51 B1 1a( 1) Summary Category S5000 Requirements All waste containers or randomly selected containers from waste streams that meet the conditions for reduced headspace gas sampling ( Section B 3a( 1); designated as summary category S5000 ( Debris waste) shall be categorized under one of the sampling scenarios shown in Table B1 5 and depicted in Figure B1 1. If the container is categorized under Scenario 1, the applicable drum age criteria( DAC) from Table B1 6 must be met prior to headspace gas sampling. If the container is categorized under Scenario 2, the applicable Scenario 1 DAC from Table B1 6 must be met prior to venting the container and then the applicable Scenario 2 DAC from Table B1 7 must be met after venting the container. The DAC for Scenario 2 containers that contain filters or rigid liner vent holes other than those listed in Table B1 7 shall be determined using footnotes " a" and " b" in Table B1 7. Containers that have not met the Scenario 1 DAC at the time of venting must be categorized under Scenario 3. Containers categorized under Scenario 3 must be placed into one of the Packaging Configuration Groups listed in Table B1 8. If a specific packaging configuration cannot be determined based on the data collected during packaging and/ or repackaging ( Attachment B, Section B 3( d)( 1), a conservative default Packaging Configuration Group of 3 for drums and 6 for Standard Waste Boxes ( SWBs) must be assigned, provided the drums do not contain pipe component packaging. If a container is designated as Packaging Configuration Group 4 ( i. e., a pipe component), the headspace gas sample must be taken from the pipe component headspace. The DAC for Scenario 3 containers that contain rigid liner vent holes that are undocumented during packaging ( Attachment B, Section B 3( d)( 1), repackaging ( Attachment B, Section B 3( d)( 1), and/ or venting ( Section B1 1a[ 6][ ii]) shall be determined using the default conditions in footnote " b" in Table 1 9. The DAC for Scenario 3 containers that contain filters that are either undocumented or are other than those listed in Table B1 9 shall be determined using footnote " a" in Table B1 9. Each of the Scenario 3 containers shall be sampled for headspace gas after waiting the DAC in Table B1 9 based on its packaging configuration ( note: Packaging Configuration Groups 4, 5, and 6 are not summary category group dependent, and SWB requirements apply when the SWB itself is used for the direct loading of waste).

Drum age criteria apply only to 55 gallon drums and standard waste boxes. Drum age criteria for all other container types must be established through permit modification prior to acceptance of these containers. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

52 B1 1a( 2) Summary Category S3000/ S4000 Requirements All waste containers or randomly selected containers from waste streams that meet the conditions for reduced headspace gas sampling ( Section B 3a( 1); designated as summary categories S3000 ( Homogeneous solids) and S4000 ( Soil/ gravel) shall be categorized under one of the sampling scenarios shown in Table B1 5 and depicted in Figure B1 1. If the container is categorized under Scenario 1, the applicable DAC from Table B1 6 must be met prior to headspace gas sampling. If the container is categorized under Scenario 2, the applicable Scenario 1 DAC from Table B1 6 must be met prior to venting the container and then the applicable Scenario 2 DAC from Table B1 7 must be met after venting the container. The DAC for Scenario 2 containers that contain filters or rigid liner vent holes other than those listed in Table B1 7 shall be determined using footnotes " a" and " b" in Table B1 7. Containers that have not met the Scenario 1 DAC at the time of venting must be categorized under Scenario 3. Containers categorized under Scenario 3 must be placed into one of the Packaging Configuration Groups listed in Table B1 8. If a specific packaging configuration cannot be determined based on the data collected during packaging and/ or repackaging ( Attachment B, Section B 3( d)( 1), a conservative default Packaging Configuration Group of 3 for drums and 6 for Standard Waste Boxes ( SWBs) must be assigned, provided the drums do not contain pipe component packaging. If a container is designated as Packaging Configuration Group 4 ( i. e., a pipe component), the headspace gas sample must be taken from the pipe component headspace. The DAC for Scenario 3 containers that contain rigid liner vent holes that are undocumented during packaging ( Attachment B, Section B 3( d)( 1), repackaging ( Attachment B, Section B 3( d)( 1), and/ or venting ( Section B1 1a[ 6][ ii]) shall be determined using the default conditions in footnote " b" in Table B1 10. The DAC for Scenario 3 containers that contain filters that are either undocumented or are other than those listed in Table B1 10 shall be determined using footnote " a" in Table B1 10. Each of the Scenario 3 containers shall be sampled for headspace gas after waiting the DAC in Table B1 10 based on its packaging configuration ( note: Packaging Configuration Groups 4, 5, and 6 are not summary category group dependent, and SWB requirements apply when the SWB itself is used for the direct loading of waste). AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

53 B1 1a( 3) General Requirements The determination of packaging configuration consists of identifying the number of confinement layers and the identification of rigid poly liners when present. AMWTP shall use either the default conditions specified in Tables B1 7 through B1 10 for retrievably stored waste or the data documented during packaging ( Attachment B, Section B 3( d)( 1), repackaging ( Attachment B, Section B 3( d)( 1), and/ or venting ( Section B1 1a[ 6][ ii]) for determining the appropriate DAC for each container from which a headspace gas sample is collected. These drum age criteria are to ensure that the container contents have reached 90 percent of steady state concentration within each layer of confinement ( Lockheed 1995, BWXT 2000). The following information must be reported in the headspace gas sampling documents for each container from which a headspace gas sample is collected:

 sampling scenario from Table B1 5 and associated information from Tables B1 6 and/ or TableB1 7;  the packaging configuration from Table B1 8 and associated information from Tables B1 9, or B1 10, including the diameter of the rigid liner vent hole, the number of inner bags, the number of liner bags, the presence/ absence of drum liner, and the filter hydrogen diffusivity;  the permit   required equilibrium time; and  the drum age For all retrievably stored waste containers, the rigid liner vent hole diameter must be assumed to be 0.3 inches unless a different size is documented during drum venting or repackaging. For all retrievably stored waste containers, the filter hydrogen diffusivity must be assumed to be the most restrictive unless container specific information clearly identifies a filter model and/ or filter diffusivity characteristic that is less restrictive. For all retrievably stored waste containers that have not been repackaged, acceptable knowledge shall not be used to justify and packaging configuration less conservative than the default ( i. e., Packaging Configuration Group 3 for drums and 6 for SWBs). For information reporting purposes listed above, AMWTP may report the default packaging configuration for retrievably stored waste without further confirmation.

All waste containers with unvented rigid containers greater than 4 liters ( exclusive of rigid poly liners) are either subject to innermost layer of containment sampling or are vented prior to initiating drum age and equilibrium criteria. When sampling the rigid poly liner under Scenario 1, the sampling device must form an airtight seal with the rigid poly liner to ensure that a representative sample is collected ( using a sampling needle connected to the sampling head to pierce the rigid poly liner, and that allows for the collection of a representative sample, satisfies this requirement). HSG samples are analyzed for the analytes listed in Table B3 2. Consistent with the footnote " a" in Table B1 8, any waste container that cannot be assigned a packaging configuration specified in Table B1 8, shall not be shipped to, or accepted for disposal at WIPP. If additional packaging configurations are identified, an appropriate Permit Modification will be submitted to incorporate the DAC using the methodology BWXT ( 2000). AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

54 Drum age criteria apply only to 55 gallon drums and standard waste boxes. Drum age criteria for all other container types must be established through permit modification prior to acceptance of these containers at WIPP.

The sampling manifold and sampling heads used with the On Line Integrated HSG System and SUMMA ® or equipment meet the appropriate general guidelines established in EPA's Compendium Method TO 14 as modified and amended in the WIPP RCRA Part B Permit, Attachment B, Waste Analysis Plan. Samples are directed to an analytical instrument instead of being collected in SUMMA or equivalent canisters when a singlesample on line integrated manifold system is used. The leak proof and inert nature of the integrated holding area interior surface has been demonstrated and documented. Since samples will not be transported to another location when using on line integrated sampling/ analysis systems, the sample custody requirements of Section B1 4 and B1 5 do not apply. The same sampling manifold and sampling heads are used with on line integrated sampling/ analysis systems and all of the requirements associated with sampling manifolds and sampling heads will be met. The HSG On Line Integrated System utilize combined on line batch QC samples as specified in Section B1 1b, Table B1 2, and Table B1 3.

HSG sampling of waste drums at the AMWTP is conducted per INST OI 13, Drum Vent/ Headspace Gas Sample Operations. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

55 B1 1a( 4) Manifold Headspace Gas Sampling The HSG sampling protocol employs a multiport manifold capable of collecting samples from a single sample head or from in line QC sample gas cylinders ( blank/ nitrogen and reference standard), and routing the sample directly to the GC/ MS unit for analysis and QC purposes. The sampling equipment is leak checked and cleaned prior to first use and as needed thereafter. The manifold is evacuated to 0.0039 inches Hg ( 0.10 mm Hg) prior to sample collection. The manifold inlet valve is attached to a changeable filter connected to either a side port needle sampling head capable of forming an airtight seal ( for puncturing the filter or rigid poly liner when necessary), or a drum punch sampling head capable of forming an airtight seal ( capable of punching through the metal lid of a drum for sampling through the drum lidThis filter/ drum punch sampling head uses a combination drill/ hollow stem sampling tube/ carbon composite filter to penetrate the drum lid and liner without sparking. The filter/ drum punch sampling head design allows for the collection of the headspace gas sample under the liner lid, and assembly is seated to provide a WIPP WAP compliant filter for the drum.

The manifold is equipped with a purge assembly that allows applicable QC samples to be collected through all sampling components that may affect compliance with the QAOs. AMWTP will demonstrate and document the effectiveness of the sampling equipment design in meeting the QAOs. Field blanks are samples of room air collected in the sampling area in the immediate vicinity of the waste container to be sampled.

The manifold, associated sampling head, and headspace gas sample volume are designed to ensure the collection of representative samples. The manifold internal volume must be calculated and documented in a field logbook dedicated to headspace gas sampling collection. Internal manifold and sample line volume is small in comparison to the volume of the headspace. The total volume of headspace gases collected during each sampling operation is obtained by adding the sampled volume with the manifold volume and is documented in design verification documentation.

The sample side of the sampling manifold consists of the following major components:

  A sampling head with leak tight connections to the headspace sampling manifold.

  GC grade stainless steel tubing with sufficient flexibility to allow any necessary movement of the sampling head caused by compression of the waste container to the sample head.

  The headspace sampling manifold pressure sensor( s) is pneumatically connected to the headspace sampling manifold. The headspace sampling manifold pressure sensor( s) is capable of measuring absolute pressure in the range from 0.05 to 1,000 mm Hg. Its resolution is ± 0.01 mm Hg at 0.05 mm Hg. The pressure sensor( s) has an operating range from approximately 15 ° C to 50 ° C. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

56   The On Line Integrated HSG System needs only one port for the collection of samples. All ports ( inlet and outlet) utilize solenoid actuated, normally closed valves to ensure an air tight seal when the system not in use. All sampling ports and piping have VCR ® fittings for connection to ensure air tight connections and to prevent degradation of the fittings on the manifold.

  An oil vacuum pump is used to reduce the pressure in the headspace sampling manifold to less than or equal to 0.05 mm Hg. Precautions have been taken to prevent diffusion of oil vapors back to the manifold including the use of a non interfering silicone based lubricant, continuous pump operation and piping dimensioning from the pump to the manifold. Compliance is demonstrated by several months of operation and equipment blank analyses without indication of contamination due to oil diffusion.

  The system was designed with a minimum distance between the sample head and the valve that isolates the pump from the manifold in order to minimize the dead volume in the manifold.

  The manifold is equipped with an PID ( photoionization detector) capable of detecting the analytes listed in Table B3 2. The Organic Vapor Analyzer ( OVA) measures total VOC concentration below the lowest headspace gas PRQL based on manufacturer's specifications. Detection of l, l, 2 trichloro l, 2,2 trifluoroethane is not possible using the photoionization detector used. The OVA measurement is confirmed by the collection and GC/ MS analysis of field blanks and as specified in the method requirements, equipment blanks to check for manifold cleanliness.

