are summarized in Table B3-16B

Method performance samples are used to demonstrate acceptable headspace
performance prior to the analysis of any samples.  Initially, a minimum
of seven replicate performance samples is analyzed to demonstrate
acceptable precision and accuracy, and to determine MDLs for hydrogen
and methane.

The same procedure used to prepare gas samples for analysis is also used
to prepare the blanks.  Analyses of blanks are acceptable if analyte
concentrations are less than three times the analyte MDLs.

B3-16c	Instrument Testing, Inspection, and Maintenance Requirements

Headspace Analytical Services personnel ensure that its analytical
instruments are tested, inspected, and maintained in such a manner that
the quality assurance objectives in Table B3-16A are met.

Table B3-1, Physical form of waste (waste material parameter) and
Descriptions

WASTE MATERIAL PARAMETER	DESCRIPTION

Iron-based Metal/Alloys	Iron and steel alloys in the waste excluding the
waste container materials.

Aluminum-based Metals/Alloys	Aluminum or aluminum-based alloys in the
waste materials.

Other Metals	All other metals found in the waste materials.

Other Inorganic Materials	Non-metallic inorganic waste, including
concrete, glass, firebrick, ceramics, sand, and inorganic sorbents.

Cellulosics	Materials generally derived from high polymer plant
carbohydrates, e.g., paper, cardboard, wood, cloth, etc.

Rubber	Natural or man-made elastic latex materials, e.g., surgeon’s
gloves, leaded rubber gloves, etc.

Plastics (Waste Materials)	Generally man-made materials, often derived
from petroleum feedstock, e.g., polyethylene, polyvinylchloride, etc.

Organic Matrix	Cemented organic resins, solidified organic liquids and
sludges.

Inorganic Matrix	Any homogeneous materials consisting of sludge, or
aqueous-based liquids which are solidified with cement silicate, or
other solidification agents, e.g., waste water treatment sludge,
cemented aqueous liquids, and inorganic particulates, etc.

Soils	Generally consists of naturally occurring soils which have been
contaminated with inorganic waste materials.

Steel (Packaging Materials)	208-liter (55-gallon) drums.

Plastics (Packaging Materials)	90 mm polyethylene drum liner and plastic
bags.

Source:	Waste Isolation Pilot Plant Transuranic Waste Baseline Inventory
Report (DOE 1995b)

Table B3-2, Gas Volatile Organic Compounds Target Analyte List and
Quality Assurance Objectives

When Using SUMMA® Canisters or On-Line Systems

COMPOUND

CAS NUMBER	PRECISIONa (%RSD OR RPD)

ACCURACYa (%R)

MDLb (NG)

PRQL (PPMV)

COMPLETENESS (%)

Benzene	71-43-2	<25	70-130	10	10	90

Bromoform	75-25-2	<25	70-130	10	10	90

Carbon Disulfided	75-15-0	<25	70-130	10	10	90

Carbon Tetrachloride	56-23-5	<25	70-130	10	10	90

Chlorobenzene	108-90-7	<25	70-130	10	10	90

Chloroform	67-66-3	<25	70-130	10	10	90

Cyclohexane e	110-82-7	<25	70-130	10	10	90

1,1-Dichloroethane	75-34-3	<25	70-130	10	10	90

1,2-Dichloroethane	107-06-2	<25	70-130	10	10	90

1,1-Dichloroethylene	75-35-4	<25	70-130	10	10	90

cis-1,2-Dichloroethylene	156-59-2	<25	70-130	10	10	90

Trans-1,2-Dichloroethylene	156-60-5	<25	70-130	10	10	90

Ethyl Benzene	100-41-4	<25	70-130	10	10	90

Ethyl Ether	60-29-7	<25	70-130	10	10	90

Methylene Chloride	75-09-2	<25	70-130	10	10	90

1,1,2,2-Tetrachloroethane	79-34-5	<25	70-130	10	10	90

Tetrachloroethylene	127-18-4	<25	70-130	10	10	90

Toluene	108-88-3	<25	70-130	10	10	90

1,1,1-Trichloroethane	71-55-6	<25	70-130	10	10	90

Trichloroethylene	79-01-6	<25	70-130	10	10	90

1,1,2-Trichloro-1,2,2-trifluoroethane	76-13-1	<25	70-130	10	10	90

1,2,4-Trimethylbenzene e	95-63-6	<25	70-130	10	10	90

1,3,5-Trimethylbenzene e	108-67-8	<25	70-130	10	10	90

m-Xylenec	108-38-3	<25	70-130	10	10	90

o-Xylene	95-47-6	<25	70-130	10	10	90

p-Xylenec	106-42-3	<25	70-130	10	10	90

Acetone	67-64-1	<25	70-130	150	100	90

Butanol	71-36-3	<25	70-130	150	100	90

Methanol	67-56-1	<25	70-130	150	100	90

Methyl Ethyl Ketone	78-93-3	<25	70-130	150	100	90

Methyl Isobutyl Ketone	108-10-1	<25	70-130	150	100	90

a	Criteria apply to PRQL concentrations

b	Values based on delivering 10 mL  to the analytical system

c	These xylene isomers cannot be resolved by the analytical methods
employed in this program, and are reported as m,p-xylene.

d	Compound added to original target analyte list due to frequency of
detection as a Tentatively Identified Compound (TIC) in at least one
waste stream.

e	These three compounds are not included in the WIPP-WAP, but are
included in the list of Flammable Volatile Organic Compounds specified
in the TRUPACT-II SAR.

MDL	=	Method Detection Limit (maximum permissible value, total number of
nanograms delivered to the analytical system per sample)

PRQL	=	Program Required Quantitation Limit

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

Table B3-3, Summary of Laboratory Quality Control Samples and
Frequencies

for Gas Volatile Organic Compounds Analysis

 When Using SUMMA® Canisters or On-Line Systems

QC SAMPLE	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTION a, c

Method Performance Samples	Seven (7) samples initially and four (4)
semi-annually	Meet Table B3-2 QAOs	Repeat until acceptable

Laboratory Duplicates, or

On-Line Duplicates	One (1) per analytical batch  or  on-line batch.	RPD
< 25% b	Nonconformance if

Laboratory Blanks, or

On-Line Equipment/Field Blanks	Daily prior to sample analysis for GC/MS
and GC/FID.

Otherwise daily prior to sample analysis and one (1) per analytical
batch or on-line batch.	Analyte amounts

 ( 3 x MDLs for GC/MS and GC/FID	Flag data with a “B” if analyte
amounts ( 3 x MDLs for GC/MS and GC/FID

Laboratory Control Samples, or

On-Line Control Samples (FRS/CCV)	One (1) per analytical batch or
on-line batch.	70-130 %R	Nonconformance if

%R ( 70 or (130

GC/MS

	BFB Tune every 12 hours	Abundance criteria for all key ions are met
Repeat until acceptable

	5-pt. Initial Calibration

initially, and as needed	%RSD of response factor for each analyte ( 35
Repeat until acceptable

	Continuing Calibration

every 12 hours	%D for all compounds ( 30 of initial calibration	Repeat
until acceptable

GC/FID

	3-pt. Initial Calibration

initially, as needed	%RSD of response factor for each analyte ( 30

Linear regression plots yield straight line and %R is 70-130 for each
standard analyte	Repeat until acceptable

	Continuing calibration

every 12 hours	%D for all compounds ( 30 of initial calibration; RTs ±
3 standard deviations of initial calibration	Repeat until acceptable

Blind Audit Samples	Samples and frequency controlled by the Gas PDP Plan
Specified in the Gas PDP Plan	Specified in the Gas PDP Plan

a	Corrective action when QC samples do not meet the acceptance criteria;
nonconformance procedures are outlined in Section B3-13.

b	Applies only to concentrations greater than the PRQLs listed in Table
B3-2.

c	Data usability is assessed using the criteria presented in EPA
540/R-99/008, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999).

