HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN HNF 2600, Revision 15 May 11, 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN HNF 2600 Revision 15 Approved by: Signature on file Date: 05/ 11/ 2005 Office Director, CBFO Office of Characterization and Transportation ( print/ sign)

Approved by: Signature on file Date: 05/ 11/ 2005 Manager, CBFO Quality Assurance ( print/ sign)

Approved by: Signature on file Date: 05/ 10/ 2005 Site Project Manager ( print/ sign)

Approved by: Signature on file Date: 05/ 10/ 2005 Site Quality Assurance Officer ( print/ sign)

Approved by: Signature on file Date: 05/ 10/ 2005 Waste Certification Official ( print/ sign)

Approved by: Signature on file Date: 05/ 10/ 2005 Transportation Certification Official ( print/ sign)

Approved by: Signature on file Date: 05/ 10/ 2005 RL Project Director ( print/ sign) HNF 2600, REV 15 Page 3 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TABLE OF CONTENTS 1.0 INTRODUCTION .............................................................................................................. 16 2.0 CERTIFICATION PROJECT ORGANIZATION AT THE HANFORD SITE ................ 19 2.1 ORGANIZATION AND RESPONSIBILITIES.......................................................... 19 2.2 WASTE CHARACTERIZATION/ CERTIFICATION PROCESS............................. 25 2.3 CERTIFICATION PROJECT DOCUMENT CONTROL AND RECORDS MANAGEMENT..................................................................................................................... 41 3.0 COMPLIANCE PLAN FOR CH WAC............................................................................. 42 3.1 SUMMARY OF WIPP AUTHORIZATION BASIS .................................................. 42 3.2 CONTAINER PROPERTIES CRITERIA AND REQUIREMENTS ......................... 47 3.3 RADIOLOGICAL PROPERTIES CRITERIA AND REQUIREMENTS.................. 53 3.4 PHYSICAL PROPERTIES CRITERIA AND REQUIREMENTS............................. 61 3.5 CHEMICAL PROPERTIES CRITERIA AND REQUIREMENTS ........................... 61 3.6 DATA PACKAGES CONTENTS............................................................................... 64 4.0 HANFORD COMPLIANCE PLAN FOR CH TRAMPAC............................................... 66 4.1 CH TRUCON Document............................................................................................. 67 4.2 Compliance Program.................................................................................................... 70 4.3 CONTAINER AND PHYSICAL PROPERTIES REQUIREMENTS........................ 71 4.4 NUCLEAR PROPERTIES REQUIREMENTS........................................................... 80 4.5 CHEMICAL PROPERTIES REQUIREMENTS......................................................... 89 4.6 GAS GENERATION REQUIREMENTS ................................................................... 99 4.7 PAYLOAD ASSEMBLY REQUIREMENTS........................................................... 175 5.0 QUALITY ASSURANCE PLAN .................................................................................... 188 5.1 ORGANIZATION AND QA PROGRAM ................................................................ 191 5.2 PERSONNEL QUALIFICATION AND TRAINING............................................... 193 5.3 QUALITY IMPROVEMENT.................................................................................... 194 5.4 DOCUMENTS........................................................................................................... 195 5.5 RECORDS ................................................................................................................. 195 5.6 WORK PROCESSES................................................................................................. 196 5.7 PROCUREMENT...................................................................................................... 197 5.8 INSPECTION AND TESTING ................................................................................. 198 5.9 ASSESSMENT REQUIREMENTS .......................................................................... 200 5.10 SAMPLE CONTROL REQUIREMENTS ................................................................ 202 5.11 SCIENTIFIC INVESTIGATION REQUIREMENTS............................................... 202 5.12 SOFTWARE REQUIREMENTS .............................................................................. 203 6.0 REFERENCES ................................................................................................................. 203 HNF 2600, REV 15 Page 4 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN ACRONYMS AND ABBREVIATIONS AK acceptable knowledge ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials C of C Certificate of Compliance CAR corrective action report CBFO Carlsbad Field Office Certification Plan Hanford Site Transuranic Waste Certification Plan. CFR Code of Federal Regulations CH contact handled CH DSA Contact handled Documented Safety Analysis CH TRAMPAC Contact Handled Transuranic Waste Authorized Methods for Payload Control CH TRUCON Contact Handled Transuranic Waste Content Codes ( document) CH TRU contact handled transuranic CH WAC Contact Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant CIN container identification number CPR cellulosics/ plastic & rubber CWC Central Waste Complex DOE U. S. Department of Energy DOE RL U. S. Department of Energy Richland Operations Office DOT U. S. Department of Transportation dpm disintegration( s) per minute DQO data quality objective EPA U. S. Environmental Protection Agency FH Fluor Hanford FGE fissile gram equivalent FGE/ g mass values by 239Pu FGE conversion factors ICV inner containment vessel LDR land disposal restriction LWA Land Withdrawal Act M& O management and operating mrem/ hr milliroentgen( s) equivalent man per hour MS mass spectrometry NIST National Institute of Standards and Technology nCi/ g nanocurie( s) per gram NCR nonconformance report HNF 2600, REV 15 Page 5 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN NDA nondestructive assay NDE nondestructive examination NFT Nuclear Filter Technology NMED New Mexico Environment Department NRC U. S. Nuclear Regulatory Commission OCA outer containment assembly OCV outer containment vessel OPCTCD Overpack Payload Container Transportation Certification Document PATCD Payload Assembly Transportation Certification Document PCB polychlorinated biphenyl PCTCD Payload Container Transportation Certification Document PDP performance demonstration program PE Ci plutonium 239 ( 239Pu) equivalent curie( s) PFP Plutonium Finishing Plant Project Hanford Site Transuranic Waste Certification Project QA quality assurance QAO quality assurance objective QAPD DOE/ CBFO Quality Assurance Program Document QAPD Procedures Matrix Hanford Site TRU Waste Project Quality Assurance Program Document Procedures Matrix QAPjP Hanford Site Transuranic Waste Characterization Quality Assurance Project Plan QC quality control RCRA Resource Conservation and Recovery Act RCT radiological control technician RH remote handled RMS root mean square RSS root sum of squares RTR real time radiography SAR safety analysis report SPM site project manager SQAO site quality assurance officer SVOC semivolatile organic compound SW 846 Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods SWB standard waste box SWD Solid Waste Disposal TC toxicity characteristic TCO transportation certification official TDOP ten drum overpack HNF 2600, REV 15 Page 6 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TIC tentatively identified compound TRU transuranic TRUPACT II Transuranic Package Transporter II TRUPACT II SARP Safety Analysis Report for the TRUPACT II Shipping Package TWBIR Transuranic Waste Baseline Inventory Report VOC volatile organic compound WAP Waste Analysis Plan ( Attachment B of WIPP Hazardous Waste Facility Permit) WCO waste certification official WIPP Waste Isolation Pilot Plant WRAP Waste Receiving and Processing WSPF Waste Stream Profile Form WWIS Waste Isolation Pilot Plant Waste Information System HNF 2600, REV 15 Page 7 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN DEFINITIONS Acceptable knowledge ( AK)  An EPA term, which includes process knowledge and results from previous testing, sampling, and analysis, associated with the waste. AK includes information regarding the raw materials used in a process or operation, process description, products produced, and associated wastes. AK documentation includes the site history and mission, site specific processes or operations, administrative building controls, and all previous and current activities that generate a specific waste.

Activity   A measure of the rate at which a material emits nuclear radiation, usually given in terms of the number of nuclear disintegrations occurring in a given length of time. The common unit of activity is the curie, which amounts to 37 billion ( 3.7 x 1010) disintegrations per second. The International Standard unit of activity is the Becquerel and is equal to one disintegration per second.