The standard side of the sampling manifold consists of the following major components:

  A cylinder of compressed zero nitrogen is used to clean the manifold between samples and provide gas for the collection of equipment blanks or on line blanks. The high purity gas is certified by the manufacturer to contain less than one ppm total VOCs. The gases are metered into the standard side of the manifold using solenoid controlled valves that are corrosion proof and that do not allow for the introduction of manifold gas into the purge gas cylinders. Gas quality is of ultra high purity grade and metered by a two stage stainless steel regulator.

  Cylinders of field reference standard gases or on line control sample gases are used for evaluating the accuracy of the headspace sampling process. Field reference standard gas is delivered through a flow regulating two stage stainless steel regulator. The field reference standard gas is certified by the manufacturer to contain analytes from Table B3 2 of Permit Attachment B3 at known concentrations. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

57   A humidifier filled with ASTM Dl 193 77 ( ASTM 1983b) Type I or Type II water is connected to the headspace sampling manifold between the compressed gas cylinder and the sampling manifold. Dry gases flowing to the purge assembly pick up moisture from the humidifier. Moisture is added to the dry gases to assist with system cleaning between headspace gas sample collection and to condition equipment blanks and field reference standards.

  A purge assembly allows the sampling head ( sample side) to be connected to the standard side of the manifold.

  A pressure regulator connected to the purge assembly monitors the gas flow rate through the purge assembly. The pressure through the purge assembly is monitored to assure excess flow during cleaning activities and during QC sample collection. Maintaining excess flow prevents ambient air from contaminating QC samples and allow samples of gas from the compressed gas cylinders to be collected near ambient pressures.

  An ambient pressure sensor with a measurement range for the ambient barometric pressures is in the sampling/ manifold location. It is kept in the sampling area during sampling operations. The ambient pressure sensor has a full range of at least 500 to 800 mm Hg and is kept in the sampling area during sampling operations. Resolution is 1.0 mm Hg or less and calibration performed by the manufacturer is based on National Institute of Standards and Technology ( NIST), or equivalent, standards.

  A temperature sensor with a minimum range of 18 ° C to 50 ° C is in the sampling/ manifold location. The temperature sensor calibration is traceable to NIST, or equivalent, standards. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

58 B1 1a( 5) Direct Canister Headspace Gas Sampling This Section is not applicable to the AMWTP.

B1 1a( 6) Sampling Heads The AMWTP samples through the filter and preserves the integrity of the drum to contain radionuclides ( e. g., replace the damaged filter, replace set screw in filter housing, seal the punched drum lid).

B1 1a( 6)( i) Sampling Through the Filter To sample the drum headspace gas through the drum's filter, the AMWTP uses, a side port needle ( e. g., a hollow needle sealed at the tip with a small opening on its side close to the tip) pressed through the filter and into the headspace beneath the drum lid. This permits the gas to be drawn into the manifold or directly into the canister( s). All of the general method requirements, sampling apparatus requirements, and QC requirements described in this section are met in addition to the following requirements that are pertinent to drum headspacegas sampling through the filter:

  The lid of the drum's 90 mil poly rigid liner shall contain a hole for venting to the drum headspace. A representative sample cannot be collected from the drum headspace until the 90 mil poly liner has been vented to the drum. If the DAC for Scenario 1 is met, a sample may be collected from inside the 90 mil rigid poly liner. If the sample is collected by removing the drum lid, the sampling device shall form an airtight seal with the rigid poly liner to prevent the intrusion of outside air into the sample ( using a sampling needle connected to the sampling head to pierce the rigid poly liner satisfies this requirement). If headspace gas samples are collected from the drum headspace prior to venting the 90 mil rigid poly liner, the sample is not acceptable and a nonconformance report shall be prepared, submitted, and resolved. Nonconformance procedures are outlined in Section B3.

For sample collection, the drum's filter shall be sealed to prevent outside air from entering the drum and diluting and/ or contaminating the sample. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

59 The sampling head for collecting drum headspace by penetrating the filter consists of a side port needle, a filter to prevent particles from contaminating the gas sample, and an adapter to connect the side port needle to the filter. To prevent cross contamination, the sampling head is cleaned or replaced after sample collection, after field reference standard collection, and after field blank collection. The following requirements shall also be met:

The housing of the filter shall allow insertion of the sampling needle through the filter element or a sampling port with septum that bypasses the filter element into the drum headspace.

  The side port needle shall be used to reduce the potential for plugging.

  The purge assembly shall be modified for compatibility with the side port needle.

B1 1a( 6)( ii) Sampling Through the Drum Lid by Drum Lid Punching A HSG sample is collected through the drum lid at the time of drum punching ( i. e., samples are not collected through the carbon filter). This sampling method and the overall system preserves the integrity of the drum to contain radionuclides and maintaining an air tight seal by the installation and seating of the sampling stem and carbon composite filter into the drum lid.

The process of sampling through the drum lid begins by raising the waste container up to the sample chamber seal and applying a minimum of 200 pounds force between the drum and the seal, which creates an airtight seal around the area to be penetrated. Seal integrity is tested by pumping the volume within the seal to 300 torr or less. The pressure transducer measures the seal housing chamber initial and final pressures over a 15 second period. An acceptable seal test has a leak rate of less than 50 torr per minute. To sample the drum headspace gas through the drum lid, the lid is breached using a sparkless drill/ filter assembly. To assure that the sample collected is representative, all of the appropriate general method requirement for TRU waste characterization, sampling apparatus requirements, and QC requirements specified in EPA's Compendium Method TO 14 are met in addition to the following requirements:

  The seal between the drum lid and sampling head minimizes the intrusion of ambient air.

  All components of the drum sampling system that come into contact with sample gases are purged with humidified nitrogen prior to sample collection.

  On line blanks and on line field reference standards are collected through all the components of the punch that contact the headspace gas sample. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

60   Once the drum lid has been breached and the filter seated, drill rotation ceases. This ensures liner penetration.

  Because pressure increases may occur during sealing of the drum punch to the drum lid, provisions are made to relieve potential drum pressure increases during drum punch operations.

  The lid of the drum's 90 mil rigid poly liner shall contain a hole for venting to the drum headspace. The drill filter assembly design ensures penetration of drum poly liners. A representative sample cannot be collected from the drum headspace until the 90 mil rigid poly liner has been vented to the drum. If the DAC for Scenario 1 is met, a sample may be collected from inside the 90 mil rigid poly liner. If, for any reason, headspace gas samples are collected from the drum headspace prior to venting the poly liner, the sample is not acceptable and a nonconformance report is prepared, submitted, and resolved. Nonconformance procedures are outlined in Section B3 13.

  During sampling, if the drum contains an existing carbon composite filter, it is sealed to prevent outside air from entering the drum using a tested sealing cap and clamp mechanism.

  A flow indicating device, which monitors excess flow of purge gases ( for system purge) is pneumatically connected to the drum punch assembly and controlled by means of the system's programmable logic control ( PLC) software.

  The drum sampling system is firmly seated to the drum lid using a pneumatic lifting bladder; lifting the drum and creating a minimum of 200 pounds of seal force between the drum lid and seal. This is continuously monitored and adjusted by the PLC software.

  If the headspace gas sample is not taken at the time of drum punching, the presence and diameter of the rigid liner vent hole shall be documented during the punching operation for use in determining an appropriate Scenario 2 DAC.

B1 1a( 6)( iii) Sampling Through a Pipe Overpack Container Filter Vent Hole This Section is not applicable to the AMWTP. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

61 B1 1b Quality Control For the On Line Integrated HSG System, QC samples are collected and analyzed on a per on line batch basis. An on line batch is the number of headspace gas samples collected within a 12 hour period using the same online integrated analysis system as described in INST OI 13, Drum Vent/ Head Space Sample Operations. The analytical batch requirements are specified by the analytical method being used in the on line system. Table B1 2 provides a summary of field QC sample frequency requirements, and Table B1 3 provides a summary of QC sample acceptance criteria.

For the On Line Integrated HSG System, the on line batch QC samples serve as combined sampling batch/ analytical batch QC samples as follows:

  The on line blank replaces the equipment blank and laboratory blank.

  The on line control sample replaces the field reference standard and laboratory control sample.

  The on line duplicate replaces the field duplicate and laboratory duplicate.

The acceptance criteria for on line batch QC samples are the same as for the sampling batch and analytical batch QC samples they replace. Acceptance criteria are shown in Table B1 3. A separate field blank is collected and analyzed for each on line batch. However, if the results of a field blank collected through the sampling manifold meets the acceptance criterion, a separate on line blank need not be collected and analyzed.

The Site Quality Assurance Officer ( SQAO) monitors and documents field QC sample results and fills out a nonconformance report if acceptance or frequency criteria are not met. The SPM also ensures appropriate corrective action is taken if acceptance criteria are not met.

B1 1b( 1) Field Blanks Field blanks are collected to evaluate background levels of program required analytes. Field blanks are collected prior to sample collection, and at a frequency of one per sampling batch. The SPM uses the field blank data to assess impacts of ambient contamination, if any, on the sample results. Field blank results determined by gas GC/ MS or gas chromatography/ flame ionization ( GC/ FID) detection are acceptable if the concentration of each VOC analyte is less than or equal to three times the method detection limit ( MDL) listed in Table B3 2. A nonconformance report is initiated and resolved if the final reported QC sample results do not meet the acceptance criteria. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

62 B1 1b( 2) Equipment Blanks Equipment blanks shall be collected to assess cleanliness prior to first use after cleaning of all sampling equipment. On line equipment/ manifold blanks are collected to assess cleanliness prior to first use after cleaning of all sampling equipment. On line blanks are used to assess equipment cleanliness as well as analytical contamination. After the initial cleanliness check, equipment blanks collected through the manifold shall be collected at a frequency of one per sampling batch for VOC analysis or one per day, whichever is more frequent. The SPM uses the on line equipment/ manifold blank data to assess impacts of potentially contaminated sampling equipment on the sample results. Equipment blank results determined by GC/ MS or GC/ FID are acceptable if the concentration of each VOC analyte is less than or equal to three times the MDL listed in Table B3 2. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

63 B1 1b( 3) Reference Standards Field reference standards are used to assess the accuracy with which the sampling equipment collects VOCs samples into SUMMA ® or equivalent canisters prior to first use of the sampling equipment. The on line control sample is used to assess the accuracy with which the sampling equipment collects VOC samples as well as an indicator of analytical accuracy for the on line sampling system. Field reference standards for VOC analysis contains a minimum of six of the analytes listed in Table B3 2 at concentrations within a range of 10 to 100 ppmv and greater than the MDL for each compound.

Field reference standards have a known valid relationship to a nationally recognized standard ( e. g., NIST). If NIST traceable standards are not available and commercial gases are used, a Certificate of Analysis from the manufacturer documenting traceability is required. Commercial stock gases are not used beyond their manufacturer specified shelf life.

After the initial accuracy check, on line control samples are collected through the system at a frequency of one per on line batch. The QAOs for accuracy for each tested compound has a recovery of 70 to 130 percent. For the direct canister method, field reference standards collection may be discontinued if the field reference standard results demonstrate the QAO for accuracy specified in Section B3. Field reference standard results are acceptable if the accuracy for each tested compound has a recovery of 70 to 130 percent.

B1 1b( 4) Field Duplicates Duplicates are collected sequentially and in accordance with Table B1 1. Field duplicates also serve as a measure of analytical precision for the on line sampling system. Field duplicate results are acceptable if the relative percent difference is less than or equal to 25 for each tested compound found in concentrations greater than the PRQL in both duplicates.

B1 1c Equipment Testing, Inspections, and Maintenance All sampling equipment components that come into contact with headspace sample gas are constructed of relatively inert materials such as stainless steel or Teflon ® . Stainless steel components are cleaned, passivated, or procured as GC grade.