BFB	=	4-Bromofluorbenzene

%D	=	Percent Difference

MDL	=	Method Detection Limit

PDP	=	Performance Demonstration Program

QAO	=	Quality Assurance Objective

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

RT	=	Retention Time

Table B3-4, Volatile Organic Compounds Target Analyte List and Quality
Assurance Objectives

COMPOUND	CAS

NUMBER	PRECISION a

( %RSD or RPD)	ACCURACY a

(%R)	MDL b

(mg/kg)	PRQL b

(mg/kg)	COMPLETENESS

(%)

Benzene	71-43-2	<45	37-151	1	10	90

Bromoform	75-25-2	<47	45-169	1	10	90

Carbon disulfide	75-15-0	<50	60-150	1	10	90

Carbon tetrachloride	56-23-5	<30	70-140	1	10	90

Chlorobenzene	108-90-7	<38	37-160	1	10	90

Chloroform	67-66-3	<44	51-138	1	10	90

Chloromethanef	74-87-3	<50	60-150	1	10	90

1,4-Dichlorobenzene c	106-46-7	<60	18-190	1	10	90

ortho-Dichlorobenzene c	95-50-1	<60	18-190	1	10	90

1,2-Dichloroethane	107-06-2	<42	49-155	1	10	90

1,1-Dichloroethylene	75-35-4	<250	D-234 d	1	10	90

Trans-1,2-Dichlorethylene	156-60-5	<50	60-150	1	10	90

Ethyl benzene	100-41-4	<43	37-162	1	10	90

Methylene chloride	75-09-2	<50	D-221 d	1	10	90

1,1,2,2-Tetrachloroethane	79-34-5	<55	46-157	1	10	90

Tetrachloroethylene	127-18-4	<29	64-148	1	10	90

Toluene	108-88-3	<29	47-150	1	10	90

1,1,1-Trichloroethane	71-55-6	<33	52-162	1	10	90

1,1,2-Trichloroethane	79-00-5	<38	52-150	1	10	90

Trichloroethylene	79-01-6	<36	71-157	1	10	90

Trichlorofluorormethane	75-69-4	<110	17-181	1	10	90

1,1,2-Trichloro-1,2,2-trifluoroethane	76-13-1	<50	60-150	1	10	90

Vinyl chloride	75-01-4	<200	D-251 d	1	4	90

m-xylene	108-38-3	<50	60-150	1	10	90

o-xylene	95-47-6	<50	60-150	1	10	90

p-xylene	106-42-3	<50	60-150	1	10	90

Acetone	67-64-1	<50	60-150	10 e	100	90

Butanol	71-36-3	<50	60-150	10 e	100	90

Ethyl ether	60-29-7	<50	60-150	10 e	100	90

Isobutanol	78-83-1	<50	60-150	10 e	100	90

Methanol	67-56-1	<50	60-150	10 e	100	90

Methyl ethyl ketone	78-93-3	<50	60-150	10 e	100	90

Pyridine c	110-86-1	<50	60-150	10 e	100	90

a	Applies to laboratory control samples and laboratory matrix spikes.
If a solid laboratory control sample material which has established
statistical control limits is used, then the established control limits
for that material should be used for accuracy requirements.

b	TCLP MDL and PRQL values are reported in units of mg/l and limits are
reduced by a factor of 20.

c	Can also be analyzed as a semi-volatile organic compound.  If analyzed
as a semi-volatile compound, the QAOs of Table B3-6 apply.

d	Detected; result must be greater than zero.

e	Estimate, to be determined.

f	Compound added to original target analyte list for waste streams
RF009.01, RF005.01, and RF118.01 due to frequency of detection as a
Tentatively Identified Compound (TIC). See interoffice memorandums from
G.A. O’Leary to C.A.Turner, GAO-057-00, GAO-032-01, and GAO-070-01.

MDL	=	Method Detection Limit (maximum permissible value)

PRQL	=	Program Required Quantitation Limit; calculated from the toxicity
characteristic level for benzene assuming a 25 gram sample, 0.5 L of
extraction fluid, and 100 percent analyte extraction

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

Table B3-5, Summary of Laboratory Quality Control Samples and
Frequencies for Volatile Organic Compounds Analysis

QC

SAMPLE	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTION a, c

Method performance

Samples	Seven (7) samples initially and four (4) semi-annually	Meet
Table B3-4 QAOs	Repeat until acceptable

Laboratory duplicatesb	One (1) per analytical batch	Meet Table B3-4
Precision QAOs	Nonconformance if  RPDs > values in Table B3-4.

Laboratory blanks	One (1) per analytical batch	Analyte concentrations (3
x MDLs	Nonconformance if analyte concentrations > 3 x MDLs.

Matrix spikes	One (1) per analytical batch	Meet Table B3-4 accuracy QAOs
Nonconformance if %Rs are outside the range specified in Table B3-4.

Matrix spike duplicatesb	One (1) per analytical batch	Meet Table B3-4
accuracy and precision QAOs	Nonconformance if RPDs > values and %Rs
outside range specified in Table B3-4.

Laboratory control samples	One (1) per analytical batch	Meet Table B3-4
accuracy QAOs	Nonconformance if %R < 80 or > 120.

GC/MS	BFB Tune every 12 hours

5-pt. Initial Calibration

initially, and as needed

	Abundance criteria met as per method

Calibrate according to SW-846 Method requirements

%RSD for CCC ( 30,

%RSD for all other compounds ( 15%

Average response factor (RRF) used if %RSD ( 15; linear regression used
if % RSD >15; R or R2 (  0.990 if using alternative curve

System Performance Check Compound (SPCC) minimum RRF as per SW-846
Method; RRF for all other compounds ( 0.01	Repeat until acceptable

	Continuing calibration

Every 12 hours	%D ( 20 for CCC

SPCC minimum RRF as per SW-846 Method; RRF for all other compounds (
0.01

RT for internal standard must be ( 30 seconds from last daily
calibration, internal standard area count must be > 50 % and < 200% of
last daily calibration	Repeat until acceptable

GC/FID	3-pt. Initial Calibration

initially and as needed	Correlation coefficient > 0.990 or %RSD for
response factors ( 20  for all analytes	Repeat until acceptable

	Continuing calibration

every 12 hours	%D or %Drift for all analytes ( 15 of expected values

RT ( 3 standard deviations from initial calibration	Repeat until
acceptable

Surrogate compounds	Each analytical sample	Average %R from minimum of 30
samples for a given matrix ( 3 standard deviations	Nonconformance if %R
< (average %R – 3 standard deviation) or > (average %R + 3 standard
deviation).