Aluminum honeycomb spacer assembly  An assembly that is located within each end of the inner containment vessel ( ICV) to provide:

1. A generous void volume to accommodate payload gas generation.

2. An energy absorbing barrier between the payload and the ICV dished heads.

Assay  The observation of spontaneous or stimulated nuclear radiations, interpreted to estimate the content of one or more radionuclides in a material.

Assessment  Evaluation process used to measure the performance or effectiveness of a system and its elements. Assessment is an all inclusive term used to denote any of the following: audit, performance evaluation, management systems review, peer review, inspection, or surveillance.

Atomic energy defense activities   Activities of the Secretary of Energy ( and predecessor agencies) performed in whole or in part in carrying out any of the following functions: naval reactors development; weapons activities, including defense inertial confinement fusion; verification and control technology; defense nuclear material production; defense nuclear waste and materials byproduct management; defense nuclear materials security investigations; and defense research and development.

Audit  Planned and documented independent assessment to determine by investigation, examination, or evaluation of objective evidence, the adequacy of and compliance with established procedures, instructions, drawings, and other applicable documents, and the effectiveness of implementation. An audit should not be confused with surveillance or inspection activities performed for the sole purpose of process control or product acceptance.

Carbon composite filter  See filter vent.

Certification authority  Authorization to certify TRU waste to the WIPP waste acceptance criteria ( WAC) that is granted by the permittee to those TRU waste generator/ storage sites whose TRU waste programs have been evaluated and found to be acceptable. HNF 2600, REV 15 Page 8 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Certified waste  Payload containers loaded with waste that has been verified to meet the criteria of the CH WAC.

Chemical compatibility  Assessing the properties of all potential chemicals (> 1 weight percent) in a payload container. There must be no adverse safety or health hazards produced as a result of any mixtures that could occur.

Combustible materials  Organic materials that are dominantly cellulosic ( e. g., cotton, paper, cloth, wood, etc.), including plastics.

Compressed gas  Compressed gases are those materials defined as such by 49 Code of Federal Regulations ( CFR) 173, Subpart D.

Contact handled TRU waste  Transuranic waste packages that have a surface dose rate not greater than 200 mrem/ hr.

Contact handled transuranic waste authorized methods for payload control ( CH TRAMPAC)   The governing document for shipments in the TRUPAC II packagings.

Contact handled transuranic waste content codes ( CH TRUCON)   The document containing a description of the waste stream, waste form, and package configuration for each waste content code authorized for shipment in the TRUPACT II packagings.

Content code  A uniform system applied to waste forms to group those with similar characteristics for purposes of shipment in TRUPACT II packagings.

Corrosive materials  Corrosive materials are those defined as such by 40 CFR 261.22 ( a)( l).

Curie   A unit of activity equal to 37 billion ( 3.7 x 1010) disintegrations per second.

Decay heat  Heat produced by radioactive emissions that are absorbed in the surrounding material.

Defense TRU waste  Nuclear waste derived from the manufacture of nuclear weapons and operation of naval reactors. Associated activities include ( a) naval reactors development, ( b) weapons activities, including defense inertial confinement fusion, ( c) verification and control technology, ( d) defense nuclear materials production, ( e) defense nuclear waste materials and byproducts management, ( f) nuclear waste and materials security and investigations, and ( g) research and development. See permittee Interim Guidance on Ensuring Waste Qualifies for Disposal at the Waste Isolation Pilot Plant.

DOE field element  The first line DOE field element that carries the organizational responsibility for ( 1) managing and executing assigned projects, ( 2) directing contractors who conduct the projects, and ( 3) ensuring that environment, safety, and health are integral parts of each project. HNF 2600, REV 15 Page 9 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Dose equivalent rate   The radiation dose equivalent delivered per unit time ( e. g., rem per hour).

Explosive materials  Explosive materials are those defined as such by 49 CFR 173, Subpart C.

Filter vent  A filter vent is defined as filter media manufactured of carbon composite, Kevlar, stainless steel, or any material that enables the filter to meet the minimum performance specifications stipulated in the CH TRAMPAC.

Fissile gram equivalent ( FGE)  The mass of a fissile radionuclide normalized to 239Pu.

Flammable volatile organic compound ( VOC)  A headspace gas VOC that has a National Fire Protection Association ( NFPA) flammability hazard degree of 3 or 4 and a flash point of less than 100 ° F or considered by EPA to be a significant fire hazard under WIPP repository conditions. Flammable headspace gas VOCs that are evaluated for the TRU waste project are listed in table 5.2 2 of the CH TRAMPAC.

G value  The number of molecules of gas species produced per 100 electron volts of decay energy absorbed by the waste.

Germanium counter  An assay system that uses high purity germanium ( HPGe) detectors for measuring gamma radiation.

Glovebox  A sealed box with windows and rubber gloves attached to ports such that an operator may work inside the box without risk of contamination.

Headspace   The total contained volume of a container minus the volume occupied by the waste material.

Headspace gas   The gas within the headspace of a container.

Immobilized materials  Materials that are fixed in a solidified matrix ( e. g., glass, ceramic, cement, concrete).

Inner containment vessel ( ICV)  The assembly ( comprised of a lid and body) providing a secondary level of containment for the payload. Within each end of the ICV is an aluminum honeycomb spacer assembly.

Lower Limit of Detection   The level of radioactivity which, if present, will yield a measured value greater than the critical limit with a 95% probability. The critical limit is defined as that value which measurements of the background will exceed with a 5% probability.

Machine compacted Waste   Waste whose volume has been reduced using a mechanical process.

NaI ( TI) drum counter  An assay system that uses sodium iodide scintillation detectors for measuring gamma radiation. HNF 2600, REV 15 Page 10 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Newly generated TRU waste  Waste generated after the development, approval, and implementation of a TRU waste characterization program that has been granted certification authority by the permittee. Newly generated TRU waste also includes any previously generated waste ( see also retrievably stored waste) that undergoes any form of treatment, processing, or repackaging in accordance with an approved quality assurance project plan.

Nondestructive assay ( NDA)  Assay methods for waste items that do not affect the physical or chemical form of the material.

Nondestructive examination ( NDE)  Methods that allow examination of the contents of payload containers without affecting the chemical or physical forms of these items. See also radiography.

Oil Dri  A trade name for a basically clay material absorbent.

Operational day ( also " when in operation")  A 24 hour period in which an NDA characterization system is to be used to perform measurements for TRU wastes.

Operational week  Seven consecutive days, starting at 7 a. m. on Monday, in which an NDA characterization system performed WIPP related measurements on one or more days in that week.

Outer containment assembly  The assembly ( comprised of a lid and body) providing a primary level of containment for the payload. The outer containment assembly ( OCA) completely surrounds the inner containment vessel and consists of an exterior stainless steel shell, a relatively thick layer of polyurethane foam, and an inner stainless steel boundary, which forms the outer containment vessel ( OCV).

Outer containment vessel  The innermost boundary of the OCA.

Overpack  A container around another container.

Package  ( 1) A packaging plus its contents. ( 2) The reusable Type B shipping container ( i. e., TRUPACT II) loaded with TRU waste payload containers, which has been prepared for shipment in accordance with the package QA program. ( 3) In the regulations governing the transportation of radioactive materials, the packaging together with its radioactive contents, as presented for transport.

Packaging quality assurance plan  A site specific document that defines the quality assurance ( QA) and quality control ( QC) activities applicable to usage of the NRC approved packaging. This plan shall meet the requirements of 10 CFR Part 71, Subpart H. ( The Hanford Site Packaging QA Plan is addressed in section 5.0 of the Certification Plan.).