To minimize the potential for cross contamination of samples, the headspace gas sampling manifolds and On Line Integrated HSG System are cleaned and leak checked prior to each sampling event. Procedures used for cleaning and preparing the manifold use the general guidelines that are appropriate for TRU waste characterization established by the EPA in the Compendium Method TO 14 and is discussed in INST OI 13, Drum Vent/ Head Space Sample Operation. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

64 B1 1c( 1) Headspace Gas Sample Canister Cleaning This Section is not applicable to the AMWTP.

B1 lc( 2) Sampling Equipment Initial Cleaning and Leak Check The on line system and sampling heads that come into contact with headspace gas are thoroughly inspected and cleaned prior to assembly. The on line system is purged with humidified nitrogen and leak checked after assembly. This cleaning is repeated if the on line system is contaminated to the extent that the routine system cleaning is inadequate.

B1 1c( 3) Sampling Equipment Routine Cleaning and Leak Check The on line system and sampling head is cleaned and checked for leaks in accordance with the cleaning and leak check procedures described in EPA's Compendium Method TO 14. The cleaning procedure is conducted after headspace gas samples; after on line duplicate collection; after on line blank collection; and after the additional cleaning required for field reference standard ( on line control sample) collection has been completed.

VOCs are removed from the internal surfaces of the on line system to levels that are less than or equal to three times the MDLs of the analytes listed in Table B3 2, as determined by analysis of an equipment blank or through use of an OVA. When not in use, the manifold shall be demonstrated clean before storage with a positive pressure of high purity gas ( i. e., zero air, nitrogen, or helium) in both the standard and sample sides.

Sampling is suspended and corrective actions are taken when the analysis of an equipment blank indicates that the VOC limits have been exceeded or if a leak test fails. The SPM ensures that corrective action has been taken prior to resumption of sampling.

B1 1c( 4) On Line System Cleaning After Field Reference Standard Collection The sampling system is specifically cleaned after a field reference standard has been collected. The HSG sampling system is designed to automatically flush/ clean the entire system ( evacuate and pressurize with humidified nitrogen) and adequately clean the system's internal surfaces for both the sample and standard side. After completing this protocol and prior to collecting another sample, the system cleaning verification using the OVA and leak check is also performed in accordance with INST OI 13, Drum Vent/ Head Space Sample Operations. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

65 B1 1c( 5) Sample Head Cleaning To prevent cross contamination, the needle, drill/ filter assembly, airtight fitting , sample chamber and replaceable filter of the sampling heads are cleaned in accordance with INST OI 13, Drum Vent/ Head Space Sample Operation, procedures which use the cleaning procedures described in EPA in the Compendium Method TO 14 prior to use or reuse.

The sampling system is designed to automatically flush the entire system ( evacuate and pressurize with humidified zero nitrogen) and adequately clean the system's internal surfaces. After completing this protocol and prior to collecting another sample, the system cleaning verification using the OVA and leak check is also performed.

B1 1d Equipment Calibration and Frequency The manifold pressure sensor are certified prior to initial use and then periodically ( annually or shorter frequency) as described in MP CMNT 10.1, Maintenance Management, using NIST, or equivalent traceable standards. If necessary, the pressure indicated by the pressure is temperature compensated. The ambient air temperature sensor, if present, is certified prior to initial use, then annually, to NIST traceable, or equivalent, temperature standards.

The OVA is calibrated once per day, prior to first use, or as necessary according to the manufacturer's specifications in accordance with INST TRUW 8.2.1, HSG Calibration. If OVA calibration period is greater than one day, verification of calibration is performed each day. Calibration gases for the OVA are certified to contain isobutylene at the manufacturers recommended concentrations. The balance of the OVA calibration gas is consistent with the manifold purge gas when the OVA is used ( i. e., zero air, nitrogen, or helium).

Analytical equipment is calibrated and verified as specified in Table B3 3 for Gas VOCs.

B1 2 Sampling of Homogeneous Solids and Soil/ Gravel This section describes the requirements for collecting samples of TRU waste classified as homogeneous solids and soils/ gravels. Sampling protocols are based upon methods similar to those approved by EPA methods and American Society for Testing and Materials ( ASTM) and are implemented in INST OI 16, Drum Coring Operations.

Sampling protocols are designed for characterization of solid process residues and soils on a waste stream basis. They are also designed to ensure that representative samples of these wastes, including QC samples, are consistently collected and transferred to the responsible laboratory in a manner that maintains their full integrity. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

66 The chosen strategy is designed to provide the analytical laboratories the minimum amount of required sample, to minimize sample handling and the quantity of investigation derived waste. The waste is analyzed for the target analytes specified in Tables B3 4, B3 6, and B3 8.

Sampling methods not identified in this section shall not be used. If a sampling method is proposed for use which has not been identified in this section, the sampling method, protocol and detailed sampling plan shall be submitted to the SPM for submittal to the CBFO for approval. The CBFO will determine the need for permit modification and approval by NMED. As new methods are submitted to CBFO and approved by NMED, they will be added to this section.

B1 2a Methods Requirements The methods used to collect samples of TRU waste classified as homogeneous solids and soil/ gravel from waste containers is such that the samples are representative of the waste from which they are taken. To minimize the quantity of investigation derived waste, the laboratories conducting the analytical work will receive no more than is required for analysis, based on the analytical methods. Homogeneous solids and soil/ gravel samples are handled in accordance with the specifications presented in Table B1 4.

A sufficient number of samples are collected to adequately represent the waste being sampled. Debris waste ( S5000) is not sampled, and debris that may be present in waste streams defined as Summary Category Groups S3000 or S4000 is not sampled.

Samples of retrievably stored waste containers will be collected using appropriate coring equipment or other EPA approved methods to collect a representative sample. Newly generated wastes that are sampled from a process as it is generated may be sampled using EPA approved methods, including scoops and ladles, that are capable of collecting a representative sample. All sampling and core sampling will comply with the QC requirements specified in B1 2b.

B1 2a( 1) Core Collection Coring tools are used to collect cores of homogenous solids and soil/ gravel from waste containers, when possible, in a manner that minimizes disturbance to the core. A rotational coring tool ( i. e., a tool that is rotated longitudinally), similar to a drill bit, to cut, lift the waste cuttings, and collect a core from the bore hole, is used to collect sample cores from waste containers. For homogenous solids and soil/ gravel that are relatively soft, non rotational coring tools may be used in lieu of a rotational coring tool. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

67 The following requirements apply to the use of coring tools:

  Each coring tool shall contain a removable tube ( liner) that is constructed of fairly rigid material unlikely to affect the composition and/ or concentrations of target analytes in the sample core. Materials that are acceptable for use for coring device sleeves and end caps are polycarbonate, teflon, or glass for most samples, and stainless steel or brass if samples are not to be analyzed for metals. The AMWTP uses polycarbonate sleeves and Teflon lined end caps that are cleaned in accordance with B1 2b prior to use. An equipment blank is taken prior to first use to ensure the absence of target analytes. Liner outer diameter is no more than 2 in. and no less than one in. Liner wall thickness is recommended to be no greater than 1/ 16 in. Before use, the liner is cleaned in accordance the requirements in Section B1 2b. The liner fits flush with the inner wall of the coring tool and shall be of sufficient length to hold a core that is representative of the waste along the entire depth of the waste. The depth of the waste is calculated as the distance from the top of the sludge to the bottom of the drum ( based on the thickness of the liner and the rim at the bottom of the drum).

The liner material is sufficientiently transparent to allow visual examination of the core after sampling. If sub sampling is not conducted immediately after core collection and liner extrusion, then end caps constructed of material unlikely to affect the composition and/ or concentrations of target analytes in the core ( e. g., Teflon ® ) is placed over the ends of the liner. End caps shall fit tightly to the ends of the liner.

  A spring retainer is used with each coring tool when the physical properties of the waste are such that the waste may fall out of the coring tool's liner during sampling activities. The spring retainer is constructed of relatively inert material ( e. g., stainless steel or Teflon ® ) and its inner diameter shall not be less than the inner diameter of the liner. Before use, spring retainers are cleaned in accordance with the requirements given in Section B1 2b.

  Coring tools may have an air lock mechanism that opens to allow air inside the liners to escape as the tool is pressed into the waste ( e. g., ball check valve). If used, this air lock mechanism shall also close when the core is removed from the waste container.

  After disassembling the coring tool, a device ( extruder) to forcefully extrude the liner from the coring tool is used if the liner does not slide freely. All surfaces of the extruder that may come into contact with the core have been cleaned in accordance with the requirements in Section B1 2( b) prior to use.

  Coring tools are of sufficient length to hold the liner and have been constructed to allow placement of the liner leading edge as close as possible to the coring tools leading edge.

All surfaces of the coring tool that have the potential to contact the sample core or sample media are cleaned in accordance with the requirements in Section B1 2( b) prior to use. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

68   The leading edge of the coring tools may be sharpened and tapered to a diameter equivalent to, or slightly smaller than, the inner diameter of the liner to reduce the drag of the homogenous solids and soil/ gravel against the internal surfaces of the liner, thereby enhancing sample recovery.

  Rotational coring tools have a mechanism to minimize the rotation of the liner inside the coring tool during coring activities, thereby minimizing physical disturbance to the core.

  Rotational coring is conducted in a manner that minimizes transfer of frictional heat to the core, thereby minimizing potential loss of VOCs.

  Non rotational coring tools shall be designed such that the tool's Kerf width is minimized. Kerf width is defined as one half of the difference between the outer diameter of one tool and the inner diameter of the tool's inlet.

B1 2a( 2) Sample Collection Sampling of cores are conducted in accordance with the following requirements:

  Sampling is conducted as soon as possible after core collection. If a substantial delay ( i. e., more than 60 minutes) is expected between core collection and sampling, the core shall remain in the liner and the liner shall be capped at each end. If the liner containing the core is not extruded from the coring tool and capped, then two alternatives are permissible: 1) the liner shall be left in the coring tool and the coring tool shall be capped at each end, or 2) the coring tool shall remain in the waste container with the air lock mechanism attached. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

69   Samples of homogenous solids and soil/ gravel for VOC analyses are collected prior to extruding the core from the liner. These samples may be collected by collecting a single sample from the representative subsection of the core, or three sub samples may be collected from the vertical core to form a single 15 gram composite sample. Smaller sample sizes may be used if method PRQL requirements are met for all analytes. The sampling locations shall be randomly selected. If a single sample is used, the representative subsection is chosen by randomly selecting a location along the portion of the core ( i. e. core length). If the three sub sample method is used, the sampling locations shall be randomly selected within three equal length subsections of the core along the long axis of the liner and access to the waste shall be gained by making a perpendicular cut through the liner and the core. The procedures to select, and record the selection, of random sampling locations is given in INSTOI 16, Drum Coring Operations. True random sampling involves the proper use of random numbers for identifying sampling locations. A sampling device such as the metal coring cylinder described in EPA's SW 846 Manual ( 1996), or equivalent, is immediately used to collect the sample once the core has been exposed to air. Immediately after sample collection, the sample shall be extruded into 40 ml volatile organics analysis ( VOA) vials ( or other containers specified in appropriate SW 846 methods), the top rim of the vial visually inspected and wiped clean of any waste residue, and the vial cap secured. Sample handling requirements are outlined in Table B1 4. Additional guidance for this type of sampling can be found in SW 846.

Samples of the homogenous solids and soil/ gravel for semi volatile organic compound, polychlorinated biphenyls, and metals analyses are collected. These samples may be collected from the same subsample locations and in the same manner as the sample collected for VOC analysis, or they may be collected by splitting or compositing the representative subsection of the core. The representative subsection is chosen by randomly selecting a location along the portion of the core ( i. e. core length). The procedures to select, and record the selection, of random sampling locations is given in INST OI 16. True random sampling involves the proper use of random numbers for identifying sampling locations. The procedures used to select the random sampling locations will be subject to review as part of annual audits by the CBFO. Guidance for splitting and compositing solid materials can be found in SW 846. All surfaces of the sampling tools that have the potential to come into contact with the sample shall be constructed of materials unlikely to affect the composition or concentrations of target analytes in the waste ( e. g., Teflon ® ) . In addition, all surfaces that have the potential to come into contact with core sample media shall either be disposed or decontaminated according to the procedures found in Section B1 2( b). Sample sizes and handling requirements are outlined in Table B1 4.