Blind audit samples	Samples and frequency controlled by the Solid PDP
Plan	Specified in the Solid PDP Plan	Specified in the Solid PDP Plan

a	Corrective Action per Section B3-13 of this document when final
reported QC samples do not meet the acceptance criteria.
Nonconformances do not apply to matrix related exceedances.

b	May be satisfied using matrix spike duplicate; acceptance criteria
applies only to concentrations greater than the PRQLs listed in  Table
B3-4.

c	Data usability is assessed using the criteria presented in EPA
540/R-99/008, USEPA Contract Laboratory Program Functional Guidelines
for Organic Data Review (EPA 1999).

BFB	=	4-Bromofluorbenzene	%R	=	Percent Recovery

%D	=	Percent Difference	%RSD	=	Percent Relative Standard Deviation

MDL	=	Method Detection Limit 	RPD	=	Relative Percent Difference

PDP	=	Performance Demonstration Program	RT	=	Retention Time

QAO	=	Quality Assurance Objective

Table B3-6, Semi-Volatile Organic Compounds Target Analyte List and
Quality Assurance Objectives

COMPOUND

CAS

NUMBER	PRECISIONa,g

(%RSD OR RPD)

ACCURACYa,g

(%R)

MDLb

(MG/KG)

PRQLb

(MG/KG)

COMPLETENESS

Acetophenonee	98-86-2	TBDf	TBDf	TBDf	40	90

Cresols	1319-77-3	<50	25 - 115	5	40	90

1,4-Dichlorobenzeneb, c	106-46-7	<86	20 - 124	5	40	90

Ortho-Dichlorobenzene c	95-50-1	<64	32 - 129	5	40	90

2,4-Dinitrophenol	51-28-5	<119	D-172d	5	40	90

2,4-Dinitrotoluene	121-14-2	<46	39 - 139	0.3	2.6	90

Hexachlorobenzene	118-74-1	<319	D-152d	0.3	2.6	90

Hexachloroethane	67-72-1	<44	40 - 113	5	40	90

Nitrobenzene	98-95-3	<72	35 - 180	5	40	90

Pentachlorophenol	87-86-5	<128	14 - 176	5	40	90

Pyridinec	110-86-1	<50	25 - 115	5	40	90

a 	Applies to laboratory control samples and laboratory matrix spikes.
If a solid laboratory control sample material which has established
statistical control limits is used, then the established control limits
for that material should be used for accuracy requirements.

b 	TCLP MDL and PRQL values are reported in units of mg/l and limits are
reduced by a factor of 20.

c	Can also be analyzed as a volatile organic compound.

d	Detected; result must be greater than zero.

e	Compound added to original target analyte list for waste stream
RF118.01 due to frequency of detection as a Tentatively Identified
Compound (TIC). See interoffice memorandum from G.A. O’Leary to
C.A.Turner, GAO-069-01.

f	Data is currently insufficient for calculating QAOs for precision,
accuracy, and MDL for this compound.

g	Criteria apply to PRQL concentrations.

CAS	=	Chemical Abstract Service

MDL	=	Method detection limit (maximum permissible value)

PRQL	=	Program required quantitation limit; calculated from the toxicity
characteristic level for nitrobenzene assuming a 100-gram (g) sample,
0.5 gal (2 liter [L]) of extraction fluid, and 100 percent analyte
extraction (milligrams per kilogram)

%R	=	Percent Recovery

%RSD	=	Percent relative standard deviation

RPD	=	Relative percent difference

Table B3-7, Summary of Laboratory Quality Control Samples and
Frequencies for Semi-Volatile Organic Compounds Analysis

QC

SAMPLE	MINIMUM

FREQUENCY

ACCEPTANCE CRITERIA	CORRECTIVE

ACTION a, c

Method Performance Samples	Seven (7) samples initially and four (4)
semi-annually	Meet Table B3-6 QAOs	Repeat until acceptable

Laboratory duplicates b	One (1) per analytical batch	Meet Table B3-6
precision QAOs	Nonconformance if RPDs > values in Table B3-6.

Laboratory blanks	One (1) per analytical batch	Analyte concentrations

(  3 x MDLs	Nonconformance if analyte concentrations ( 3 x MDLs.

Matrix spikes	One (1) per analytical batch	Meet Table B3-6 accuracy QAOs
Nonconformance if RPDs > values and %Rs outside range specified in Table

B3-6.

	GC/MS Calibration	DFTPP Tune every 12 hours

5-pt. Initial Calibration

initially, and as needed

	Abundance criteria met as per method

Calibrate according to SW-846 Method requirements

%RSD for CCC ( 30,

%RSD for all other compounds ( 15%

Average response factor (RRF) used if %RSD ( 15, use linear regression
if % RSD >15; R or R2 (  0.990 if using alternative curve

System Performance Check Compound (SPCC) minimum RRF as per SW-846
Method; RRF for all other compounds ( 0.01	Repeat until acceptable

	Continuing calibration

Every 12 hours	%D ( 20 for CCC

SPCC minimum RRF as per SW-846 Method; RRF for all other compounds (
0.01

RT for internal standard must be ( 30 seconds from last daily
calibration, internal standard area count must be > 50 % and < 200% of
last daily calibration	Repeat until acceptable

GC/ECD	5-pt. Calibration

initially and as needed	Correlation coefficient > 0.990 or %RSD for
response factors ( 20  for all analytes	Repeat until acceptable

	Continuing calibration

every 12 hours	%D or %Drift for all analytes ( 15 of expected values

RT ( 3 standard deviations from initial calibration	Repeat until
acceptable

Table B3-7, Summary of Laboratory Quality Control Samples and
Frequencies for Semi-Volatile Organic Compounds Analysis (continued)

QC

SAMPLE	MINIMUM

FREQUENCY

ACCEPTANCE CRITERIA	CORRECTIVE

ACTION a, c

Matrix spikes duplicates	One (1) per analytical batch	Meet Table B3-6
accuracy and precision QAOs	Nonconformance if RPDs and %Rs > values in
Table B3-6.

Laboratory control samples	One (1) per analytical batch	Meet Table B3-6
accuracy QAOs	Nonconformance if %R < 80 or > 120.

Surrogate compounds	Each analytical sample	Average %R from minimum of 30
samples for a given matrix ± 3 standard deviations	Nonconformance if %R
< (average %R – 3 standard deviations) or > (average %R + 3 standard
deviations).

Blind audit samples	Samples and frequency controlled by the Solid PDP
Plan	Specified in the Solid PDP Plan	Specified in the Solid PDP Plan

a	Corrective Action is taken per Section B3-13 of this document when
final reported QC samples do not meet the acceptance criteria.
Nonconformances do not apply to matrix related exceedances.

b	May be satisfied using matrix spike duplicate; acceptance criteria
applies only to concentrations greater than the PRQLs listed in Table
B3-6.

c	Data usability is assessed using the criteria presented in EPA
540/R-99/088, USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review (EPA 1999).