Packaging  The packaging is the container the waste is placed into for shipment that meets the requirements of 49 CFR 173, Subpart I, and 10 CFR 71.4. For TRU waste, the packaging is the reusable Type B shipping container for transport of TRU waste payload containers ( e. g., TRUPACT II). HNF 2600, REV 15 Page 11 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Passive active neutron counter  An assay system that uses passive neutron coincidence counting ( PNCC) to measure neutrons that occur spontaneously ( passive) and the differential die away technique ( DDT) to measure those that are induced as a result of neutron interrogation of fissile material ( active).

Payload  CH TRU waste contained within one of the approved configurations for shipment in the TRUPACT II ( e. g., fourteen 55 gallon drums, two SWBs, etc.). The payload is considered to include a lift pallet if SWBs are not used. Any dunnage used external to the 55 gallon drums or SWBs is also considered to be part of the payload.

Payload container  The outermost container ( e. g., 55 gallon drum, standard waste box [ SWB] or ten drum overpack ( TDOP) for TRU waste material that is placed in a reusable Type B shipping container ( e. g., TRUPACT II or RH TRU 72 B cask) for transport.

Payload assembly  An assembly of payload containers qualified for transport in a TRUPACT II.

Payload pallet  A lightweight pallet with an aluminum honeycomb core used for loading and unloading fourteen 55 gallon drums of CH TRU waste at one time.

Pipe component  A stainless steel container used for packaging specific waste forms within a 55 gallon drum. The pipe component is exclusively used as part of the pipe overpack.

Pipe overpack  A payload container consisting of a pipe component positioned by dunnage within a 55 gallon drum with a rigid, polyethylene liner and lid. Fourteen pipe overpacks will fit within the TRUPACT II packaging. The design and use of a pipe overpack is controlled by the NRC issued Certificate of Compliance when used in the TRUPACT.

Plutonium equivalent curie ( PE Ci)  An equivalent radiotoxic hazard of a radionuclide normalized to 239Pu.

polyethylene liners  Rigid drum liners molded from high density polyethylene, typically with a wall thickness of about 0.09 inches ( 90 mils). The liner generally has a snap on cover of the same material.

Pressurized containers. Smaller containers within the payload container which may hold compressed gas.

239Pu fissile gram equivalent  See fissile gram equivalent.

Pyrophoric  49 CFR 173.124 defines a pyrophoric as " a liquid or solid that, in small quantities and without an external ignition source, can ignite within five ( 5) minutes after coming in contact with air." This includes spontaneously combustible materials, water reactive materials, and oxidizers. Examples of pyrophoric radionuclides are metallic plutonium and americium. Examples of nonradioactive pyrophorics are organic peroxides, sodium metal, and chlorates. HNF 2600, REV 15 Page 12 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Quality Assurance Project Plan ( QAPjP)  A site specific document that describes the methods used by TRU waste generator/ storage sites to comply with the applicable requirements for TRU waste characterization specified in the Waste Isolation Pilot Plant ( WIPP) waste analysis plan ( WAP). The QAPjP incorporates qualitative or quantitative criteria for determining whether the waste characterization activities are being satisfactorily performed, describes all activities pertaining to TRU waste characterization required by the WAP, references site specific procedural and administrative controls, and identifies organizations and positions responsible for implementing waste characterization and certification activities.

Radioassay  All types of nondestructive or destructive assay techniques used to identify and quantify radionuclides in TRU waste. See also nondestructive assay ( NDA) and radiochemical assay.

Radiochemical assay  Destructive assay methods performed with wet samples in a radiochemical laboratory using separation techniques.

Radiography  A nondestructive testing method, also referred to as nondestructive examination ( NDE), that uses X rays, gamma rays, or neutrons to inspect and determine the physical form of waste.

Remote handled transuranic waste  Packaged TRU waste whose external surface dose rate exceeds 200 mrem per hour. For the WIPP, there is an upper limit of 1000 rem per hour.

Retrievably stored TRU waste  Waste generated after 1970 and before the development, approval, and implementation of a TRU waste characterization program that meets the requirements for certification authority. TRU waste that is generated outside the umbrella of the approved Hanford Site TRU Project may be managed as retrievably stored TRU waste to demonstrate compliance with applicable characterization and certification requirements.

Shipper  A TRU waste generator/ storage site that releases a TRUPACT II cask to a carrier for shipment.

Shipping category  A grouping system for the transport of TRU waste payload containers that quantifies gas generation parameters for transport using the TRUPACT II.

Shipping package  The packaging with its radioactive contents, or payload, as presented for transportation ( 10 CFR 71.4). The package is denoted as the TRUPACT II CH TRU waste shipping package, or equivalently, the TRUPACT II shipping package, or TRUPACT II package.

Standard waste box ( SWB)  A payload container authorized for use with TRUPACT II transportation packages that meets U. S. Department of Transportation ( DOT) Specification 7A packaging, or equivalent, requirements. The SWB was designed specifically to fit TRUPACT II. HNF 2600, REV 15 Page 13 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Summary category group   Used to segregate TRU mixed wastes into broad groups having similar physical forms. The summary category groups include homogeneous solids ( S3000) that are at least 50 percent by volume solid process residues, soil/ gravel ( S4000) that is at least 50 percent by volume soil/ gravel, and debris ( S5000) that is at last 50 percent by volume materials that meet the criteria specified in <IP_ADDRESS>0 New Mexico Administrative Code ( incorporating 40 CFR § 268.2 ( g)). If a waste does not include at least 50 percent of any given category by volume, then the summary category group assigned shall be the same as that constituting the greatest volume of waste for that waste stream.

Ten drum overpack  A specialized payload container authorized for use within the TRUPACT II packaging. One SWB, six 85 gallon drums, or ten 55 gallon drums can fit inside a ten drum overpack ( TDOP). One TDOP will fit within the TRUPACT II packaging.

Tentatively identified compounds ( TICs)  Nontarget compounds identified using GC/ MS. The reported concentrations for TICs will have a higher uncertainty associated with them than the reported target analyte concentrations.

Test category  Payload containers that do not meet the analytical category decay heat limits or whose concentration of flammable VOCs in the headspace exceeds 500 ppm are classified a test category.

Transportation authority  Authorization for use of the TRUPACT II or RH TRU 72 B cask for transportation of TRU waste, which is granted by the permittee to those TRU waste generator/ storage sites whose TRU waste programs have been evaluated and found to be acceptable.

Transuranic ( TRU) wastes  Wastes contaminated with alpha emitting radionuclides of atomic number greater than 92 ( e. g., the radioactive isotopes of plutonium), having half lives greater than 20 years, and present in concentrations greater than 100 nanocuries per gram of waste.

TRU alpha ( or  ) activity concentration  The measured or reported sum of the activities for all TRU isotopes with half lives greater than 20 years that predominately undergo alpha decay per unit mass of the waste.

TRU isotope  Any isotope with an atomic number greater than 92. For purposes of calculating PE Ci, 233U is treated as a TRU isotope.

TRU mixed waste  TRU waste that is co contaminated with hazardous constituents as identified in 40 CFR Part 261, Subparts C and D.

TRU waste certification plan  A site specific document that describes the methods used by TRU waste generator/ storage sites to comply with each TRU waste acceptance criterion and requirement established in the CH WAC. The certification plan shall include procedural and administrative controls and must describe all activities pertaining to TRU waste certification, including the required QA and QC activities applicable to the certification of TRU waste. HNF 2600, REV 15 Page 14 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TRUPACT II  An NRC certified Type B transportation packaging used for transportation of CH TRU wastes.