Newly generated waste samples may be collected using methods other than coring, as discussed in Section B1 2a. Newly generated wastes samples will be collected as soon as possible after sampling, but the spatial and temporal homogeneity of the waste stream dictate whether a representative grab sample or composite sample shall be collected. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

70 B1 2b Quality Control Requirements Quality control ( QC) requirements for homogeneous waste sampling include collecting co located samples from cores or other sample types to determine precision, collection equipment blanks to verify cleanliness of the sampling and coring tools and sampling equipment; and analysis of reagent blanks to ensure reagents, such as deionized and high pressure liquid chromatography ( HPLC) water, are of sufficient quality. Coring and sampling of homogeneous solids and soil/ gravel comply, at a minimum, with the quality control requirements in Sections Bl 2b( l), B1 2b( 2), and B1 2b( 3).

B1 2b( 1) Co located Samples In accordance with the requirement to collect field duplicates required by the Environmental Protection Agency ( EPA) methods found in SW 846, samples are collected to determine the combined precision of the coring and sampling procedures. The co located core methodology is a duplicate sample collection methodology intended to collect samples from a second core placed at approximately the same location within the drum when samples are collected by coring. Waste may not be amenable to coring in some instances. In this case, a co located sample may be collected from a sample ( e. g. scoop) collected from approximately the same location in the waste stream. A sample from each co located core or waste sample collected by other means is collected side by side as close as feasible to one another, handled in the same manner, visually inspected through the transparent liner ( if cored), and sampled in the same manner at the same randomly selected sample location( s). If the visual examination detects inconsistencies such as color, texture, or waste type in the waste at the sample location, another sampling location may be randomly selected, or the samples may be invalidated and colocated samples or cores may again be collected. Co located samples, from either core or other sample type, shall be collected at a frequency of one per sampling batch or once per week, whichever is more frequent. A sampling batch is a suite of homogenous solids and soil/ gravel samples collected consecutively using the same sampling equipment within a specific time period. A sampling batch can be up to 20 samples ( excluding field QC samples), all of which shall be collected within 14 days of the first sample in the batch. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

71 B1 2b( 2) Equipment Blanks In accordance with SW 846 equipment blanks are collected from fully assembled sampling and coring tools ( i. e., at least those portions of the sampling equipment that contact the sample) prior to first use after cleaning at a frequency of one per " equipment cleaning batch". The equipment blank shall be collected from the fully assembled sampling or coring tool in the area where the sampling or coring tools are cleaned, prior to covering with protective wrapping and storage. The equipment blank is collected by pouring clean water ( e. g., deionized water, HPLC water) down the inside of the assembled sampling or coring tool. The water is collected in a clean sample container placed at the leading edge of the sampling or coring tool and analyzed for the analytes listed in Tables B3 4, B3 6 and the PRDLs, and B3 8. The results of the equipment blank will be considered acceptable if the analysis indicates no analyte at a concentration greater than three times the MDLs listed in Tables B3 4 and B3 6 or in the Program Required Detection Limits ( PRDLs) in Table B3 8. If analytes are detected at concentrations greater than three times the MDLs ( or PRDLs for metals), then the associated equipment cleaning batch of sampling or coring tools shall be cleaned again and another equipment blank collected. Equipment from an equipment cleaning batch may not be used until analytical results have been received verifying an adequately low level of contamination in the equipment blank.

Equipment blanks for coring tools are collected from liners that are cleaned separately from the coring tools. These equipment blanks shall be collected at a frequency of one per equipment cleaning batch. The equipment blanks shall be collected by randomly selecting a liner from the equipment cleaning batch, pouring clean water ( e. g., deionized water or HPLC water) across its internal surface, collecting the water in a clean sample container, and analyzing the water for the analytes listed in Tables B3 4, B3 6, and the analytes in Table B3 8 of Permit Attachment B3. The results of the equipment blank analysis will be considered acceptable if the results indicate no analyte at a concentration greater than three times the MDLs listed in Tables B3 4, B3 6, or the PRDLs in Table B3 8 of Permit Attachment B3. If analytes are detected at concentrations greater than three times the MDLs ( or PRDLs for metals), then the associated equipment cleaning batch of liners shall be cleaned again and another equipment blank collected. Equipment from an equipment cleaning batch may not be used until analytical results have been received verifying an adequately low level of contamination in the equipment blank. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

72 Sampling equipment ( e. g., bowls, spoons, chisel, VOC sub sampler) are also to be cleaned. Equipment blanks are collected for the sampling equipment at a frequency of one per equipment cleaning batch. After the sampling equipment has been cleaned, one item from the equipment cleaning batch is randomly selected, water ( e. g., deionized water, HPLC water) is passed over its surface, collected in a clean container, and analyzed for the analytes listed in Tables B3 4, B3 6, and B3 8. The results of the equipment blank will be considered acceptable if the results indicate no analyte present at a concentration greater than three times the MDLs listed in Tables B3 4 and B3 6 and in the PRDLs in B3 8. If analytes are detected at concentrations greater than three times the MDLs ( or PRDLs for metals), then the associated equipment cleaning batch of sampling equipment shall be cleaned again and another equipment blank collected. Equipment from an equipment cleaning batch may not be used until analytical results have been received verifying an adequately low level of contamination in the equipment blank. The above equipment blanks may be performed on a purchased batch basis for sampling equipment purchased sterile and sealed in protective packaging. Equipment blanks need not be performed for equipment purchased in sealed protective packaging accompanied by a certificate certifying cleanliness.

The results of equipment blanks are traceable to the items in the equipment cleaning batch that the equipment blank represents. All sampling items should be identified, and the associated equipment cleaning batch should be documented. The method of documenting the connection between equipment and equipment cleaning batches shall be documented. Equipment blank results for the coring tools, liners, and sampling equipment shall be reviewed prior to use. A sufficient quantity of these items should be maintained in storage to prevent disruption of sampling operations. The AMWTP may use certified clean disposable sampling equipment and discard liners and sampling tools after one use. As a result, cleaning and equipment blank collection is not required.

B1 2b( 3) Coring Tool and Sampling Equipment Cleaning Coring tools and sampling equipment must be cleaned in accordance with the following requirements:

  All surfaces of sampling equipment or tools that will come into contact with the samples are cleaned prior to use. All items of sampling equipment and tools are cleaned in the same manner. Immediately following cleaning, equipment and tools are assembled and sealed inside clean protective wrapping ( plastic bags). AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

73   Each reusable sampling or coring tool( e. g., drill heads, ball mills, sample splitters, etc) have a unique identification number. Each number is referenced to the waste container on which it was used. This information is recorded in the field records. One sampling or coring tool from each cleaning batch is tested for cleanliness in accordance with the requirements specified above. The identification number of the sampling or coring tool from which the equipment blank was collected is recorded in the field records. The results of the equipment blank analysis for the equipment cleaning batch in which each sampling or coring tool was cleaned are submitted to the sampling site with the identification numbers of all sampling or coring tools in the equipment cleaning batch. If analytes are detected at concentrations greater than three times the MDLs ( or PRDLs for metals), then the associated equipment cleaning batch of sampling equipment shall be cleaned again and another equipment blank collected. Equipment from an equipment cleaning batch may not be used until analytical results have been received verifying an adequately low level of contamination in the equipment blank.

  Sample containers should be purchased pre cleaned per EPA cleaning protocols. If sampling containers are not purchased pre cleaned, they are cleaned in accordance with SW 846 criteria. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

74 B1 2c Equipment Testing, Inspection, and Maintenance Prior to initiation of sampling or coring activities, sampling and coring tools are tested in accordance with manufacturer specifications to ensure operation within manufacturer's tolerance limits. Other specifications specific to the sampling operations ( e. g., operation of containment structure and safety systems) are also tested and verified as operating properly prior to initiating sampling activities. Coring tools shall be assembled, including liners, and tested. Air lock mechanism, if present, and rotation mechanism shall be inspected for free movement of critical parts. Sampling and coring tools found to be malfunctioning are repaired or replaced prior to use.

Coring tools and sample collection equipment shall be maintained in accordance with manufacturer's specifications. Clean sampling and coring tools and sampling equipment shall be sealed inside clean protective wrapping and maintained in a clean storage area prior to use. Sampling equipment shall be properly maintained to avoid contamination. A sufficient supply of spare parts should be maintained to prevent delays in sampling activities due to equipment down time. Records of equipment maintenance and repair are maintained in the field records in accordance with INSTCMNT 10.1.2, Maintenance Management System.

Inspection of sampling equipment and work areas shall include the following:

  Sample collection equipment in the immediate area of sample collection are inspected daily for cleanliness. Visible contamination on any equipment ( e. g., waste on floor of sampling area, hydraulic fluid from hoses) that has the potential to contaminate a waste sample is thoroughly cleaned upon its discovery. Inspection records are maintained in the field databank or appropriate data sheet.

  The waste coring and sampling work areas are maintained in a clean condition to minimize cross contamination between waste ( including cores) and samples.

  Expendable equipment ( e. g., plastic sheeting, plastic gloves, pans) are visually inspected for cleanliness prior to use and properly discarded after use.

  Prior to removal of the protective wrapping from a coring tool designated for use, the condition of the protective wrapping is visually assessed. Coring tools with torn protective wrapping are returned for cleaning. Coring tools visibly contaminated after the protective wrapping has been removed shall not be used and shall be returned for cleaning or properly discarded. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

75   Sampling equipment are visually inspected prior to use. All sampling equipment that comes into contact with waste samples must be stored in a protective wrapping until use. Prior to removal of the protective wrappings from sampling equipment, the condition of the protective wrappings is visually assessed. Sampling equipment with torn protective wrapping should be discarded or returned for cleaning. Sampling equipment visibly contaminated after the protective wrapping has been removed shall not be used and shall be returned for cleaning or properly discarded.

  Cleaned sampling and coring equipment will be physically segregated from all equipment that has been used for a sampling event and has not been decontaminated.

B1 2d Equipment Calibration and Frequency The scales used for weighing samples are calibrated as necessary to maintain scale operation within manufacture's specifications, and after repairs and routine maintenance. Weights used for calibration are traceable to nationally recognized standards. Calibration records are maintained in the field records.

B1 3 Radiography Radiography is a nondestructive technique that involves X ray scanning of waste containers to identify and verify waste container contents. Radiography requirements are prescribed in INST OI 12, Real Time Radiography Operations. The objectives of the radiography are as follows:

  Verify Waste Matrix Code;

  Estimate waste material parameter weights;

  Verify the waste stream description; and   Verify prohibited items ( refer to section B 1c).

B1 3a Methods Requirements Radiography at the AMWTP aids in the examination and identification of containerized waste. All activities required to achieve radiography objectives are described in the AMWTP QAPjP and Operating Instructions ( OIs). These documents include instructions specific to the radiography system( s) used at the AMWTP. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

76 A radiography system ( e. g., real time radiography digital, digital radiography/ computed tomography) normally consists of an X ray producing device, an imaging system, an enclosure for radiation protection, a waste container handling system, an audio/ video recording system, and an operator control and data acquistion station. The radiography system at the AMWTP has controls which allow the operator to vary the voltage, thereby controlling image quality. It is possible to vary the voltage between 150 and 400 kilovolts to provide an optimum degree of penetration through the waste.

To perform radiography, the waste container is scanned while the operator views the video monitor. An audio/ video tape or equivalently non alterable media is made of the waste container scan and is maintained as a non permanent record. A radiography data form is also used to document the Waste Matrix Code and estimated waste material parameter weights of the waste. The estimated waste material parameter and weights are determined by compiling an inventory of waste items, residual materials, and packaging materials. The items on this look up table provide an estimate of waste material parameter weights. Containers whose contents prevent full examination of the remaining contents, shall be subject to visual examination unless the AMWTP certifies that visual examination would provide no additional relevant information for that container.

Radiography is conducted in accordance with INST OI 12, Real Time Radiography Operations.