%D	=	Percent Difference

DFTPP	=	decafluorotriphenylphosphine

MDL	=	Method Detection Limit

PDP	=	Performance Demonstrate Program

QAO	=	Quality Assurance Objective

%R	=	Percent Recovery

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

RT	=	Retention Time

Table B3-8, Metals Target Analyte List and Quality Assurance Objectives

ANALYTE	CAS NUMBER	PRECISION

(% RSD OR RPD)a	ACCURACY (%R)b	PRDLc

(µG/L)	PRQLd

(MG/KG)	COMPLETENESS (%)

Antimony	7440-36-0	( 30	80-120	100	100	90

Arsenic	7440-38-2	( 30	80-120	100	100	90

Barium	7440-39-3	( 30	80-120	2,000	2,000	90

Beryllium	7440-41-7	( 30	80-120	100	100	90

Cadmium	7440-43-9	( 30	80-120	20	20	90

Chromium	7440-47-3	( 30	80-120	100	100	90

Lead	7439-92-1	( 30	80-120	100	100	90

Mercury	7439-97-6	( 30	80-120	4.0	4.0	90

Nickel	7440-02-0	( 30	80-120	100	100	90

Selenium	7782-49-2	( 30	80-120	20	20	90

Silver	7440-22-4	( 30	80-120	100	100	90

Thallium	7440-28-0	( 30	80-120	100	100	90

Vanadium	7440-62-2	( 30	80-120	100	100	90

Zinc	7440-66-6	( 30	80-120	100	100	90

a	( 30 % control limits apply when sample and duplicate concentrations
are ( 10 x IDL for ICP-AES and AA techniques, and ( 100 x IDL for ICP-MS
techniques.  If less than these limits, the absolute difference between
the two values shall be less than or equal to the PRQL.

b	Applies to laboratory control samples and laboratory matrix spikes.
If a solid laboratory control sample material which has established
statistical control limits is used, then the established control limits
for that material should be used for accuracy requirements.

c	PRDL set such that it is a factor of 10 below the PRQL for 100% solid
samples, assuming a 100x dilution during digestion.

d	TCLP PRQL values are reported in units of mg/l and limits are reduced
by a factor of 20.

CAS	=	Chemical Abstract Service

%RSD	=	Percent Relative Standard Deviation

RPD	=	Relative Percent Difference

%R	=	Percent Recovery

PRDL	=	Program Required Detection Limit (i.e., maximum permissible value
for IDL)

PRQL	=	Program Required Quantitation Limit

Table B3-9, Summary of Laboratory QC Samples and Frequencies for Metals
Analysis

QC SAMPLES	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTIONS a, d

Method performance samples	Seven (7) samples, initially, and four (4)
semi-annually	Meet Table B3-8 QAOs	Repeat until acceptable

Laboratory blanks	One (1) per analytical batch	(3 x IDL

((5 x IDL for ICP-MS)	Redigest and reanalyze any samples with analyte
concentrations which are (10 x blank value and

( 0.5 x PRQL

Matrix spikes	One (1) per analytical batch	Meet Table B3-8 accuracy QAOs
Nonconformance if %R is outside the range specified in Table B3-8.

Matrix spike duplicates	One (1) per analytical batch	Meet Table B3-8
accuracy and precision QAOs	Nonconformance if RPDs > values and %R
outside range specified in Table B3-8.

ICP-MS Tune (ICP-MS Only)	Daily	4 Replicate %RSD ( 50;

mass calibration ( 0.9 amu; resolution ( 1.0 amu full width at 10% peak
height	Nonconformance if %RSD ( 5, mass calibration ( 0.9 amu;
resolution ( 1.0 amu

Initial Calibration

1 blank, 1 standard  for ICP, ICP-MS

1 blank, 3 standard for GFAA, FLAA

1 blank, 5 standard for CVAA, HAA	Daily	90-110 %R  (80-120% for CVAA,
GFAA, HAA, FLAA) for initial calibration verification solution.

Regression coefficient ( 0.995 for FLAA, CVA, GFAA, MAA	Correct problem
and recalibrate; repeat initial calibration

Continuing calibration 	Every 10 samples and beginning and end of run
90-110 %R for continuing calibration verification solution.

(80-120% for CVAA, GFAA, HAA, FLAA)	Correct problem and recalibrate;
rerun last 10 samples

Internal Standard Area Verification (ICP-MS)	Every Sample	Meet SW-846
Method 6020 Criteria	Nonconformance if not reanalyzed at 5X dilution
until criteria are met

Serial dilution (ICP, ICP-MS)c	One (1) per analytical batch	5x dilution
must be ( 10 % D of initial value for sample ( 50 x IDL	Flag Data with a
“Z” if  ( 10% D and ( 50 x IDL

Interference Correction Verification (ICP, ICP-MS)	Beginning and end of
run or every 12 hours (8 for ICP) whichever is more frequent	80-120%
recovery for analytes

Note:  Acceptance Criteria and Corrective Action apply only if
interferants found in sample at levels greater than ICS A Solution
Correct problem and recalibrate, nonconformance if not corrected

Laboratory Control Samples	One (1) per analytical batch	Table B3-8
accuracy QAOs  	Redigest and reanalyze for effected analytes;
nonconformance if not reanalyzed.

Blind audit samples	Samples and frequency controlled by the Solid PDP
Plan	Specified in the Solid PDP Plan	Specified in the Solid PDP Plan

a	Corrective action per Section B3-13 when final reported QC samples do
not meet acceptance criteria.  Nonconformance do not apply to matrix
related exceedances.

b	Applies only to concentrations greater than PRQLs listed in Table
B3-8.

c	The SW-846 requirements apply to CVAA and HVAA serial dilution
acceptance criteria.

d	Data usability is assessed using the criteria presented in EPA
540-R-01-008, USEPA Contract Laboratory Program National Functional
Guidelines for Inorganic Data Review (EPA 2002).

IDL 	=	Instrument Detection Limit

PDP 	=	Performance Demonstration Program

PRQL	=	Program Required Quantitation Limit

%R 	=	Percent Recovery

RPD	=	Relative Percent Difference

TABLE B3-10, MINIMUM TRAINING AND QUALIFICATIONS REQUIREMENTS

PERSONNEL

REQUIREMENTS a

Radiography Operators c

	Site-specific training based on Waste Matrix Codes and waste material
parameters; requalification every 2 years

Gas Chromatography Technical Supervisors b

Gas Chromatography Operators c

	B.S. or equivalent experience and 6 months previous applicable
experience

Gas Chromatography/Mass Spectrometry Operators c

Mass Spectrometry Operators c

	B.S. or equivalent experience and 1 year independent spectral
interpretation or demonstrated expertise

Gas Chromatography/Mass Spectrometry Technical Supervisors b

Mass Spectrometry Technical Supervisors b

Atomic Absorption Spectroscopy Technical Supervisors b

Atomic Absorption Spectroscopy Operators c

Atomic Mass Spectrometry Operators c

Atomic Emission Spectroscopy Operators c

	B.S. or equivalent experience and 1 year applicable experience

Atomic Mass Spectrometry Technical Supervisors b	B.S. and specialized
training in Atomic Mass Spectrometry and 2 years applicable experience

Atomic Emission Spectroscopy Technical Supervisors b	B.S. and
specialized training in Atomic Emission Spectroscopy and 2 years
applicable experience.

a	Based on requirements contained in USEPA Contract Laboratory Program
Statement of Work for Organics Analysis (Document Number OLM 01.0) and
Statement of Work for Inorganics Analysis (Document Number ILM 03.0).

b	Technical Supervisors are those persons responsible for the overall
technical operation and development of a specific analytical technique.
Refer to the TWCP TIP, Appendix 4, Analysis Processes, for the
qualification requirements for this functional position.  Also refer to
Section A-5a(2)(i) Headspace Analytical Services Manager, or A-5g(1),
Analytical Laboratories Manager, for one of the site-specific titles for
this functional position.  Although the Headspace Analytical Services
Manager or Analytical Laboratories Manager often performs the functional
role of Technical Supervisor during the data generation level review,
other qualified personnel (i.e., as specified in the TWCP TIP) may
perform the role of Technical Supervisor.

c	Operators are those persons responsible for the actual operation of
analytical equipment.