TRUPACT II packaging  The packaging consisting of an OCA, ICV, and two aluminum honeycomb spacer assemblies.

TRUPACT II user  Organizations or facilities that prepare a TRUPACT II for release to a carrier for shipment. Users ensure, via their TRUPACT II user program, that the payload, inspection, testing, closing, and release for shipment of the TRUPACT II meets the requirements of the TRUPACT II certificate of compliance. Users may also perform minor maintenance on the TRUPACT II.

Twist and tape  A method of bag closure for waste consisting of gathering the neck of the bag, twisting tightly, and wrapping tightly with plastic tape. Often called " horsetail."

Validation  An activity that demonstrates or confirms that a process, item, data set, or service satisfies the requirements defined by the user. Data validation requirements for the TRU waste project are described in the QAPjP.

Verification  The act of authenticating or formally asserting the truth that a process, item, data set, or service is ( in fact) that which is claimed. Data verification is the process used to confirm that all review and validation procedures have been completed. Data verification requirements for the TRU waste project are described in the QAPjP.

Visual examination ( VE) technique  A process of verification for newly generated waste involving two independent verifications of the physical form of the waste container contents. The process consists of the first operator confirming and documenting the contents ( e. g., inventory) of the container at the time of packaging. A second operator documents concurrence of the waste container contents. Corrective actions are taken if either the first or the second operator cannot confirm the waste contents ( e. g., inventory).

Volatile organic compounds ( VOC)  For the purposes of the TRU waste project, those gas VOCs listed in the WIPP Hazardous Waste Facility Permit Waste Analysis Plan ( WAP) Table B 1 and any additional compounds tentatively identified by the VOC analytical procedures used to satisfy TRU waste characterization requirements specified in the WAP.

Waste acceptance criteria  Criteria developed for the safe disposal of TRU waste in the WIPP, meeting the very long term disposal requirements of the WIPP underground salt bed.

Waste certification  Formal and documented activities associated with waste processing and records required to certify that the waste has been characterized and meets the requirements of the CH WAC.

Waste characterization  The process of determining that TRU waste meets the requirements of the CH WAC by the acceptable performance of the activities defined by site specific, permitteeapproved TRU waste project documents. HNF 2600, REV 15 Page 15 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Waste form  The physical form of the waste ( e. g., sludge, combustibles, metals, etc.).

Waste material type  Further divisions of waste types based on gas generation potential expressed as the G value for hydrogen.

Waste matrix code  A DOE developed coding system for grouping waste streams that have similar matrix constituents, especially for treatment objectives. This coding system allows waste streams within the DOE TRU waste system that have similar physical and chemical waste form properties to be categorized together.

Waste matrix code group  A term used in the WIPP WAP to group waste streams related to physical and chemical properties.

Waste package assembly  An assembly of waste packages, such as a seven pack of drums that is intended to be handled and emplaced in a single unit by the WIPP waste handling system.

Waste packaging  The process of filling a payload container with waste and remaining within the controls applied to layers of confinement and other WIPP waste acceptance criteria.

Waste stream  Waste material generated from a single process or from an activity that is similar in material, physical form, and hazardous constituents.

Waste type  Waste type refers to physical types of waste such as debris, soils and gravels, solidified inorganics, solid inorganics, solidified organics, and solid organics. HNF 2600, REV 15 Page 16 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 1.0 INTRODUCTION As a generator of transuranic ( TRU) and TRU mixed waste destined for disposal at the Waste Isolation Pilot Plant ( WIPP), the Hanford site must ensure that its TRU waste meets the requirements of U. S. Department of Energy ( DOE) O 435.1, Radioactive Waste Management, and DOE/ WIPP 02 3122, Contact Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant ( CH WAC). CH WAC requirements are derived from the WIPP Technical Safety Requirements, WIPP Contact Handled Documented Safety Analysis ( WIPP CH DSA), the transportation requirements for CH TRU wastes derived from the Transuranic Package Transporter Model II ( TRUPACT II) Certificate of Compliance, WIPP Land Withdrawal Act ( WIPP LWA), WIPP Hazardous Waste Facility Permit, the U. S. Environmental Protection Agency ( EPA) Compliance Certification Decision, the initial Report for PCB Disposal Authorization, the EPA letter of approval to land dispose non liquid PCBs at WIPP and the Revision to the Record of Decision for the DOEs WIPP Disposal Phase. The CH WAC establishes the specific physical, chemical, radiological, and packaging criteria for acceptance of defense TRU waste shipments at WIPP. The CH WAC also requires that participating DOE TRU waste generator/ treatment/ storage sites produce site specific documents, including a certification plan, that describe their program for managing TRU waste and TRU waste shipments before transferring waste to WIPP. In addition, the QAPD specifies the need to develop a quality assurance ( QA) plan that meets all applicable requirements of the QAPD. The Hanford Site is not implementing the use of the HalfPACT, 100 gallon drum, machine compaction ( pucks), payload management, S300 pipe overpacks, or controlled shipments.

Waste characterization activities provide much of the data upon which certification decisions are based. Waste characterization requirements for TRU waste and TRU mixed waste are established in the WIPP Hazardous Waste Facility Permit Waste Analysis Plan ( WIPP WAP). HNF 2599, Hanford Site Transuranic Waste Characterization Quality Assurance Project Plan, implements the applicable requirements in the WIPP WAP and includes the qualitative and quantitative criteria for making hazardous waste determinations. The Hanford site must also ensure that its TRU waste destined for disposal at WIPP meets requirements for transport in the Transuranic Package Transporter II ( TRUPACT II). The U. S. Nuclear Regulatory Commission ( NRC) establishes the TRUPACT II requirements in the Safety Analysis Report for the TRUPACT II Shipping Package ( TRUPACT II SAR), and the CH TRAMPAC. Hanford's QA packaging plan is defined in section 4.0 of this Certification Plan, consistent with 10 CFR Part 71, Subpart H.

In addition, a TRU waste is eligible for disposal at WIPP only if it has been generated in whole or in part by one or more of the activities listed in Section 10101( 3) of the Nuclear Waste Policy Act. DOE sites must determine that each waste stream to be disposed of at WIPP is " defense" TRU waste. ( See also the definition of " defense" TRU waste.) Only CH TRU wastes meeting the requirements of HNF 2599, WIPP WAP, CH WAC, and other requirements documents described above will be accepted for transportation and disposal at WIPP. HNF 2600, REV 15 Page 17 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 1 1 illustrates the hierarchy of regulatory requirements for TRU waste certification and reflects the flowdown of requirements from higher level documents to site level program documents and implementing procedures. To ensure future changes to the CH WAC and other relevant requirements documents are appropriately reflected, this Hanford Site Transuranic Waste Certification Plan ( certification plan) will be reviewed at least annually and updated as necessary.

This certification plan establishes the programmatic framework and criteria within which the Hanford site ensures that CH TRU wastes can be certified as compliant with the CH WAC and CH TRAMPAC ( as applicable). This certification plan does not address remote handled ( RH) defense TRU forms. RH TRU waste will not be shipped or accepted at WIPP until it has been addressed. This certification plan includes the following sections:

  Section 2.0, " Certification Project Organization at the Hanford Site," identifies Hanford site organizations involved in the TRU waste certification project ( the project), describes the interaction between the characterization, certification, and transportation personnel, and lists the responsibilities of key project officials.   Section 3.0, " Compliance Plan for CH WAC," summarizes the CH WAC requirements and describes Hanford site TRU Project activities and specific documents that implement and verify compliance with each requirement.   Section 4.0, " Compliance Plan for CH TRAMPAC," summarizes the CH TRAMPAC requirements and describes Hanford site TRU Project activities and practices that demonstrate compliance with the TRUPACT II SAR.   Section 5.0, " Quality Assurance Plan," describes how the Hanford site TRU Project complies with the Quality Assurance Program Document, CH WAC, and 10 CFR Part 71, Subpart H, QA requirements for TRU waste certification and use, maintenance, and control of packages used to store and transport waste to WIPP in compliance with U. S. Department of Transportation ( DOT) and NRC requirements.