Waste containers whose packaging configuration or contents prevent full radiography examination of the remaining contents ( e. g., lead lined drums) must be subjected to VE in lieu of radiography. If radiography indicates that the waste does not match the waste stream description a nonconformance report ( NCR) is initiated in accordance with MP Q& SI 5.4, Identification of Nonconforming Conditions. If a prohibited nonconforming item is discovered in a waste container, the container is rejected and disposition for special case handling in the Waste Tracking System. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

77 B1 3b Quality Control The radiography system involves qualitative and semiquantitive evaluations of visual displays. Operator training and experience are the most important considerations for assuring quality controls in regard to the operation of the radiography system and for interpretation and disposition of radiography results. Only trained and qualified radiography operators are allowed to operate radiography equipment.

Standardized training and qualification requirements for radiography operators are based upon existing industry standard training requirements and comply with the training and qualification requirements of the WIPP WAP as detailed in the MP RTQP 14.4, Personnel Qualification and Certification.

The AMWTP has developed a training program that provides radiography operators with both formal and on the job ( OJT) training. Radiography operators shall be instructed in the specific waste generating practices, typical packaging configurations, and associated waste material parameters expected to be found in each Waste Matrix Code at the site. The OJT and apprenticeship shall be conducted by an experienced, qualified radiography operator prior to qualification of the training candidate. Radiography operators are trained on the types of waste that are generated, stored, and characterized at the AMWTP. All of the radiography QC requirements specified in the WIPP WAP are incorporated into the AMWTP training program and radiography operations to ensure data quality and comparability.

The training program contains the following elements. The elements of the radiography training program include formal and OJT, as presented below. These elements are addressed in MP RTQP 14.4, Personnel Qualification and Certification. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

78 B1 3b( 1) Formal Training   Project Requirements   State and Federal Regulations   Basic Principles of Radiography   Radiographic Image Quality   Radiographic Scanning Techniques   Application Techniques   Radiography of Waste Forms   Standards, Codes, and Procedures for Radiography   Site Specific Instruction B1 3b( 2) On the Job Training   System Operation   Identification of Packaging Configurations   Identification of Waste Material Parameters   Weight and Volume Estimation   Identification of Prohibited Items AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

79 Radiography test drums contain items common to the waste streams to be generated and stored at the AMWTP. Test drum( s) representative of the Waste Matrix Codes for the WSPFs are examined and successfully identified as part of the radiography operator qualification process. The test drums are divided into layers with varying packing densities that are representative of the waste streams. Test drums are representative of the waste matrix codes for which Waste Stream Profile Form approval is sought, are examined and successfully identified prior to waste stream shipment. The following is a list of required elements of a radiography test drum:

  A punctured aerosol can   Pigtails on poly liners ( horsetail bag)

  Pair of coveralls   Empty bottle   Irregular shaped pieces of wood   Empty one gallon paint can   Full container   Aerosol can with fluid   One gallon bottle with three tablespoons of fluid   One gallon bottle with one cup of fluid ( upside down)

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

80 These items shall be successfully identified by the operator as part of the qualification process. Qualifications of radiography operators shall, at a minimum, encompass the following requirements:

  Successfully pass a comprehensive exam based upon training enabling objectives. The comprehensive exam will address all of the radiography operations, documentation, characterization and procedural elements stipulated in this QAPjP.

  Perform a practical capability demonstration in the presence of appointed site radiography subject matter expert. The person will be an experienced radiography operator who is also qualified as an OJT trainer.

Requalifications of operators are based on evidence of continued satisfactory performance ( primarily audio/ video tape reviews) and shall be done at least every two years . Unsatisfactory performance will result in disqualification. Unsatisfactory performance is defined as the misidentification of a prohibited item in a training drum or a score of less than 80% on the comprehensive exam. Retraining and demonstration of satisfactory performance are required before a disqualified operator is again allowed to operate the radiography system.

A training drum with internal containers of various sizes is scanned biannually by each operator. The audio/ video tape or equivalent media is then reviewed by a supervisor to ensure that operator's interpretations remain consistent and accurate. Imaging system characteristic are verified on a routine basis.

Independent replicate scans and replicate observations of the video output of the radiography process is performed under uniform conditions and procedures. Independent replicate scans are performed on one waste container per day or once per testing batch, whichever is less frequent. Independent observation of one scan ( not the replicate scan) are also made once per day or once per testing batch, whichever is less frequent, by a qualified radiography operator other than the individual who performed the first examination. A testing batch is a suite of waste containers undergoing radiography using the same testing equipment. A testing batch can be up to 20 waste containers without regard to waste matrix.

Oversight functions include periodic audio/ videotape reviews of accepted waste containers by a qualified radiography operator other than the operator who dispositioned the waste container . The results of this independent verification are available to the radiography operator. The AMWTP SQAO is responsible for monitoring the quality of the radiography data and calling for corrective action, when necessary. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

81 B1 3b( 3) Visual Examination As an additional QC check or in lieu of radiography, the waste container contents are verified directly by performing VE on the waste container contents using MP TRUW 8.19, RTR/ VE Drum Selection). VE is performed on a statistically determined portion of waste containers to verify the results of radiography. With the exception of items or conditions that could pose a hazard to VE personnel, the radiography results are not made available until after the VE is completed. This verification includes the Waste Matrix Code and waste material parameter weights. This verification is performed through a comparison of radiography and VE examination results. The Waste Matrix Code is determined and waste material parameter weights are estimated to confirm that the container is properly included in the appropriate waste stream. The VE results are validated per Section B3 10 and the results transmitted to the RTR facility.

Visual examination is conducted to describe all contents of a waste container and includes estimated or measured weights of the contents. The description clearly identifies all discernible waste items, residual materials, packaging materials, or ( waste material parameter). Visual examination experts that are experienced and trained, assess the need to open individual bags or packages of waste. If individual bags/ packages are not opened estimated weights are recorded.

Estimated weights are established through the use of historically derived waste weight tables and an estimation of the waste volumes. It may not be possible to see through inner bags because of discoloration, dust, or because inner containers are sealed. In these instances, documented AK is used to identify the Waste Matrix Code and estimated waste material parameter weights. If AK is insufficient for individual bags/ packages, actual weights of waste items, residual materials, packaging materials, or waste material parameters are recorded. VE activities are documented on VE data forms and/ or the WTS. In addition, VE for confirmation of radiography results is documented on audio/ videotape recording and on VE data forms as specified in INST OI 34, VE Operating Procedures & Data Reporting or INST OI 16, Drum Coring Operations.

Visual examination consists of a semi quantitative and qualitative evaluation of the waste container contents and is recorded on audio/ video tape. Standardized training for VE has been developed to include both formal classroom training and OJT. Personnel performing VE are instructed in the specific waste generating processes, typical packaging configurations, and the waste material parameters expected to be found in each Waste Matrix Code at the AMWTP. The OJT and apprenticeship is conducted by an operator experienced and qualified in VE prior to qualification of the candidate. Visual examination personnel are requalified once every two years. Refer to MP RTQP 14.4, Personnel Qualification and Certification, for specific requirements for qualification and requalification of VE operators. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

82 The elements of the VE training program are presented below:

B1 3b( 4) Formal Training   Project Requirements   State and Federal Regulations   Application Techniques   Site Specific Instruction B1 3b( 5) On the Job Training   Identification of Packaging Configurations   Identification of Waste Material Parameters   Weight and Volume Estimation   Identification of Prohibited Items The AMWTP designates visual examination experts ( VEE). The VEE is selected based on experience and training in the types of waste being characterized. The VEE will be familiar with the waste generating processes that have taken place at the AMWTP and will also be familiar with all types of waste being characterized at the AMWTP. The VEE is responsible for the overall direction and implementation of the visual examination at the AMWTP. The VEE will receive training in the same elements as the visual examination personnel with both formal training and on the job training. Qualification of a VEE is based on familiarity with waste generating processes, familiarity with the types of waste being characterized, and meeting the training requirements discussed above. The SPM evaluates personnel, using the above criteria, and designates VEEs accordingly. Consistent with other VE personnel, the VEE will be requalified once every two years. VEEs selected will meet the qualification and training requirements specified in MP RTQP 14.4, Personnel Qualification and Certification.

If the waste is homogeneous, the VEE may decide that a limited VE involving a confirmation of the radiography data is appropriate. If the waste is heterogeneous the VEE may decide a full VE by opening bags and segregating waste is warranted. Various degrees of segregation are possible based on the VEE's judgment and availability of AK data. The decision making criteria for this decision is for the VEE to assess the subject waste using AK information, training, and past experience with the subjet waste stream to determine the extent of examination necessary. The VEE's decisions are documented on the VE data form. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

83 A description of the waste container contents is recorded on a VE data form and/ or the WTS. The description clearly identifies all waste material parameters and provides enough information to estimate weights of waste material parameters. In cases where bags are not opened, a brief written description of the contents of the bags and an estimate of the amount of each waste type in the bags must be provided. The basis of all decision made by the VEE will be documented. The written records of VE are supplemented with the audio/ videotape recording. All work will be conducted in accordance with INST OI 34, VE Operating Procedure & Data Reporting or INST OI 16, Drum Coring Operations.

B1 4 Custody of Samples Chain of Custody on field samples ( including field QC samples) is initiated immediately after sample collection or preparation ( refer to INST OI 16, Drum Coring Operations). Sample custody is maintained by ensuring that samples are custody sealed during shipment to the laboratory. After samples are accepted by the analytical laboratory, custody is maintained in accordance with MCP 2002, Analytical Sample Management by assuring samples are as follows:

  in the possession of an authorized individual; or   in that individual's view; or   in sealed or locked container controlled by that individual; or   in a secure controlled access location.

Sample custody is maintained until the sample is released by the SPM or until the sample is expended. The AMWTP Chain of Custody includes provisions for each of the following:

  Signature of individual initiating custody control, along with data and time.

  Documentation of sample numbers for each sample under custody. Sample numbers will be referenced to a specific sampling event description that will identify the sampler( s) through signature, the date and time of sample collection, type/ number containers for each sample, sample matrix, preservatives ( if applicable), requested methods of analysis, place/ address of sample collection and the waste container number.

  For off site shipping, method of shipping transfer, responsible shipping organization or corporation, and associated air bill or lading number. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

84   Signatures of custodians relinquishing and receiving custody, along with date and time of the transfer.

  Description of final sample container disposition, along with signature of individual removing sample container from custody.

  Comment section.

  Documentation of discrepancies, breakage or tampering.

All samples and sampling equipment are identified with unique identification numbers. Sampling Coring tools and equipment are identified with unique equipment numbers to ensure that all sampling equipment, coring tools, and sampling canisters are traceable to equipment cleaning batches.

All samples are uniquely identified to ensure the integrity of the sample and can be used to identify the AMWTP and date of collection. Sample tags and labels identify at a minimum the following:

  Sample ID number   Sampler initials and organization   Ambient temperature and pressure ( for gas samples only)

  Sample description   Requested analyses   Date and time of collection   QC designation ( if applicable)

B1 5 Sample Packing and Shipping Samples are packaged at the AMWTP and shipped to the ALD. In the event that analytical facilities are not at the site, the samples will be packaged and shipped to an off site laboratory. Sample containers are packed to prevent damage to the sampling container and to maintain the preservation temperature, if necessary. Department of Transportation ( DOT) regulations are adhered to for shipment of the package. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

85 When preparing SUMMA ® or equivalent canisters for shipment, special care is taken with the pressure gauge and the associated connections. Metal boxes which have separate compartments or cardboard boxes with foam inserts are standard shipping containers. The chosen shipping container shall meet selected DOT regulations. Cold packs are added to the approved shipping container when it is necessary to maintain the preservation temperatures in the package.

A uniform Hazardous Waste Manifest is not required, since samples are exempted from the definition of hazardous waste under RCRA.

Glass jars are wrapped in bubble wrap or similarly protected. The wrapped jars are placed in plastic bags inside of the shipping container so that the inside of the shipping container and the other samples in the shipping container are not contaminated in the event that one of the jars breaks. The plastic bag enables the receiving laboratory to prevent contamination of their shipping and receiving area. Plastic jars do not present a shipping problem.