As discussed in Section B1-3b, the RFETS-specific position title for RTR
Operator is Nondestructive Testing (NDT) Technician.  The qualification
requirements for this position are presented in the TWCP TIP, Appendix
3, Measurement Systems, Non-Destructive Testing (NDT); and in
5-NDT-TC-1A, Training, Qualification and Certification of Nondestructive
Testing personnel.

The RFETS-specific position title for an analytical operator is
Chemist/Operator.  The qualification requirements for specific
analytical Chemist/Operators are presented in the TWCP TIP, Appendix 4,
Analysis Processes.

Table B3-11, Testing Batch Data Report Contents

Required Information	Radiography	Visual Examination

(to Confirm RTR)	Visual Verification

of Acceptable Knowledge	Comment

Batch Data Report Date	X	X	X	This date is the date of the QAO release
signature.

Batch number	X	X	X

	Waste Container number	X	X	X	The Waste Container number corresponds to
the Drum number, POC Drum Assembly number, or Standard Waste Box number,
etc.

For some Residues projects, the Waste Container number is NA because
these Residues projects report on the “inner containers”.  A list of
the “inner containers” is included on the cover page of each Residue
Testing Batch Report.  The WEMS database provides a cross-reference
between the inner container numbers and the number of the Drum or POC
Drum Assembly.

Waste stream name and/or number	O	O	O	The waste stream name and number
are documented in RMRS-WIPP-98-100.

Waste Matrix Code	X	X	X	Summary Category Group included in Waste Matrix
Code

Implementing procedure (specific version used)	X	X	X	If procedure cited
contains more than one method, the method used must also be cited.  Can
use revision number, date, or other means to track specific version
used.

Container type	O	O	O	The Container Type corresponds to “Drum”,
“POC Drum Assembly”, or “Standard Waste Box”, etc.

For some Residues projects, the Container type is NA because these
Residues projects report based on the “inner containers”.  A list of
the “inner containers” is included on the cover page of each Residue
Testing Batch Report.  The WEMS database provides a cross-reference
between the inner container numbers and the number of the Drum or POC
Drum Assembly.

Videotape reference	X	X	NA	Reference to videotape(s) applicable to each
container.  For visual examination (for characterization) of newly
generated waste, videotape not required if two trained operators review
the contents of the waste container to ensure correct reporting.

Imaging check	O	NA	NA

	Camera check	NA	O	NA

	Audio check	O	O	NA

Table B3-11, Testing Batch Data Report Contents (continued)

Required Information	Radiography	Visual Examination

(to Confirm RTR)	Visual Verification

of Acceptable Knowledge	Comment

QC check of scales	NA	O	O	Available documented evidence that calibrated
scale(s) were used.  Only applicable if items are weighed during the
visual examination.

QC documentation	X	X	X	If items are weighed during the visual
examination, the scale/balance identification number and the
scale/balance calibration due date are recorded on the applicable
documents.

In addition for Residues, the ITR and QAO review the applicable
documentation to verify that the  scale/balance check weighing
activities are performed satisfactorily; however, this check is not
considered QC documentation and these documents are not included in the
batch reports.

Description of liners and layers of confinement (if possible)	X	X	X	For
some Residues projects, the description of liners and layers of
confinement of the outer container is NA because these Residues projects
report based on the “inner containers”.  A list of the “inner
containers” is included on the cover page of each Residue Testing
Batch Report.  The WEMS database provides a cross-reference between the
inner container numbers and the number of the Drum or POC Drum Assembly.

Indication of vented rigid liners	X	X	X	Only required for containers
with rigid liners.  If RTR is used to verify, then include in Testing
Batch Data Report.

For some Residues projects, the indication of vented rigid liners is NA
because these Residues projects report based on the “inner
containers”.  A list of the “inner containers” is included on the
cover page of each Residue Testing Batch Report.  The WEMS database
provides a cross-reference between the inner container numbers and the
number of the Drum or POC Drum Assembly.

Description of container contents	X	X	X	Provide enough details for
verification of estimated weights for the 12 waste material parameters,
and to identify all discernable waste items, etc..

Verification that the physical form matches the waste stream description
and Waste Matrix Code	X	X	X	Summary Category Group included in the Waste
Matrix Code.

Indication of sealed containers > 4 liters	X	X	X	Verification that
sealed containers greater than 4 liters were NOT detected is documented
on the applicable the data sheet.

Amount of free liquids	X	X	X	Verification that free liquids or
containerized liquids were NOT detected is documented on the applicable
the data sheet.

Estimated weights for the

12 waste material parameters	X	X	X	Table B3-1 lists waste material
parameters.

For some Residues projects, the estimated weights of the outer packaging
is NA because these Residues projects report based on the “inner
containers”.  A list of the “inner containers” is included on the
cover page of each Residue Testing Batch Report.  The WEMS database
provides a cross-reference between the inner container numbers and the
number of the Drum or POC Drum Assembly.

Table B3-11, Testing Batch Data Report Contents (continued)

Required Information	Radiography	Visual Examination

(to Confirm RTR)	Visual Verification

of Acceptable Knowledge	Comment

Container gross weight	X	X	X	The Container gross weight corresponds to
the gross weight of the “Drum”, “POC Drum Assembly”, or
“Standard Waste Box”, etc.

When repackaging retrievably stored waste, the Waste Container gross
weight is NA because, although the net weight of the waste (without
packaging) is recorded, the gross weight of the  Drum or POC Drum
Assembly is not available for measurement at the time of the Visual
Verification activity.

The WEMS database provides a cross-reference between the inner container
numbers and the number of the Drum or POC Drum Assembly.

Container empty weight	O	O	O	Established, documented empty container
weights can be used.

For some Residues projects, the Waste Container empty weight is NA
because these Residues projects report based on the “inner
containers.”  A list of the “inner containers” is included on the
cover page of each Residue Testing Batch Report.  The WEMS database
provides a cross-reference between the inner container numbers and the
number of the Drum or POC Drum Assembly.

Comments	X	X	X

	Reference to or copy of associated NCRs, if any	X	X	X	Copies of data
quality NCRs, if any, are referenced in the Test Batch Data Report and
may be included with the Test Batch Data Report.

Copies of associated NCRs must be available.