This certification plan, which includes the compliance plan for CH TRAMPAC and associated QA plan, together with HNF 2599 establish the basis for the Hanford site's TRU waste characterization, certification, and transportation packaging operations. The QA plan also meets applicable requirements of the QAPD. These documents are submitted to the Carlsbad Field Office ( CBFO) for review and approval. HNF 2600, REV 15 Page 18 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN  Quality control requirements between documents Figure 1 1  Hanford Site TRU Waste Certification Document Hierarchy DOE/ CBFO WIPP CH Documented Safety Analysis ( FEIS, SEIS I, SSEIS II QAPD CH WAC NMED WIPP Hazardous Waste facility Permit EPA WIPP Compliance Certification Decision WIPP Approval for PCB Disposal Hanford Site QAPjP HNF 2599 Hanford Site Certification Plan HNF 2600 TRU Project Facility Procedures NRC TRUPACT II Certificates Of Compliance CONGRESS WIPP Land Withdrawal Act Energy & Water Development Appropriations Act WIPP CH TRU Waste Acceptance Criteria HNF 2600, REV 15 Page 19 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 2.0 CERTIFICATION PROJECT ORGANIZATION AT THE HANFORD SITE The responsibilities for TRU waste management at the Hanford site are distributed within various organizations. This section identifies the Hanford site organizations involved in the project and describes the responsibilities of and interactions between these organizations. Delegation of authority for decision making will be designated to the lowest appropriate level within the various organizations. This section also contains generalized process flow diagrams for TRU waste certification activities associated with newly generated and retrievably stored TRU waste, summarizes the use of acceptable knowledge ( AK) in the certification project, and describes the document control and records management process.

2.1 ORGANIZATION AND RESPONSIBILITIES Figure 2 1 is a functional organization chart pertaining to TRU waste characterization, certification, and payload assembly activities at the Hanford site. The following subsections identify the organizations that oversee the project and describe the roles and responsibilities of key positions within the project charged with implementing the requirements defined in this certification plan.

2.1.1 Office Director, CBFO Office of Characterization and Transportation The Office Director, CBFO Office of Characterization and Transportation executes program functions related to characterization of waste for disposal at the WIPP. The Office Director manages the CBFO Office of Characterization and Transportation team, which is responsible for TRU waste characterization.

The Office Director or designee assists sites in preparing their waste for shipment to WIPP for disposal. The Office Director or designee develops options, recommendations, and guidelines for program activities and provides overall technical oversight of the TRU waste program activities at participating DOE sites. The Office Director or designee, in conjunction with the permittee QA manager, is responsible for conducting audits of all activities associated with TRU waste characterization and certification described in the WIPP Hazardous Waste Facility Permit and associated WAP and QAPD. The Office Director or designee reviews and approves this certification plan before its implementation. The permittee QA manager also reviews and approves this certification plan.

2.1.2 DOE Richland Operations Office The U. S. DOE Richland Operations Office ( RL) Assistant Manager for Central Plateau is responsible for project execution and oversight, and serves as an interface between permittee and the Hanford site. The RL Project Director ensures that certification plan activities comply with applicable DOE orders, the WAP, QAPD, CH WAC, CH TRAMPAC, and all applicable federal and state regulations. The RL Project Director also ensures that resources and funding are available to accomplish TRU waste certification activities. HNF 2600, REV 15 Page 20 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN WSCF HGS sampling ( tech.), HG analysis CWC Container management; HGS Waste Serv.

Container mgmt./ tracking/ status/ resolution, VE ( technical) Director TRU Program/ Mgr. Operations, SPM AK WCO TCO RL Project Director PFP VE technique, solid sampling, NDA TRU Cert. Supp. Training, records, procedures, CAM/ DE, WWIS, Procurement, Contracts, ESL T Plant HGS Repackaging QA Director Internal assessments, QC test/ inspection SQAO FQAO WRAP NDA, NDE, VE ( ops), VE Technique, HGS, TRUPACT II, Repackaging RL TRU Waste Program Manager Figure 2 1 Hanford Site TRU Waste Certification Project Functional Organization Chart Lines of communication Lines of authority HNF 2600, REV 15 Page 21 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 2.1.3 Site Project Manager The site project manager ( SPM) is the principal point of contact with DOE ( including permittee, CBFO Office of Characterization and Transportation, and RL) for technical activities associated with TRU waste. The SPM provides programmatic support for Hanford site TRU waste organizations involved in TRU waste storage, characterization, certification, and transportation activities. The SPM coordinates with the Hanford site waste certification official ( WCO) and transportation certification official ( TCO) and oversees project activities to ensure that Hanford site TRU waste is characterized and certified compliant with WIPP requirements. Specific project responsibilities assigned to the SPM include the following:

  Reviewing and approving HNF 2599 and this certification plan.   Ensuring that the Hanford site compliance plan for CH TRAMPAC and associated documents are revised, reviewed, approved, and implemented as necessary to maintain authorization for shipping TRU waste to WIPP.   Ensuring project personnel receive appropriate training and orientation.   Selecting, prioritizing, and tracking waste to be sampled and analyzed.   Validating and verifying project level analytical data.   Reconciling analytical data with data quality objectives ( DQOs).   Certifying Waste Stream Profile Form ( WSPF) data.   Obtaining AK information from waste generators regarding U. S. Environmental Protection Agency ( EPA) hazardous waste numbers.   Submitting quality assurance/ quality control ( QA/ QC) reports to DOE field offices.   Transmitting testing, sampling, and analytical data to Carlsbad Field Office ( CBFO), the permittee.   Assisting the Hanford site QA officer ( SQAO) in defining and standardizing project assessment criteria and preparing responses to deficiency reports, such as corrective action reports ( CARs), generated by permittee internal or other external assessment organizations.   Halting certification activities if problems affecting the quality of certification processes or work products exist.   Notifying personnel of nonconformances in accordance with WMP 400, Waste Isolation Pilot Plant Procedures, Section 1.3.2, " TRU Nonconforming Item Reporting and Control."

The SPM may delegate any of these activities to another individual; however, the SPM retains responsibility for ensuring that project requirements are met. HNF 2600, REV 15 Page 22 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 2.1.4 Hanford Site Quality Assurance Officer ( SQAO)

The SQAO plans and provides QA oversight for TRU waste characterization and certification and oversees the implementation of tHNF 2599 and the QA requirements of the certification plan. The SQAO's general responsibilities include the following:

  Scheduling and conducting QA assessments.   Reviewing and approving HNF 2599, this certification plan, and implementing procedures.   Coordinating internal and external audits and assessments to verify compliance.   Reviewing and approving supplier and subcontractor QA plans as appropriate.   Tracking and evaluating trends in compliance with QA objectives ( QAOs) established in HNF 2599 and Appendix E of this Certification Plan by performing the following:

1. Ensuring that testing, sampling, and analytical facilities are assessed.

2. Ensuring that nonconformance reports ( NCRs) or CARs that affect project activities are prepared, when appropriate.

3. Tracking and trending nonconformances.

4. Verifying corrective actions have been taken to resolve nonconformances.

5. Validating and verifying data at the project level.

6. Submitting QA/ QC reports to the SPM, as needed.

7. Preparing and submitting semiannual QA summary reports to the SPM.

  Coordinating responses to deficiency reports ( e. g., CARs) generated by permittee or other external assessment organizations.   Providing QA oversight for data package assembly and interface with the WIPP Waste Information System ( WWIS).   Stopping certification activities if problems affecting the quality of certification processes or work products exist.   Having direct access to responsible management at a level where appropriate action can be affected.   Being sufficiently independent from cost and schedule considerations.   Having the organizational freedom to communicate with management.   Having no assigned responsibilities unrelated to the QA program that would prevent appropriate attention to QA matters.   Developing, establishing, and interpreting QA policy, and ensuring effective implementation.   Interfacing, as appropriate, with the permittee staff, participants, and other stakeholders on QA matters. HNF 2600, REV 15 Page 23 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN   Assisting subordinate organizations with quality planning, documentation, quality measurements, and problem identification and resolution.   Providing guidance to all applicable subordinate organizations concerning identification, control, and protection of QA records.