Shipping containers contain appropriate blank samples to detect VOC cross contamination. A DOT approved cooler, or similar package, is used as a shipping container. When sample preservation temperatures must be maintained, an adequate number of cold packs are placed in the shipping container. If fill material is needed, the compatibility between the sample containers and the fill material is evaluated prior to use.

Sample containers are affixed with signed tamper proof seals or devices so that is apparent if the sample integrity has been compromised and to ensure that the seal or device is traceable to the individual who affixed the seal. A seal is also placed outside the shipping container for the same reason. Sample custody documentation, with the signature of the current custodian showing sample custody release, is placed inside the shipping container. A seal is then placed on the outside of the shipping container, or the shipping container is locked, so that the integrity of the custody of the sample inside the shipping container is evident. Transfer of sample custody is complete when the receiving custodian opens shipping container and signs the sample custody documentation. The sample custody documentation serves to track the physical transfer of samples between the two custodians. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

86 Table B1 1, Gas Sample Requirements PARAMETER HEADSPACE SAMPLE MINIMUM VOLUME ( ML) HOLDING TEMPERATURE VOCs 250a, b 0 40 o C a Alternatively, if available headspace is limited, 100 mL samples may be collected for determination of volatiles. b Alternatively, canisters, that meet QAOs may be used.

Table B1 2, Headspace Gas: Summary of Field Quality Control Sample Frequencies QC SAMPLES MANIFOLD DIRECT CANISTER ON LINE SYSTEMS Field Blanksa 1 per sampling batchd 1 per sampling batchd 1 per on line batchf Sampling Equipment Blanksb Or On Line Equipment Blanksb 1 per sampling batchd Oncee 1 per on line batchf Field Reference Standards Or On Line Control Samplesc 1 per sampling batchd Oncee 1 per on line batchf Field Duplicates Or On Line Duplicates 1 per sampling batchd 1 per sampling batchd 1 per on line batchf a Analysis of field blanks for VOCs ( Table B3 2), only, is required. For on line integrated sampling/ analytical systems, if field blank results meet the acceptance criteria, a separate on line blank is not required. b One equipment blank or on line equipment blank must be collected, analyzed for VOCs ( Table B3 2), and demonstrated as clean prior to first use of the headspace sampling equipment with each of the sampling heads, then at the specified frequency, for VOCs, only thereafter. Daily, prior to work, the sampling manifold, if in use, must be verified as clean. c One field reference standard or on line control sample must be collected, analyzed, and demonstrated to meet the QAOs specified in Table B3 2 prior to first use, then at the specified frequency thereafter. d A sampling batch is a suite of samples collected consecutively using the same sampling equipment within a specific time period. A sampling batch can be up to 20 samples ( excluding field QC samples), all of which must be collected within 14 days of the first sample in the batch. e One equipment blank and field reference standard must be collected after equipment purchase, cleaning, and assembly. f An on line batch is the number of samples collected within a 12 hour period using the same on line integrated sampling/ analysis system. The analytical batch requirements are specified by the analytical method being used in the on line system. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

87 Table B1 3, Headspace Gas: Summary of Field Quality Control Sample Acceptance Criteria QC SAMPLES ACCEPTANCE CRITERIA CORRECTIVE ACTION a Field Blanks VOC amounts   3 x MDLs in Table B3 2 for GC/ MS or GC/ FID;   PRQLs in Table B3 2 for FTIRS Nonconformance if any VOC amount > 3 x MDLs in Table B3 2 for GC/ MS or GC/ FID; > PRQLs in Table B3 2 for FTIRS Sampling Equipment Blanks VOC amounts   3 x MDLs in Table B3 2 for GC/ MS or GC/ FID;   PRQLs in Table B3 2 for FTIRS Nonconformance if any analyte amount > 3 x MDLs in Table B3 2 for GC/ MS or GC/ FID; > PRQLs in Table B3 2 for FTIRS Field Reference Standards Or On Line Control Samples 70  130 % R Nonconformance if % R < 70 or > 130 Field Duplicates Or On Line Duplicates RPD < 25 % Nonconformance if RPD > 25 %

a Corrective action is only required if the final reported QC sample results do not meet the acceptance criteria.

MDL = Method detection limit % R = Percent recover RPD = Relative percent difference Table B1 4, Sample Handling Requirements for Homogeneous Solids and Soil/ Gravel PARAMETER SUGGESTED QUANTITYa REQUIRED PRESERVATIVE SUGGESTED CONTAINER MAXIMUM HOLDING TIMEc VOCs 15 grams Cool to 4 o C Glass Viald 14 Days Prep/ 40 Days Analyzee SVOCs 50 grams Cool to 4 o C Glass Jarf 14 Days Prep/ 40 Days Analyzee PCBsg 50 grams Cool to 4 o C Glass Jarf 14 Days Prep/ 40 Days Analyzee Metals 10 grams Cool to 4 o C Plastic Jarh 180 Daysi a Quantity may be increased or decreased according to the requirements of the analytical laboratory, as long as the QAOs are met. c Holding time begins at sample collection ( holding times are consistent with SW 846 requirements). d 40 mL VOA vial or other appropriate containers shall have an airtight cap. e 40 day holding time allowable only for methanol extract  14 day holding time for non extracted VOCs. f Appropriate containers ( e. g., opaque glass container) should be used and should have Teflon ® lined caps. g Analysis for PCBs is required only for waste streams in waste matrix code S3220 ( organic sludges) or for waste forms indicated by AK. h Polyethylene or polypropylene is preferred, glass jar is allowable. i Holding time for mercury analysis is 28 days.

NOTE: Preservation requirements in the most recent version of SW 846 may be used if appropriate. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

88 TABLE B1 5 HEADSPACE GAS DRUM AGE CRITERIA SAMPLING SCENARIOS Scenario Description 1 A. Unvented drums without rigid poly liners are sampled through the drum lid at the time of venting. B1. Unvented drums with unvented rigid poly liners are sampled through the rigid poly liner at the time of venting or prior to venting. B2. Vented drums with unvented rigid poly liners are sampled through the rigid poly liner at the time of venting or prior to venting. C. Unvented drums with vented rigid poly liners are sampled through the drum lid at the time of venting.

2 Drums that have met the criteria for Scenario 1 and then are vented, but not sampled at the time of venting. a 3 Containers ( i. e., drums, SWBs, and pipe components) that are initially packaged in a vented condition and sampled in the container headspace and containers that are not sampled under Scenario 1 or 2.

a Containers that have not met the Scenario 1 DAC at the time of venting must be categorized under Scenario 3. This requires the additional information required of each container in Scenario 3 ( i. e., determination of packaging configuration), and such containers can only be sampled after meeting the appropriate Scenario 3 DAC. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

89 TABLE B1 6 SCENARIO 1 DRUM AGE CRITERIA ( in days) MATRIX Summary Category Group DAC ( days)

S3000/ S4000 127 S5000 53 NOTE: Containers that are sampled using the Scenario 1 DAC do not require information on the packaging configuration because the Scenario 1 DAC are based on a bounding packaging configuration. In addition, Information on the rigid liner vent hole presence and diameter do not apply to containers that are sampled using the Scenario 1 DAC because they are unvented prior to sampling. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

90 TABLE B1 7 SCENARIO 2 DRUM AGE CRITERIA ( in days) MATRIX Summary Category Group S3000/ S4000 Summary Category Group S5000 Filter H2 Diffusivity a Rigid Liner Vent Hole Diameter ( in) b Rigid Liner Vent Hole Diameter ( in) b ( mol/ s/ mod fraction) 0.30 0.375 0.75 1.0 0.30 0.375 0.75 1.0 1.9 x 10 6 36 30 23 22 29 22 13 12 3.7 x 10 6 30 25 19 18 25 20 12 11 3.7 x 10 5 13 11 11 11 7 6 6 4 a The documented filter H2 diffusivity must be greater than or equal to the listed value to use the DAC for the listed filter H2 diffusivity ( e. g., a container with a filter H2 diffusivity of 4.2 x 10 6 must use a DAC for a filter with a 3.7 x 10 6 filter H2 diffusivity). If a filter H2 diffusivity for a container is undocumented or unknown or is less than 1.9 x 10 6 filter H2 diffusivity, a filter of known H2 diffusivity that is greater than or equal to 1.9 x 10 6 filter H2 diffusivity must be installed prior to initiation of the relevant DAC period.

b The documented rigid liner vent hole diameter must be greater than or equal to the listed value to use the DAC for the listed rigid liner vent hole diameter ( e. g., a container with a rigid liner vent hole of 0.5 in. must use a DAC for a rigid liner vent hole of 0.375 in.). If the rigid liner vent hole diameter for a container is undocumented during packaging ( Attachment B, Section B 3( d) 1), repackaging ( Attachment B, Section B 3( d) 1), and/ or venting ( Section B1 1a[ 6][ ii]), that container must use a DAC for a rigid liner vent hole diameter of 0.30 in.

NOTE: Containers that are sampled using the Scenario 2 DAC do not require information on the packaging configuration because the Scenario 2 DAC are based on a bounding packaging configuration. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

91 TABLE B1 8 SCENARIO 3 PACKAGING CONFIGURATION GROUPS Packaging Configuration Group Covered S3000/ S4000 Packaging Configuration Groups Covered S5000 Packaging Configuration Groups Packaging Configuration Group 1, 55 gal. drums a   No layers of confinement, filtered inner lid b   No inner bags, no liner bags ( bounding case)   No layers of confinement, filtered inner lid b   No inner bags, no liner bags ( bounding case)

Packaging Configuration Group 2, 55 gal. drums a

1 inner bag   1 filtered inner bag   1 liner bag ( bounding case)   1 filtered liner bag   1 inner bag   1 filtered inner bag   1 liner bag   1 filtered liner bag   1 inner bag, 1 liner bag   1 filtered inner bag, 1 filtered liner bag   2 inner bags   2 filtered inner bags   2 inner bags, 1 liner bag   2 filtered inner bags, 1 filtered liner bag   3 inner bags   3 filtered inner bags   3 filtered inner bags, 1 filtered liner bag   3 inner bags, 1 liner bag ( bounding case)

Packaging Configuration Group 3, 55 gal. drums a

1 inner bag, 1 liner bag   1 filtered inner bag, 1 filtered liner bag   2 inner bags

2 liner bags   2 filtered liner bags   1 inner bag, 2 liner bags AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

92   2 filtered inner bags   2 liner bags ( bounding case)   2 filtered liner bags   1 filtered inner bag, 2 filtered liner bags   2 inner bags, 2 liner bags   2 filtered inner bags, 2 filtered liner bags   3 filtered inner bags, 2 filtered liner bags   4 inner bags   3 inner bags, 2 liner bags   4 inner bags, 2 liner bags ( bounding case)

Packaging Configuration Group 4, pipe components

No layers of confinement inside a pipe component   1 filtered inner bag, 1 filtered metal can inside a pipe component   2 inner bags inside a pipe component   2 filtered inner bags inside a pipe component   2 filtered inner bags, 1 filtered metal can inside a pipe component   2 inner bags, 1 filtered metal can inside a pipe component ( bounding case)   No layers of confinement inside a pipe component   1 filtered inner bag, 1 filtered metal can inside a pipe component   2 inner bags inside a pipe component   2 filtered inner bags inside a pipe component   2 filtered inner bags, 1 filtered metal can inside a pipe component   2 inner bags, 1 filtered metal can inside a pipe component ( bounding case)

Packaging Configuration Group 5, Standard Waste Box a

No layers of confinement   1 SWB liner bag ( bounding case)

No layers of confinement   1 SWB liner bag ( bounding case) AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

93 Packaging Configuration Group 6, Standard Waste Box a

any combination of inner and/ or liner bags that is less than or equal to 6   5 inner bags, 1 SWB liner bag ( bounding case)   any combination of inner and/ or liner bags that is less than or equal to 6   5 inner bags, 1 SWB liner bag ( bounding case)

a If a specific Packaging Configuration Groups cannot be determined based on the data collected during packaging ( Attachment B, Section B 3( d) 1) and/ or repackaging ( Attachment B, Section B 3( d) 1), a conservative default Packaging Configuration Group of 3 for 55 gal. drums and 6 for SWBs must be assigned provided the 55 gal. drums do not contain pipe component packaging. If pipe components are present as packaging in the 55 gal. drums, the pipe components must be sampled following the requirements for Packaging Configuration Group 4.

b A filtered inner lid@ is the inner lid on a double lid drum that contains a filter.