Visual examination expert decisions	NA	X	NA	Only applicable if visual
examination expert is consulted during visual examination.

Verify absence of prohibited items	X	X	X	Verification that prohibited
items were NOT detected is documented on the data sheet.

Operator signature and date of test	X	X	X	Signatures for both operators
required for Visual Verification of Acceptable Knowledge.

Signature of visual examination expert and date	NA	X	NA

	Data review checklists	X	X	X	Copies of the completed data generation
level checklists are included in each Testing Batch Data Report.  All
data review checklists are identified.

X –	Required in batch data report.

O –	Information must be documented and traceable; inclusion in batch
data report is optional.

NA –	Not applicable.

Table B3-12, Sampling Batch Data Report Contents

Required Information	Headspace Gas	Solid Sampling	Comment

Batch Data Report Date	X	X	This date is the date of the QAO release
signature

Batch number	X	X

	Waste stream name and/or number	O	O	The waste stream name and number is
documented in RMRS-WIPP-98-100.

Waste Matrix Code	NA	X	Summary Category Group included in Waste Matrix
Code

Procedure (specific version used)	X	X	If procedure cited contains more
than one method, the method used must also be cited.  Can use revision
number, date, or other means to track specific version used.

Waste Container number	X	X	The Waste Container number corresponds to the
Drum number, POC Drum Assembly number, or Standard Waste Box number,
etc.

For some Residues projects, the Waste Container number is NA because
these Residues projects report based on the “inner containers”.  A
list of the “inner containers” is included on the cover page of each
Residue Testing Batch Report.  The WEMS database provides a
cross-reference between the inner container numbers and the number of
the Drum or POC Drum Assembly.

Container type	O	O	The Container Type corresponds to “Drum”, “POC
Drum Assembly”, or “Standard Waste Box”, etc.

For some Residues projects the Container type is NA because these
Residues projects report based on the “inner containers”.  A list of
the “inner containers” is included on the cover page of each Residue
Testing Batch Report.  The WEMS database provides a cross-reference
between the inner container numbers and the number of the Drum or POC
Drum Assembly.

Sample matrix and type	X	X	The sample matrix (e.g., solid) and the
sample type (e.g., TCLP Metals) are documented on the sample collection
data sheet and/or the COC form.

Analyses requested and laboratory	X	X

	Point of origin for sampling	X	X	Location where sample was taken (e.g.,
building number, room, material balance area).

Sample number	X	X

	Sample size	X	X	The sample size (e.g., vial size, sample weight, etc.)
is documented on the sample collection data sheet and/or the COC form.

Table B3-12, Sampling Batch Data Report Contents (continued)

Required Information	Headspace Gas	Solid Sampling	Comment

Sample location	X	X	Location within container where sample is taken.

For HSG, specify what layer of confinement was sampled.

For solids, physical location within the container (e.g., for the Grid
Sampling Method, this location is the randomly selected section of the
sampling pan; for the Cone and Quartering Sampling Method, this location
is the randomly selected opposing quarters).

Sample preservation	X	X	For SUMMA Canister HSG samples: The sample
preservation is equivalent to the Holding Temperature specified in Table
B1-3 (i.e., 0 - 40( C).

For Solid Samples: The method of sample preservation (e.g., cool to 4(
C) is documented on the applicable documentation (e.g., sample
collection data sheet, the COC form, or the refrigerator logsheet).

Person collecting sample	X	X

	Person attaching custody seal	O	O	May or may not be the same as the
person collecting the sample

Chain of Custody record	X	X	Original or copy is allowed.

Sampling equipment numbers	X	X	For disposable equipment: A reference to
the lot for each type of disposable equipment is recorded on the
applicable documentation.

Cross-reference of sampling equipment numbers with associated cleaning
batch numbers	O	X	As applicable to the equipment used for sampling.

For disposable equipment:  A reference to the lot and procurement
records to support cleanliness is sufficient

Drum age	X	NA	Must include all supporting determinative information,
including but not limited to packaging date, equilibrium start time,
storage temperature, and sampling date/time.  If Scenario 3 is used, the
packaging configuration, filter diffusivity, liner presence/absence, and
rigid liner vent hole diameter used in determining the DAC must be
documented.  If Scenario 1 and 2 are used together, the filter
diffusivity and rigid liner vent hole diameter used in determining the
DAC must be documented.  If default values are used for retrievably
stored waste, these values must clearly be identified as such.

Equilibration time	X	NA

	Verification of rigid liner venting	X	NA	Only applicable to containers
with rigid liners

Verification that sample volume taken is small in comparison to the
available volume	X	NA	Must include headspace gas volume when it can be
estimated

Scale calibration	NA	O

	Depth of waste	NA	X	For newly generated waste, if a sampling method
other than coring is used, this is replaced by documentation that a
representative sample has been taken by recording the sample collection
procedure on the applicable document.

Table B3-12, Sampling Batch Data Report Contents (continued)

Required Information	Headspace Gas	Solid Sampling	Comment

Calculation of core recovery	NA	X	For newly generated waste, if a
sampling method other than coring is used, this is replaced by
documentation that a representative sample has been taken by recording
the sample collection procedure on the applicable document.

Co-located core description	NA	X	For newly generated waste, if a
sampling method other than coring is used, this is replaced by
documentation that a QC sample has been taken by recording the sample
collection procedure on the applicable documentation.

Time between coring and subsampling	NA	X	Applicable only to coring

OVA calibration and reading	O	NA	Only applicable to manifold systems.
Must be done in accordance with manufacturer’s specifications.

Field records	X	X	Must contain the following as applicable to the
sampling method used: Collection problems; sequence of sampling
collection; inspection of the solids sampling area; inspection of the
solids sampling equipment; coring tool test; random location of
sub-sample; canister pressure; and ambient temperature and pressure.

Reference to or copy of associated NCRs, if any	X	X	Copies of associated
NCRs must be available.

Operator signature and date and time of sampling	X	X

	Data review checklists	X	X	All data review checklists are identified

X –	Required in batch data report.

O –	Information must be documented and traceable; inclusion in batch
data report is optional.

NA –	Not applicable.

Table B3-13, Analytical Batch Data Report Contents

Required Information	Headspace Gas	Solid Sampling	Comment

Batch Data Report Date	X	X	This date is the date of the QAO release
signature

Batch number	X	X

	Sample numbers	X	X

	QC designation for sample	X	X

	Implementing procedure (specific version used)	X	X	If procedure cited
contains more than one method, the method used must also be cited.  Can
use revision number, date, or other means to track specific version
used.

QC sample results	X	X

	Sample data forms	X	X	Form should contain reduced data for target
analytes and TICs

Chain of Custody	X	X	Original or copy

Gas canister tags	X	NA	Original or copy

Sample preservation	X	X

	Holding time	NA	X

	Cross-reference of field numbers to laboratory sample numbers	X	X

	Date and time analyzed	X	X

Table B3-13, Analytical Batch Data Report Contents (continued)

Required Information	Headspace Gas	Solid Sampling	Comment

Confirmation of spectra used for results	O	O	Analyst must qualitatively
evaluate the validity of the results based on the spectra, can be
implemented as a check box for each sample

TIC evaluation	X	X

	Reporting flags, if any	X	X	Table B3-14 lists applicable flags

Case narrative	X	X

	Reference to or copy of associated NCRs, if any	X	X	Copies of
associated NCRs must be available

Operator signature and analysis date	X	X

	Data review checklists	X	X	All data review checklists are identified

X –	Required in batch data report.