The SQAO may designate one or more individuals to perform the above functional responsibilities but retains ultimate responsibility for ensuring compliance with project requirements.

2.1.5 Hanford Site Waste Certification Official ( WCO)

The Hanford site WCO is responsible for certifying all data and information necessary to document that all TRU waste payload containers prepared for shipment to WIPP meet all specified criteria. The WCO coordinates activities related to waste characterization and works closely with the SQAO to effect QC of the project. Specific duties and responsibilities of the WCO include the following:

  Certifying that waste packages meet CH WAC requirements.   Interfacing with the SPM, TCO, and SQAO on matters related to waste characterization and certification.   Implementing the following project QA activities:

1. Reviewing and approving this certification plan.

2. Ensuring that waste characterization and certification documents are managed as QA records in the designated repository.

3. Preparing NCRs and CARs, and documenting corrective actions.

4. Coordinating with the SQAO to analyze trends in project nonconformances for waste characterization related activities.

5. Assisting the SQAO in preparing responses to deficiency reports ( e. g., CARs) generated by permittee or other external assessment organizations.

  Stopping waste characterization activities if problems affecting the quality of certification processes or work products exist.   Ensuring the data on characterization and certification entered into the WWIS are accurate and demonstrate the acceptability of the waste for transport to and disposal at the WIPP.

The WCO may designate one or more individuals to perform these responsibilities but retains ultimate responsibility for ensuring that project requirements are met. HNF 2600, REV 15 Page 24 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 2.1.6 Hanford Site Transportation Certification Official ( TCO)

The Hanford site TCO ensures that the site specific TRU waste packaging and transportation activities comply with the CH TRAMPAC, and DOT requirements specified in 49 CFR 173 and NRC requirements in 10 CFR 71. The TCO verifies payload containers and payload assemblies and ensures compliance with all packaging and records requirements. The TCO obtains WIPP authority to ship and ensures that all requirements are met before the transportation packaging is released to a carrier for transport. Specific TCO responsibilities include the following:

  Ensuring that the Hanford site compliance plan for CH TRAMPAC and associated documents are revised, reviewed, approved, and implemented, as necessary, for the Hanford site to maintain authorization for offsite shipments of TRU waste.   Interfacing with the originating facility to develop and maintain procedures to load the TRUPACT II in accordance with the TRUPACT II SAR, CH TRAMPAC, and CH WAC to ensure that all payloads meet all applicable requirements.   Maintaining Hanford site content codes in accordance with the CH TRUCON document, and requesting revisions from CBFO, as necessary.   Interfacing with the SPM, WCO, and SQAO on matters related to payload certification and offsite transportation of TRU waste.   Reviewing and approving this certification plan.   Reviewing all payload data sheets, and documenting compliance with all packaging and shipping requirements described in this certification plan.   Preparing and signing bills of lading, uniform hazardous waste manifests ( UHWM), and land disposal restriction ( LDR) notifications, as appropriate.

Shipping activities related to the TRUPACT II and WIPP acceptance include the following:

  Ensuring compliance with applicable DOT and NRC regulations.   Providing guidance to waste generators to assist their efforts to comply with the CHTRAMPAC and CH WAC criteria and requirements in implementing procedures affecting characterization, QA, and waste certification.   Ensuring that the proper shipping category, content code, and waste form are assigned to each container and shipment.   Reviewing all payload data sheets and Hanford site records to guarantee and document compliance with all packaging and shipping requirements.   In conjunction with the WCO, ensuring all waste containers and shipments are certifiable for transport and all documentation packages are complete and accurate.   Ensuring all data entered into the WWIS is accurate and demonstrates the acceptability of the waste for transport to and disposal at the WIPP.   Approving by signature on the transportation certification documents for every payload.   Completing PCTCD, OPCTCD, and PATCD and preparing shipping data.   Providing guidance to loading personnel for assembling and loading payload containers.   Entering final shipping data into WWIS. HNF 2600, REV 15 Page 25 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN The TCO may designate one or more individuals to perform these responsibilities but retains ultimate responsibility for ensuring that certification related project requirements are met.

2.2 WASTE CHARACTERIZATION/ CERTIFICATION PROCESS The Hanford site TRU waste process for characterizing and certifying waste and preparing it for transport to WIPP involves a series of operations based on whether the waste is retrievably stored or newly generated and the physical form of the waste. Newly generated TRU waste is defined as TRU waste generated after the New Mexico Environment Department ( NMED) notifies WIPP, by approval of the final audit report, that the Hanford site has satisfactorily implemented the characterization requirements of the WAP.

Initially, acceptable knowledge ( AK) is used to delineate all TRU waste containers into waste streams and assign an appropriate waste matrix code group category based on the physical form of the waste and the waste contents. AK is also used to make determinations regarding EPA hazardous waste numbers, radionuclide composition, and prohibited item restrictions. AK information for each waste stream is assessed and verified through evaluation of results from applicable testing, sampling, and analytical activities.

Waste characterization requirements for retrievably stored and newly generated wastes differ, as summarized below.

  Radiography and/ or visual examination ( VE) are used to identify and/ or confirm the waste matrix code group category and waste material parameter designations and identify prohibited items. All retrievably stored waste containers undergo radiography. Radiography is confirmed by VE on a randomly selected number of containers in each retrievably stored waste stream. For newly generated waste, physical form and prohibited items are verified during packaging using the VE technique. The VE technique is not the same process as VE that is performed to verify radiography. The VE technique involves two independent verifications of the physical form of the waste and contents at the time of packaging. The first operator documents the content of the waste container, providing a written inventory of actual or estimated weights of each item place in the container. The operator also documents that prohibited article( s) are not present. A second, independent operator provides additional verification by reviewing the waste contents and ensuring correct reporting of the waste container content. Corrective actions are taken if either the first or second operator cannot independently confirm the waste designations.   Radioassay data identify and quantify radionuclide composition and concentration. All TRU waste containers from newly generated and retrievably stored waste streams undergo radioassay.   Headspace gas sampling and analysis provide data to determine potential flammability and confirm EPA hazardous waste numbers of each waste container. All TRU waste containers from newly generated and retrievably stored waste streams or randomly selected containers from waste streams that meet the conditions for reduced headspacegas sampling listed in HNF 2599, Section B 3a( 1), undergo headspace gas sampling and analysis. HNF 2600, REV 15 Page 26 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN   Sampling and analysis of homogeneous wastes provide data to confirm listed and toxicity characteristic EPA hazardous waste numbers and quantify hazardous constituent concentration. The RCRA regulated constituents in newly generated homogeneous solid waste streams are documented and verified at the time of generation based on AK and sampling and analysis. For continuous processes that result in newly generated homogeneous wastes ( except soil/ gravel waste streams), initial sampling is conducted, and process control parameters are established to develop a baseline control chart for the process. The parameter limits for a waste generating process are established in specific written procedures for the process. Process performance relative to the established parameter limits is determined through annual sampling of the process, which is conducted on a random basis. If the parameter limits are exceeded, the waste stream is recharacterized according to procedures and methods specified for retrievably stored waste. In cases where control charting is not useful in controlling hazardous waste constituents, homogeneous wastes are characterized in process batches as described in HNF 2599, section B 3d( 1)( a). The number of newly generated soil/ gravel waste containers to be randomly sampled and analyzed is determined through a statistical selection process. Using a similar approach, a statistically selected portion of retrievably stored homogeneous solids and soil/ gravel wastes are sampled and analyzed to confirm waste constituents.   On a case by case basis, in consultation with the CBFO, certain waste streams may be characterized using sampling and analysis results from another TRU waste generator/ storage site that has received certification authority from CBFO. Homogeneous waste solid sampling and analysis, headspace gas sampling and analysis, radioassay, and radiography/ visual examination are all examples of characterization techniques that may be performed by other sites. The data will be useable to certify waste so long as it was gathered using plans and procedures that have been evaluated through an audit conducted by CBFO and deemed to meet the requirements of the WIPP Hazardous Waste Permit, QAPD, and CH WAC.