Definitions: Liner Bags: One or more optional plastic bags that are used to control radiological contamination. Liner bags for drums have a thickness of approximately 11 mils. SWB liner bags have a thickness of approximately 14 mils. Liner bags are typically similar in size to the container.

Inner Bags: One or more optional plastic bags that are used to control radiological contamination. Inner bags have a thickness of approximately 5 mils and are typically smaller than liner bags. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

94 TABLE B1 9 SCENARIO 3 DRUM AGE CRITERIA ( in days) MATRIX FOR S5000 WASTE BY PACKAGING CONFIGURATION GROUP Packaging Configuration Group 1 Rigid Liner Vent Hole Diameter b Filter H2 Diffusivity a ( mol/ s/ mol fraction) 0.3 inch Diameter Hole 0.375 inch Diameter Hole 0.75 inch Diameter Hole 1 inch Diameter Hole No Liner Lid No Liner 1.9 x 10 6 131 95 37 24 4 4 3.7 x 10 6 111 85 36 24 4 4 3.7 x 10 5 28 28 23 19 4 4 Packaging Configuration Group 2 Rigid Liner Vent Hole Diameter b Filter H2 Diffusivity a ( mol/ s/ mol fraction) 0.3 inch Diameter Hole 0.375 inch Diameter Hole 0.75 inch Diameter Hole 1 inch Diameter Hole No Liner Lid No Liner 1.9 x 10 6 175 138 75 60 30 11 3.7 x 10 6 152 126 73 59 30 11 3.7 x 10 5 58 57 52 47 28 8 AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

95 Packaging Configuration Group 3 Rigid Liner Vent Hole Diameter b Filter H2 Diffusivity a ( mol/ s/ mol fraction) 0.3 inch Diameter Hole 0.375 inch Diameter Hole 0.75 inch Diameter Hole 1 inch Diameter Hole No Liner Lid No Liner 1.9 x 10 6 199 161 96 80 46 16 3.7 x 10 6 175 148 93 79 46 16 3.7 x 10 5 72 72 67 62 42 10 Packaging Configuration Group 4 Filter H2 Diffusivity a ( mol/ s/ mol fraction) Headspace Sample Taken Inside Pipe Component > 1.9 x 10 6 152 Packaging Configuration Group 5 Filter H2 Diffusivity a, c ( mol/ s/ mol fraction) Headspace Sample Taken Inside SWB > 7.4 x 10 6 15 AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

96 Packaging Configuration Group 6 Filter H2 Diffusivity a, c ( mol/ s/ mol fraction) Headspace Sample Taken Inside SWB > 7.4 x 10 6 56 a The documented filter H2 diffusivity must be greater than or equal to the listed value to use the DAC for the listed filter H2 diffusivity ( e. g., a container with a filter H2 diffusivity of 4.2 x 10 6 must use a DAC for a filter with a 3.7 x 10 6 filter H2 diffusivity). If a filter H2 diffusivity for a container is undocumented or unknown or is less than 1.9 x 10 6 filter H2 diffusivity, a filter of known H2 diffusivity that is greater than or equal to 1.9 x 10 6 filter H2 diffusivity must be installed prior to initiation of the relevant DAC period.

b The documented rigid liner vent hole diameter must be greater than or equal to the listed value to use the DAC for the listed rigid liner vent hole diameter ( e. g., a container with a rigid liner vent hole of 0.5 in. must use a DAC for a rigid liner vent hole of 0.375 in.). If the rigid liner vent hole diameter for a container is undocumented during packaging ( Attachment B, Section B 3( d) 1), repackaging ( Attachment B, Section B 3( d) 1), and/ or venting ( Section B1 1a[ 6][ ii]), that container must use a DAC for a rigid liner vent hole diameter of 0.30 in.

C The filter H2 diffusivity for SWBs is the sum of the diffusivities for all of the filters on the container because SWBs have more than 1 filter. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

97 TABLE B1 10 SCENARIO 3 DRUM AGE CRITERIA ( in days) MATRIX FOR S3000 AND S4000 WASTE BY PACKAGING CONFIGURATION GROUP Packaging Configuration Group 1 Rigid Liner Vent Hole Diameter b Filter H2 Diffusivity a ( mol/ s/ mol fraction) 0.3 inch Diameter Hole 0.375 inch Diameter Hole 0.75 inch Diameter Hole 1 inch Diameter Hole No Liner Lid No Liner 1.9 x 10 6 131 95 37 24 4 4 3.7 x 10 6 111 85 36 24 4 4 3.7 x 10 5 28 28 23 19 4 4 Packaging Configuration Group 2 Rigid Liner Vent Hole Diameter b Filter H2 Diffusivity a ( mol/ s/ mol fraction) 0.3 inch Diameter Hole 0.375 inch Diameter Hole 0.75 inch Diameter Hole 1 inch Diameter Hole No Liner Lid No Liner 1.9 x 10 6 213 175 108 92 56 18 3.7 x 10 6 188 161 105 90 56 17 3.7 x 10 5 80 80 75 71 49 10 AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

98 Packaging Configuration Group 3 Rigid Liner Vent Hole Diameter b Filter H2 Diffusivity a ( mol/ s/ mol fraction) 0.3 inch Diameter Hole 0.375 inch Diameter Hole 0.75 inch Diameter Hole 1 inch Diameter Hole No Liner Lid No Liner 1.9 x 10 6 283 243 171 154 107 34 3.7 x 10 6 253 225 166 151 106 31 3.7 x 10 5 121 121 115 110 84 13 Packaging Configuration Group 4 Filter H2 Diffusivity a ( mol/ s/ mol fraction) Headspace Sample Taken Inside Pipe Component > 1.9 x 10 6 152 Packaging Configuration Group 5 Filter H2 Diffusivity a, c ( mol/ s/ mol fraction) Headspace Sample Taken Inside SWBS > 7.4 x 10 6 15 AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

99 Packaging Configuration Group 6 Filter H2 Diffusivity a, c ( mol/ s/ mol fraction) Headspace Sample Taken Inside SWBS > 7.4 x 10 6 56 a The documented filter H2 diffusivity must be greater than or equal to the listed value to use the DAC for the listed filter H2 diffusivity ( e. g., a container with a filter H2 diffusivity of 4.2 x 10 6 must use a DAC for a filter with a 3.7 x 10 6 filter H2 diffusivity). If a filter H2 diffusivity for a container is undocumented or unknown or is less than 1.9 x 10 6 filter H2 diffusivity, a filter of known H2 diffusivity that is greater than or equal to 1.9 x 10 6 filter H2 diffusivity must be installed prior to initiation of the relevant DAC period.

b The documented rigid liner vent hole diameter must be greater than or equal to the listed value to use the DAC for the listed rigid liner vent hole diameter ( e. g., a container with a rigid liner vent hole of 0.5 in. must use a DAC for a rigid liner vent hole of 0.375 in.). If the rigid liner vent hole diameter for a container is undocumented during packaging ( Attachment B, Section B 3( d) 1), repackaging ( Attachment B, Section B 3( d) 1), and/ or venting ( Section B1 1a[ 6][ ii]), that container must use a DAC for a rigid liner vent hole diameter of 0.30 in.

C The filter H2 diffusivity for SWBs is the sum of the diffusivities for all of the filters on the container because SWBs have more than 1 filter. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

100 Select Container Was container packaged in vented condition?

Will container be sampled at the time of venting?

Was Scenario 1 DAC satisfied at time of venting? ( Table B1 6)

Was rigid liner vent hole diameter documented during venting by lid punching per Section B1 1a( 6)( ii)?

Select appropriate filter diffusivity and documented rigid liner vent hole diameter from Table B1 7 Select appropriate filter diffusivity and default rigid liner vent hole diameter from Table B1 7 Satisfy appropriate Scenario 1 DAC before sampling ( Table B1 6)

Satisfy appropriate Scenario 2 DAC before sampling Table B1 7 Were packaging configuration and rigid liner vent hole presence and diameter documented during packaging/ repackaging per Section B 3d( 1)?

Select default packaging configuration for Scenario 3 ( Table B1 8)

Select appropriate filter diffusivity and documented rigid liner vent hole diameter from Table B1 9: S5000 Table B1 10: S3000/ 4000 Select appropriate filter diffusivity and default rigid liner vent hole diameter from: Table B1 9: S5000 Table B1 10: S3000/ 4000 Select appropriate packaging configuration for Scenario 3 based on packaging documentation ( Table B1 8)

Satisfy appropriate Scenario 3 DAC before sampling Table B1 9: S5000 Table B1 10: S3000/ 4000 No Yes Yes Yes Yes Yes No No No No Figure B1 1, Headspace Gas Drum Age Criteria Sampling Scenario Selection Process AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

101 AMWTP COC No.

Waste Characterization Facility Chain of Custody Sampling Location AMWTP Analytical Location INEEL Sampling Batch No. Sample Matrix SOLID Container ID IDC Sample ID Sample Date Sample Time Size Weight VOC NHVOC Semi VOC PCB Metals Comments All samples are preserved by cooling to 4 +/ 2 Degrees C Sampler Initiating Custody:__ _______________________________________________________________________

Print Name: Signature: TID: Date/ Time:

Relinquished by: Date Time Received by: Date Time Relinquished by: Date Time Received by: Date Time Relinquished by: Date Time Received by: Date Time Relinquished by: Date Time Received by: Date Time Discrepancies:

Figure B1 2, Example of the AMWTP Chain of Custody for Homogeneous Solids and Soil/ Gravel Samples AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

102 Figure B1 3, Overall Programmatic Approach to Visual Examination of the Waste for Confirmation of RTR NO YES Use radiography to determine/ verify the matrix parameter category and estimate waste material parameter weights.

Perform visual examination Visually examine unopened waste bags/ packages.

Can Waste Matrix Code and waste material parameter weights be determined without opening bags/ packages? Perform a limited visual examination through the unopened bags/ packages.

Confirm radiography indicated WMC and determine waste material parameter weights. Perform a full visual examination.

Open bags/ packages.

Determine Waste Matrix Code and waste material parameter weights.

Based on the results of visual examination, calculate the percentage of waste containers with incorrectly assigned waste matrix code. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

103 B2. STATISTICAL METHODS USED IN SAMPLING AND ANALYSIS The AMWTP uses the following statistical methods for sampling and analysis of TRU waste. These statistical methods include methods for selecting waste containers for visual inspection, selecting retrievably stored waste containers for totals analysis, setting the upper confidence limit, and control charting for newly generated waste stream sampling.

B2 1 Approach for Statistically Selecting Waste Containers for Visual Examination ( to confirm RTR)

As a QC check on the radiographic examination of waste containers, a statistically selected portion of the certified waste containers is opened and visually examined. The data from VE are used to verify the waste matrix code, waste material parameter weights, and absence of prohibited items as determined by radiography.

The data obtained from the visual examination are also used to determine, with acceptable confidence, the percentage of miscertified waste containers from the radiographic examination. Miscertified containers are those that radiography indicates meet the WAC for the WIPP and the TRUPACT Il Authorized Methods for Payload Control but that VE indicates do not meet these criteria.

Initially, the AMWTP will use an eleven percent ( 11%) miscertification rate to calculate the number of waste containers to undergo VE until an AMWTP specific miscertification rate is established. The AMWTP will establish a site specific miscertification rate is by characterizing at least fifty containers in a single summary category group at the initial 11% miscertification rate. The results of this initial characterization then serve as the site specific miscertification rate until reassessed as described below.

The site specific miscertification rate is applied initially to each summary category group to determine the number of containers in that summary category group requiring visual examination, as specified in Table B2 1. However, a summary category group specific miscertification rate is determined when either six months have passed since radiographic characterization commenced on a given summary category group, or at least 50% of a given summary category group has undergone radiographic characterization, whichever occurs first. The summary category group is then subject to the VE requirements of this reevaluated summary category group miscertification rate to ensure that the entire summary category group is appropriately characterized.