O –	Information must be documented and traceable; inclusion in batch
data report is optional.

NA –	Not applicable.

Table B3-14, Data Reporting Flags

Data Flag	Indicator

B	Analytes detected in blank (Organics / Headspace gases)

B	Analyte blank concentration greater than or equal to 20 percent of
sample concentration prior to dilution corrections (Metals)

E	Analyte exceeds calibration curve (Organics / Headspace gases)

J	Analyte less than PRQL but greater than or equal to MDL (Organics /
Headspace gases)

J	Analyte greater than or equal to IDL but less than 5 times the IDL
before dilution correction (Metals)

U	Analyte was not detected and value is reported as the MDL (IDL for
Metals)

D	Analyte was quantitated from a secondary dilution, or reduced sample
aliquot (Organics / Headspace gases)

Z	One or more QC samples do not meet acceptance criteria

H	Holding times exceeded  (not applicable to Headspace gas analysis)

Table B3-15, TC Levels Expressed as RTL Values in the Waste

ANALYTE	RTL VALUE (MG/KG) a

Metals and Semi-VOCsb

	Arsenic

	Barium

	Cadmium

	Chromium

	Cresols

	1,4-Dichlorobenzene

	2,4-Dinitrotoluene

	Hexachlorobenzene

	Hexachloroethane

	Lead

	Mercury

	Nitrobenzene

	Pentachlorophenol

	Pyridine

	Selenium

	Silver

100

2,000

20

100

4,000

150

2.6

2.6

60

100

4

40

2,000

100

20

100

VOCsc:	Benzene

	Carbon tetrachloride

	Chlorobenzene

	Chloroform

	1,2-Dichloroethane

	1,1-Dichloroethylene

	Methyl ethyl ketone

	Pyridine

	Tetrachloroethylene

	Trichloroethylene

	Vinyl Chloride	10	10

10

2,000

120

10

14

4,000

100

14

10

4

a 	The calculations assume 1) the maximum amount of material suggested
by the TCLP is used; 2) wastes are 100-percent solid (no liquid
fraction); 3) the maximum amount of extraction fluid is used; and 4) all
analytes are 100-percent soluble in the extraction fluid.

b	For metals and SVOCs, RTL value (mg/kg) = (TC level, mg/L) (volume of
extraction fluid, 2 L)/(weight of sample, 0.100 kg)

c	For VOCs, RTL value (mg/kg) = (TC level, mg/L) (volume of extraction
fluid, 0.5 L)/(weight of sample, 0.25 kg)

Table B3-16A, Hydrogen and Methane Analysis Quality Assurance
Objectives a

ANALYTE GASES

CAS NUMBER	PRECISION (%RSD OR RPD)

ACCURACY (%R)

PRQL

(VOL %)

MDL

(VOL %)

COMPLETENESS (%)

Hydrogen	1333-74-0	<25	70-130%	0.1	.05	90

Methane	74-82-8	<25	70-130%	0.1	.05	90

a	The quality assurance objectives shown in this table are site-specific
and are not WIPP-WAP requirements.

Table B3-16B, Summary of Laboratory Quality Control Samples and

Frequencies for Hydrogen and Methane Analysis

QC SAMPLE	MINIMUM FREQUENCY	ACCEPTANCE CRITERIA	CORRECTIVE ACTION a

Method performance samples	7 initially and 4 semi-annually	Meet Table
B3-16A QAOs	Repeat until acceptable

Duplicates 	1 per analytical batch	RPD ( 25 % b	Nonconformance if RPD >
25%

Blanks 	1 per analytical batch	Analytes ( PRQL	Flag data with a “B”

a	Corrective Action is required only if the concentration of a given
analyte exceeds the PRQL for that analyte.

b 	The RPD criterion applies only if the concentration of a given
analyte exceeds the PRQL for that analyte.

QAO	=	Quality Assurance Objective

RPD	=	Relative Percent Difference

PRQL	=	Program Required Quantitation Limits

This page is intentionally blank

B4.	TRU WASTE CHARACTERIZATION USING ACCEPTABLE KNOWLEDGE

B4-1	Introduction

The Resource Conservation and Recovery Act (RCRA) regulations codified
in 40 CFR Parts 260 through 265, 268, and 270, and the New Mexico
Hazardous Waste Management Regulations in Title 20 New Mexico
Administrative Code, Chapter 4, Part 1, (20.4.1 NMAC) Subparts I through
VI, Subpart VIII, and Subpart IX, authorize the use of acceptable
knowledge (AK) in appropriate circumstances by waste generators, or
treatment, storage, or disposal facilities to characterize hazardous
waste.  Acceptable knowledge is described in Waste Analysis: EPA
Guidance Manual for Facilities That Generate, Treat, Store and Dispose
of Hazardous Waste (EPA, 1994).  Acceptable knowledge, as an alternative
to sampling and analysis, can be used to meet all or part of the waste
characterization requirements under the RCRA (EPA, 1994).

Acceptable knowledge includes a number of techniques used to
characterize transuranic (TRU) waste, such as process knowledge, records
of analysis acquired prior to RCRA, and other supplemental sampling and
analysis data (EPA, 1994).  RTR and/or visual examination, headspace gas
sampling and analysis, and homogeneous waste sampling and analysis
(specified in Permit Attachment B1) are used to acquire supplemental
sampling and analysis data to meet the requirements of the Waste
Analysis Plan (WAP) specified in Permit Attachment B.  Acceptable
knowledge is used in TRU waste characterization activities in three
ways:

To delineate TRU waste streams.

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

To assess if TRU wastes are listed (<IP_ADDRESS> NMAC, incorporating 40
CFR §261.31).

Acceptable knowledge is used to assign waste matrix code and EPA
hazardous waste numbers to waste streams and to determine the physical
form of waste (waste material parameter).  The collection and use of
acceptable knowledge information applies to both retrievably stored and
newly generated TRU waste streams.  Determination of radionuclides by
acceptable knowledge is addressed in the TWMM.

Sampling and analysis is performed to confirm acceptable knowledge and
to update and modify initial AK assessments.  Sampling and analysis
includes RTR, visual examination, headspace gas, and homogeneous waste
sampling and analysis.  TRU waste streams undergo applicable provisions
of the acceptable knowledge process prior to management, storage, or
disposal of the waste at WIPP.

B4-2	Acceptable Knowledge Documentation

The RFETS acceptable knowledge information progresses from general
facility information (TRU waste management program information) to the
more detailed waste-specific information (TRU waste stream information).
 This acceptable knowledge information applies at RFETS to both the
retrievably stored and newly generated waste streams and is described in
detail in RF/RMRS-97-018, RFETS TRU Waste Acceptable Knowledge
Supplemental Information.

If the required information is not available for a particular waste,
supplemental information is obtained.  In this case, the waste is
characterized as newly generated waste, and the characterization process
for newly generated waste is presented in Section B-3d(1) of this
document.