Radioassay and analytical facilities ( i. e., headspace gas and homogeneous waste stream analysis) are qualified through participation in the applicable performance demonstration program ( PDP). The PDP program supports the determination of a facility to meet QA objectives.

The SPM reconciles waste characterization data against applicable data quality objectives ( DQOs). Data quality objectives are qualitative and quantitative statements that specify WIPP program technical and quality objectives. DQOs are determined through the DQO process. The DQOs for the waste characterization activities are contained in the WAP, attachment B3 and Subsection 3.3 and Appendix E of this Certification Plan.

On a case by case basis, in consultation with CBFO, the SPM may choose to accept data validation and verification and DQO reconciliation performed by other sites that have been granted waste certification authority by CBFO. HNF 2600, REV 15 Page 27 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figures 2 2a through 2 2f and 2 3a through 2 3e illustrate the typical process flow for retrievably stored and newly generated TRU waste, respectively. Certain characterization activities identified for retrievably stored waste may be applied to newly generated waste and vice versa, provided that compliance with waste characterization requirements can be adequately demonstrated. In addition, variance from the depicted flow path within each process may be necessary to address technical or operational needs. Sections 3.0 and 4.0 detail the methods of compliance and verification for each certification related process and identify applicable implementing procedures.

2.2.1 Waste Stream Documentation Hanford site waste generators produce waste stream documentation to meet Hanford site waste acceptance criteria and support the waste stream approval process. Waste stream information is supplied on site specific forms and attachments. At a minimum, generators provide the following waste stream information:

  Generator information   Waste stream name   Waste generating process description   Radiological information ( e. g., classification, reportable radionuclides, characterization method)   Chemical constituent information ( e. g., chemicals present, concentration ranges, characterization methods)   Land disposal restriction ( LDR) information, including identification of underlying hazardous constituents, if applicable   Waste type information ( e. g., physical state, inert materials, and stabilizing agents and/ or absorbents used)   Packaging information ( e. g., container type and size, maximum weight)   Additional attachments, including process flow information, analytical data, container drawings, or other waste acceptance information. HNF 2600, REV 15 Page 28 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 2a. Certification Flow for Retrievably Stored TRU Waste. HNF 2600, REV 15 Page 29 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Yes Yes Yes No No No Figure 2 2b. Certification Flow for Retrievably Stored TRU Waste ( continued)

Repackage compliant waste Remove noncompliant waste items NDE Criteria   Verify waste contents   Identify prohibited waste items   Verify correct packaging   Estimate waste material parameter weights. Go to Figure 2 2c NDE Data Package   Waste matrix code   Content description   Number of layers of packaging   Waste material parameter weights NDA Data Package   Pu 239 FGE   PE Ci   Isotopic composition and concentration   Wattage ( decay heat)

Incoming waste containers from Figures 2 2a, 2 2d, or 2 2e Does NDE confirm that waste container meets WIPP criteria?

NDA for glovebox waste acceptance NOTE   If waste is LLW, remove from TRU Program NDA Criteria   Calculate Pu

239 FGE   Determine radionuclide composition and concentration   Determine TRU alpha activity   Calculate decay heat Does NDA confirm that waste container meets WIPP criteria?

Is waste low level?

CERTIFICATION INFORMATION Remove waste from TRU Programs HNF 2600, REV 15 Page 30 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 2c. Certification Flow for Retrievably Stored TRU Waste ( continued) HNF 2600, REV 15 Page 31 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 2d. Certification Flow for Retrievably Stored TRU Waste ( continued) HNF 2600, REV 15 Page 32 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 2e. Certification Flow for Retrievably Stored TRU Waste ( continued) HNF 2600, REV 15 Page 33 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 2f. Certification Flow for Retrievably Stored TRU Waste ( concluded) HNF 2600, REV 15 Page 34 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 3a. Certification Flow for Newly Generated TRU Waste HNF 2600, REV 15 Page 35 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 3b. Certification Flow for Newly Generated TRU Waste ( Continued) HNF 2600, REV 15 Page 36 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 3c. Certification Flow for Newly Generated TRU Waste ( Continued) HNF 2600, REV 15 Page 37 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 3d. Certification Flow for Newly Generated TRU Waste ( Continued) HNF 2600, REV 15 Page 38 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Figure 2 3e. Certification Flow for Newly Generated TRU Waste ( Concluded) HNF 2600, REV 15 Page 39 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Information supplied by waste generators is supplemented with information gathered during TRU Project characterization and certification activities to meet data requirements for completing the permittee Waste Stream Profile Form ( WSPF) and WWIS submittals.

2.2.2 Acceptable Knowledge Documentation The Hanford site uses AK to assign waste matrix code groups, content codes, and EPA hazardous waste numbers and to determine the waste material parameters and radionuclides present in waste streams. For each TRU waste stream ( and/ or waste stream lot), AK information is compiled in an auditable record; confirmed through radiography, VE, VE technique, radiological assay, headspace gas sampling and analysis, and homogeneous waste sampling and analysis ( applicable to homogeneous solids and soil/ gravel waste streams only); and audited periodically to ensure adequacy of the information.

Information compiled to document AK on a site wide and facility specific basis includes TRU waste management project information, waste stream information, and supplemental documentation ( including reference lists), as needed. The SPM ( or designee) reviews waste stream documentation and data packages resulting from radiography, VE, VE technique, headspace gas sampling and analysis, and solidified waste sampling and analysis ( as appropriate) to confirm waste matrix code group designations, EPA hazardous waste numbers, and waste material parameter designations using AK. Changes to EPA hazardous waste numbers are identified and justified based on confirmatory testing data. AK information is reevaluated if discrepancies are identified between AK documentation and data from confirmatory testing.

2.2.3 Waste Characterization and Certification Data Reporting The SPM ( or designee) reconciles TRU waste characterization data with DQOs and completes a WSPF for each Hanford site TRU waste stream to be disposed at the WIPP. Summaries of waste stream information and reconciliation of DQOs comprise WSPF attachments. WMP 400, Section 7.1.1, " Transuranic Waste Characterization Data Quality Objectives Reconciliation and Reporting," specifies the information required to complete the WSPF and describes the process for reconciling waste characterization data with project required parameters, preparing data summary reports, and correlating container identification to data packages.