Table B2 1 provides the number of waste containers per summary category group that undergo VE for various miscertification rates and waste container population sizes using a hypergeometric sampling approach. A miscertification rate of 1% is used for any waste stream specific miscertification rate calculated to be less than 1%.

The site specific miscertification rate is reassessed annually by calculating a drum weighted average of all historic summary category group miscertification rates. Each summary category group miscertification rate is rounded off to the nearest integer value before being used to calculate the new site specific miscertification rate. A miscertification rate of 1% is used for any site specific miscertification rate calculated to be less than 1%. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

104 The number of waste containers requiring VE ( as identified in Table B2 1) utilizes a hypergeometric approach and is based on a 90 percent confidence that the actual miscertification rate ( for the population) is less than the 90 percent upper confidence level ( UCL), and also an 80 percent confidence that the UCL will be less than 14 percent if the actual miscertification rate is the same as the targeted percent of miscertified waste containers ( column heading of Table B2 1). Thus, there is only a 10 percent probability that the UCL will be below 14 percent in the case where the actual miscertification rate is 14 percent or greater. Also, there is only a 20 percent probability that the UCL will be above 14 percent in the case where the actual miscertification rate is the same as the targeted percent.

The hypergeometric approach to determining the number of containers to undergo VE is dependant upon the defined estimate of the allowable proportion of containers that were miscertified and information on previous percentages of containers that were miscertified. The rationale and details of this methodology are discussed further in Attachment B2 of the WIPP WAP, and compliance with the requirements for statistically selection waste containers for VE is achieved through the execution of site specific procedure MP TRUW 8.19, RTR/ VE Drum Selection.

B2 2 Approach for Statistically Selecting Retrievably Stored Waste Containers for Total ( or TCLP) Analysis B2 2a Statistical Selection of Containers for Totals Analysis The statistical approach for characterizing retrievably stored homogeneous solids and soil/ gravel waste and repackaged or treated S3000 waste that the AMWTP demonstrates is not suitable for control charting using sampling and analysis relies on using AK to segregate waste containers into relatively homogeneous waste streams. Using AK, the entire waste stream is classified as hazardous or nonhazardous rather than individual waste containers. Individual waste containers serve as convenient units for characterizing the combined mass of waste from the waste stream of interest. Once segregated by waste stream, random selection and sampling of the waste containers followed by analysis of the waste samples is performed to ensure that the resulting mean contaminant concentration provides an unbiased representation of the true mean contaminant concentration for each waste stream. The SPM verifies that the samples collected from within a waste stream were selected randomly in accordance with MP TRUW 8.25, Homogeneous Solids and Soils/ Gravel Sampling Plan. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

105 An end use of analytical results for retrievably stored homogeneous solids and soil/ gravel is for assigning the EPA hazardous waste D codes that apply to each mixed waste stream and to confirm AK. The D codes are indicators that the waste exhibits the toxicity characteristic for specific contaminants under RCRA. The RCRA toxicity determination is made on the basis of sampling and analysis of waste streams and on whether or not the waste stream includes F code wastes. If a waste stream includes one or more RCRA Fcodes identified via AK, toxicity characteristic contaminants associated with the F code waste( s) are not included in the RCRA toxicity characteristic determination. That is, the F codes take precedence over RCRA toxicity D code, and the waste stream is assumed hazardous regardless of the concentration. Therefore, toxicity characteristics contaminants associated with F codes( s) for a waste stream are omitted from all calculations for determining the number of containers to sample because these wastes streams are assumed to be hazardous. In addition, each toxicity characteristic contaminant associated with the Fcode s) is excluded from evaluation of analytical results to determine D codes. Contaminants of interest for the sampling, analysis, and RCRA toxicity determination of a waste stream, then, excludes contaminants associated with F codes that have been assigned to the waste stream.

The sampling and analysis strategy is illustrated in Figure B2 1. Preliminary estimates of the mean concentration and variance of each RCRA regulated contaminant in the waste is used to determine the number of waste containers to select for sampling and analysis. The preliminary estimates are made by obtaining a preliminary number of samples from the waste stream or from previous sampling from the waste stream. Preliminary estimates are based on samples from a minimum of 5 waste containers. Samples collected to establish preliminary estimates that are selected, sampled, and analyzed in accordance with applicable provisions of the WIPP WAP may be used as part of the required number of samples to be collected. The applicability of the preliminary estimates to the waste stream to be sampled is justified and documented. The preliminary estimates for the mean, variance and the appropriate number of samples ( n) to be collected for each contaminant is calculated in accordance with the equations presented in Section B2 2a of the WIPP WAP.

The number of samples collected is based upon the largest n calculated for each of the contaminants of concern. The actual number of samples collected is adjusted as necessary to ensure that an adequate number of samples are collected to allow for acceptable levels of completeness.

All calculations are rounded up to the nearest integer. A minimum of five containers are sampled and analyzed in each waste stream. If there are fewer than the minimum of the required number of containers in a waste stream, one or more containers is sampled more than once to obtain the samples of the waste. Otherwise any one container may be selected for sampling only once.

The calculated total number of required waste containers will then be randomly sampled and analyzed. Waste containers from the preliminary mean and variance estimates may be counted as part of the total number of calculated required samples if and only if:

  There is documented evidence that the waste containers for the preliminary estimate samples were selected in the same random manner as is chosen for the required samples. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

106   There is documented evidence that the method of sample collection in the preliminary estimate samples were identical to the methodology to be employed for the required samples.

  There is documented evidence that the method of sample analysis in the preliminary estimate samples were identical to the analytical methodology employed for the required samples.

  There is documented evidence that the validation of the sample analyses in the preliminary estimate samples were comparable to the validation employed for the required samples. In addition, the validated samples results shall indicate that all sample results were valid according to the analytical methodology.

Upon collection and analysis of the preliminary samples, or at any time after the preliminary samples have been analyzed, the AMWTP may assign hazardous waste codes to a waste stream. For waste streams with calculated upper confidence limits below the regulatory threshold, the AMWTP shall collect the required number of samples if the AMWTP intends to establish that the constituent is below the regulatory threshold.

B2 2b Statistical Selection of Containers for Headspace Gas Analysis When a waste stream meets the conditions for representative headspace gas sampling as discussed in Section B 3a( 1), headspace gas sampling of that waste stream may be done on a randomly selected portion of containers in the waste stream. The minimum number of containers, n, that must be sampled is determined by taking an initial VOC sample from 10 randomly selected containers. These samples are analyzed for all the target analytes. The standard deviation, s, is calculated for each of the nine VOCs in Module IV, Table IV. D. 1 of the WIPP Hazardous Waste Permit. The value of n is determined as the largest number of samples ( not to exceed the number of containers in the waste stream or waste stream lot) calculated using equations B2 8 in the WIPP WAP Waste container samples from the preliminary mean and variance estimates may be counted as part of the total number of calculated required samples if and only if:

  There is documented evidence that the waste containers for the preliminary estimate samples were selected in the same random manner as is chosen for the required samples.

  There is documented evidence that the method of sample collection in the preliminary estimate samples were identical to the methodology to be employed for the required samples.

  There is documented evidence that the method of sample analysis in the preliminary estimate samples were identical to the analytical methodology employed for the required samples.

  There is documented evidence that the validation of the sample analyses in the preliminary estimate samples were comparable to the validation employed for the required samples. In addition, the validated samples results shall indicate that all sample results were valid according to the analytical methodology.

The mean and standard deviation calculated after sampling n containers can be used to calculate a UCL90 for each of the headspace gas VOCs using the methodology presented in Section B2 3b. AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

107 B2 3 Upper Confidence Limit for Statistical Sampling B2 3a Upper Confidence Limit for Statistical Solid Sampling Upon completion of the required sampling, final mean and variance estimates and the UCL90 for the mean concentration for each contaminant is determined. The observed sample n* is checked against the preliminary estimate for the number of samples ( n) to be collected before proceeding using the equation presented in Section B2 3a of the WIPP WAP.

If the observed sample n* estimate results in greater than 20 percent more required samples than were originally calculated, then the additional samples required to fulfill the revised sample estimate are collected and analyzed. The determination of n* is an iterative process that continues until the difference between n* and the previous sample determination is less than 20 percent.

Once sufficient sampling and analysis has occurred, the waste characterization will proceed. The assessment is made with 90 percent confidence. The UCL90 for the mean concentration of each contaminant will be calculated in accordance with the equation presented in Section B2 3a of the WIPPWAP

If the UCL90 for the mean concentration is less than the regulatory threshold limit, the waste stream is not assigned the hazardous waste code for this contaminant. If the UCL90 is greater than or equal to the regulatory threshold limit, the waste stream is assigned the hazardous waste code for this contaminant.

Compliance with the requirements for calculation and comparison of the UCL90 to regulatory thresholds is achieved through the execution of procedure MP TRUW 8.11, Data Reconciliation.

B2 3b Upper Confidence Limit for Statistical Headspace Gas Sampling If a waste stream meets the conditions for representative headspace gas sampling in Section B 3a( 1), a UCL90 concentration for each of the headspace gas VOCs is calculated from the sample data collected. The observed sample n* is checked against the estimate for the number of samples ( n) to be collected before proceeding using the equation presented in Section B2 3b of the WIPP WAP.

If the observed sample n* estimate results in greater than 20 percent more required samples than were originally calculated, then the additional samples required to fulfill the revised sample estimate are collected and analyzed. The determination of n* is an iterative process that continues until the difference between n* and the previous sample determination is less than 20 percent.

Then, the UCL90 is calculated using the UCL90 equation presented in Section B2 3a of the WIPP WAP. In this case, the UCL90 is the 90 percent upper confidence VOC concentration, x is the calculated mean VOC concentration and s is the standard deviation. The value of t( , n 1) is taken from Table 9 2 of Chapter 9 of SW 846. When composite sample headspace gas sample results are used, the mean, standard deviation, and t statistic are based on the number of composite samples analyzed, rather than the number of containers sampled. _ AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.2, Rev 2 Issued: 03/ 31/ 03 Effective: 03/ 31/ 03 Quality Assurance Project Plan ( QAPjP)

108 The calculated UCL90 concentration for each headspace gas VOC is then assigned to those containers in the waste stream not selected for headspace gas sampling. If the calculated UCL90 concentration is less than the applicable MDL, the MDL for the VOC is assigned to each unsampled container instead of the UCL90 concentration. Compliance with the requirements for calculations and comparisons for the UCL90 to regulatory threshold is achieved through MP TRUW 8.11, Data Reconciliation.

B2 4 Control Charting for Newly Generated Waste Stream Sampling For newly generated waste streams that AMWTP characterizes using control charts, significant process changes and process fluctuations associated with newly generated waste is determined using statistical process control ( SPC) charting techniques; these techniques require historical data for determining limits for indicator species, and subsequent periodic sampling to assess process behavior relative to historical limits. SPC is performed on waste prior to solidification or packaging for ease of sampling. If the limits are exceeded for any toxicity characteristic parameter, the waste stream is recharacterized, and the characterization is performed according to procedures required in the WIPP WAP.

A Shewhart control chart ( Gilbert 1987) is a control chart for means that can be used for checking whether current data are consistent with past data and whether shifts or trends in means have occurred. The control chart for means is constructed of a center line and upper and lower control limits that are based on the mean and standard deviation of historical data for the process. If a current sample mean from the process lies within the limits, the process is said to be " in control", or consistent with historical data. If the current mean exceeds the limits, the process has likely changed from historical periods.

Logical sets of historical data are used for the construction of limits in this application. The sets originate from initial characterization of the waste stream ( if available), from characterization of a different lot of the same waste stream, or from a similar retrievably stored waste stream. At a minimum, a logical set includes ten representative sample values collected and analyzed from the newly generated waste stream. The data used for construction of the limits is justified. The underlying assumptions for control charts are that the data are independent and normally distributed with constant mean µ and constant variance  2. The statistical tests for normality are conducted and data transformation to normality performed, if necessary. Transformations take place prior to any calculations that use the data.