B4-2a	Required TRU Waste Management Program Information

TRU mixed waste management program information clearly defines waste
categorization schemes and terminology, provides a breakdown of the
types and quantities of TRU mixed waste that are generated and stored at
RFETS, and describes how waste is tracked and managed at RFETS,
including historical and current operations.  Information related to TRU
mixed waste certification procedures and the types of documentation
(e.g., waste profile forms) used to summarize acceptable knowledge is
also provided.

The overview of RFETS and its TRU waste management operations that is
part of the acceptable knowledge record is contained in RF/RMRS-97-018,
RFETS TRU Waste Acceptable Knowledge Supplemental Information, which
includes:

A map of RFETS with the areas and facilities involved in TRU waste
generation, treatment, and storage identified.

Facility mission description as related to TRU waste generation and
management.

Description of the operations that generate TRU waste at RFETS.

Description of waste identification and characterization schemes used at
RFETS.

Types and quantities of TRU waste generated, including historical
generation through future projections.

Description of how waste streams generated from the same process in one
or many facilities are correlated (e.g., sludge, combustibles, metals,
and glass).

Waste certification procedures for retrievably stored and newly
generated wastes to be sent to the WIPP facility.

B4-2b	Required TRU Waste Stream Information

The process information and data that support the acceptable knowledge
used to characterize TRU waste streams is compiled into
RMRS-WIPP-98-100, Acceptable Knowledge TRU/TRM Waste Stream Summaries.
The information on each waste stream includes:

Area(s) and building(s) from which the waste stream was or is generated.

The waste stream volume and period of waste generation.

Descriptions of the waste generating process for each building,
including processes associated with U134 waste generation, if
applicable.

Process flow diagrams (In the event that a process flow diagram cannot
be created, a description of the waste generating process, rather than a
formal process flow diagram, will be used to satisfy this requirement.
The use of the waste generating process description will be justified,
and the justification will be placed in the auditable record.).

Material inputs that identify the chemical content of the waste stream
and the physical waste form (e.g., glove box materials and chemicals
handled during glove box operations; data obtained through visual
verification of newly generated waste that later undergoes radiography;
information demonstrating neutralization of U134 [hydrofluoric acid] and
waste compatibility, etc.).

The acceptable knowledge written record includes a summary that
identifies all sources of waste characterization information used to
delineate the waste stream.  The basis and rationale for delineating
each waste stream, based on the parameters of interest, is clearly
summarized and traceable to referenced documents.  Assumptions made in
delineating each waste stream also are identified and justified.

If discrepancies are identified in the source documentation, the
inconsistencies are resolved using supplemental information from
interviews, phone contacts, or other correspondence.  A letter
(discrepancy report) documenting resolution to the discrepancy is
maintained as a quality record in the

acceptable knowledge files.  If the discrepancy cannot be resolved, the
letter reflects this and all necessary information.  If discrepancies
exist between required information, then RFETS applies all hazardous
waste codes indicated by the information to the subject waste stream.
Alternatively, RFETS may choose to justify an alternative assignment and
document the justification in the auditable record.  Discrepancy
resolution for the acceptable knowledge information in RF/RMRS-97-018,
RFETS TRU Waste Acceptable Knowledge Supplemental Information, is
documented in PRO-484-WIPP-003, Collection, Review, and Confirmation of
Acceptable Knowledge Documentation.

B4-2b	Required TRU Waste Stream Information  (continued)

Procedures listed in Section B4-3b comply with the following acceptable
knowledge requirements:

Procedures for identifying and assigning the physical waste form of the
waste.  Refer to Section B4-3b(4) and (7).

Procedures for delineating waste streams and assigning Waste Matrix
Codes.  Refer to Section B4-3(5) and (7).

Procedures for resolving inconsistencies in acceptable knowledge
documentation.  Refer to Section B4-3b(4).

Procedures for confirming acceptable knowledge information through
headspace gas sampling and analysis, visual examination and/or RTR, and
homogeneous waste sampling and analysis.  Refer to Section B4-3b(6).

Procedures describing management controls used to ensure prohibited
items (specified in the WAP, Permit Attachment B) are documented and
managed.  Refer to Section B4-3b(3).

Procedures to ensure RTR and visual examination include a list of
prohibited items that the operator shall verify are not present in each
container of waste (e.g., liquids exceeding TSDF-WAC limits, corrosives,
ignitables, reactives, and incompatible wastes).  Refer to Section
B4-3b(3).

Procedures to document how changes to Waste Matrix Codes, waste stream
assignment, and associated EPA hazardous waste numbers based on material
composition are documented for any waste.  Refer to Section B4-3b(5) and
(7).

Procedures for newly generated waste shall describe how acceptable
knowledge is confirmed using either visual verification or radiography
(or VE in lieu of radiography).  Refer to Section B4-3b(6).  Procedures
also describe the criteria for selecting either radiography or VE to
ensure there is documentation and adequate justification of the process
selected.  RFETS newly generated waste is characterized with visual
verification unless the use of radiography in lieu of, or in combination
with, visual verification is justified by the following criteria:

Visual verification was conducted during packaging, but is unacceptable,

Visual verification requires extensive handling of high gram content
waste that results in high radioactive exposure for the VV personnel,
and/or

Where waste packaging is conducted at numerous locations generating
small quantities of TRU waste, requiring a large number of VV personnel.

Where waste was originally packaged as low-level waste, but subsequently
determined to be TRU.

B4-2c	Supplemental Acceptable Knowledge Documentation

Supplemental acceptable knowledge information, as appropriate, is
collected to support required TRU waste stream information.  This
supplemental information is included in the acceptable knowledge written
record.  Supplemental acceptable knowledge documentation that may be
used (if available) in addition to the required information specified
above include, but are not limited to, the following information:

Process design documents (e.g., Title II Design).

Standard operating procedures.

Preliminary and final safety analysis reports and technical safety
requirements.

Waste packaging logs.

Test plans or research project reports that describe reagents and other
raw materials used in experiments.

Site databases (e.g., chemical inventory database for Superfund
Amendments and Reauthorization Act Title III requirements).

Information from RFETS personnel (e.g., documented interviews).

Standard industry documents (e.g., vendor information).

Analytical data relevant to the waste stream, including results from
fingerprint analyses, spot checks, or routine verification sampling.
This may also include new information acquired apart from the
confirmatory process which supplements required information (e.g.,
visual examination not performed in compliance with the WAP).

Material Data Safety Sheet, product labels, or other product package
information.

Sampling and analysis data from comparable or surrogate waste streams
(e.g., residues, equivalent nonradioactive materials).

Laboratory notebooks that detail the research processes and raw
materials used in an experiment.

All specific, relevant supplemental acceptable knowledge documentation
assembled and used in the acceptable knowledge process, whether it
supports or contradicts any required acceptable knowledge documentation,
is identified and an explanation provided for its use (e.g.,
identification of a toxicity characteristic).  Supplemental
documentation may be used to further document the rationale for the
hazardous characterization results.

B4-3	Acceptable Knowledge Training, Procedures and Other Requirements

RFETS uses a three phase process to characterize TRU waste by means of
acceptable knowledge information:  1) compiling enough acceptable
knowledge documentation for an auditable record, 2) confirming