Before shipping TRU waste containers from a WIPP accepted and approved waste stream, the SPM transmits waste characterization, certification, and shipment data to the WIPP using the WWIS. Only data that is finalized and been through all the data validation steps can be entered in WWIS. WWIS contains limit and edit checks on some of the WAC requirements and assists WIPP in determining that waste is acceptable for disposal at WIPP. WMP 400, Section 7.1.5, " WIPP Waste Information System Data Entry and Reporting," describes the process for entering and reporting required data on payload containers and assemblies into the WWIS. WIPP will only accept waste container shipments for disposal if the waste container information has been correctly submitted to the WWIS and approved for shipment by the WIPP data administrator. HNF 2600, REV 15 Page 40 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 2.2.4 Qualification of Existing Data The qualification process shall be conducted in accordance with approved procedures that provide for documentation of the decision process, the factors used in arriving at the choice of the qualification method, and the decision that the data are qualified for their intended use. Existing data shall be qualified using one or a combination of the following methods:

1. Determination that the data were collected under a QA program that is equivalent in effect to ASME NQA 1 1989 edition; ASME NQA 2a 1990 addenda, Part 2.7, to ASME NQA 2 1989 edition; and NQA 3 1989. Factors to be considered include:

a. Qualifications of personnel or organizations generating data b. Technical adequacy of the equipment and procedures used to collect and analyze the data c. Environmental conditions under which the data were obtained ( if germane)

d. Quality and reliability of the measurement control program under which the data were generated e. Extent to which data demonstrate properties of interest ( e. g., physical, chemical, geologic, or mechanical)

f. Extent to which conditions generating the data may partially meet requirements of DOE CBFO 94 1012 g. Prior uses of the data and the associated verification processes h. Prior peer or other professional reviews of data and their results i. Extent and reliability of the documentation associated with the data j. Extent and quality of corroborating data or confirmatory testing results k. Degree to which data generating processes were independently audited l. The importance of the data in showing that the repository design meets the performance objectives 2. The use of corroborating data, with the data relationships and inferences clearly identified and justified.

3. Confirmatory testing that is performed and documented. HNF 2600, REV 15 Page 41 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 4. Peer review conducted in a manner that is compatible with NUREG 1297, Peer Review for High Level Nuclear Waste Repositories.

a. Peer reviews shall be performed when the adequacy of information or the suitability of procedures and methods essential to showing that a repository system meets its performance requirements with respect to safety and calculations, or reference to previously established standards and practices.

b. Peer reviews performed in support of WIPP compliance activities shall be documented, as shall all peer review processes 5. Peer reviews are used for the following activities:

a. Conceptual models selected and developed by DOE b. Waste characterization analysis as required in 40 CFR 194.24( b)

c. Engineered barrier evaluation as required in 40 CFR 194.44.

2.3 CERTIFICATION PROJECT DOCUMENT CONTROL AND RECORDS MANAGEMENT This certification plan, which includes the compliance plan for CH TRAMPAC and associated QA plans, together with HNF 2599 establish the basis for the Hanford site's TRU waste characterization, certification, and transportation packaging operations. These documents are submitted to permittee for review and approval. The individuals identified in table 2 1 review and/ or approve this certification plan and any revisions. The SPM ( or designee) reviews this certification plan at least annually and schedules revisions, reviews, approvals, and distribution.

Table 2 1 Review, Approval, and Control Requirements for the Hanford Site Certification Plan Organization/ Reviewer Review and approval Change approval Change control Office Director, CBFO Office of Characterization and Transportation X Xa   Carlsbad Field Office Quality Assurance Manager X X   Site Project Manager X X Xb Site Quality Assurance Officer X X   Waste Certification Official X X   Transportation Certification Official X X   Note:   = not required. aChanges affecting performance criteria or data quality only. bEnsures compliance with records management requirements. HNF 2600, REV 15 Page 42 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Project personnel develop, maintain, and control this certification plan in accordance with WMP 400, Section 1.4.1, " TRU Document Control." Project personnel generate records of characterization, certification, packaging, and transportation activities and review these records to ensure compliance with project requirements. Records are collected, processed, stored, and maintained in accordance with records management requirements established in WMP 400, Section 1.5.1, " TRU Records Management."

3.0 COMPLIANCE PLAN FOR CH WAC This section describes how the Hanford site complies with the requirements and associated criteria for WIPP acceptance of CH TRU waste, including transportation safety requirements ( e. g., acceptable methods for payload compliance) defined in the TRUPACT II Certificates of Compliance, WIPP Hazardous Waste Facility Permit requirements for TRU mixed waste established in the WAP, and EPA environmental compliance requirements established in the 40 CFR 191/ 194, Compliance Certification Decision, the Initial Report for PCB Disposal Authorization, the letter of approval to land dispose non liquid PCBs at WIPP, the Revision to the Record of Decision for the DOE's WIPP Disposal Phase, and the Energy and Water Development Appropriations Act, the Contact handled Documented Safety Analysis.

CH WAC requirements are organized under five major categories: 1) container properties, 2) radiological properties, 3) physical properties, 4) chemical properties, and 5) data package contents.

Subsections 3.1 through 3.6 correlate with the organization in the CH WAC for CH TRU waste requirements and identify methods of compliance to meet each requirement. Procedures that implement the process controls, techniques, tests, and other actions to be applied to each TRU payload container, waste stream, and shipment are also identified. Appendix A summarizes the CH WAC and CH TRAMPAC requirements and identifies the Hanford site documents and procedures that implement each requirement. The numbering of CH WAC requirements in Appendix A correlates with the numbering system in the following subsections. Waste shipped to WIPP must comply with the most restrictive of the CH TRU requirements established in the CH WAC and CH TRAMPAC. Therefore, only the most restrictive requirements are described in this subsection. In addition, because many CH WAC and CH TRAMPAC. requirements overlap, this subsection refers to section 4.0 of this Certification Plan, where appropriate, for applicable methods of compliance and verification for both CH WAC and CH TRAMPAC requirements.

3.1 SUMMARY OF WIPP AUTHORIZATION BASIS Revisions of requirements in referenced documents controlled by agencies or organizations other than DOE ( e. g., EPA, NMED, NRC) shall have precedence over values quoted in this certification plan. Changes incorporated in future revisions of the CH WAC will be reflected in future revisions of this certification plan. Requests for exceptions ( variances) to requirements must be submitted formally to the permittee for approval. The permittee cannot approve HNF 2600, REV 15 Page 43 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN exceptions ( variances) to external requirements that are controlled by organizations other than DOE without first obtaining changes to the controlling authorizations.

Only waste that is preceded by an approved WSPF will be shipped to WIPP. Only payload containers from a properly characterized and approved waste stream can be certified as meeting the requirements and associated criteria in this certification plan. The Hanford site shall submit characterization, certification, and shipping data to WIPP using the WWIS before shipment of that waste. Any payload containers with unresolved discrepancies associated with hazardous waste characterization will not be managed or disposed at WIPP until the discrepancies are resolved in accordance with requirements established in the WAP. Corrective action reports applicable to WAP requirements shall be resolved before waste shipment. Throughout this subsection and the discussions of compliance and verification methods, it can be assumed, unless otherwise noted, that if a requirement is not met, project personnel will segregate the nonconforming item and initiate an NCR or CAR in accordance with WMP 400, Section 1.3.2, " TRU Nonconforming Item Reporting and Control," or WMP 400, Section 1.3.3, " TRU Corrective Action Reporting and Control." Corrective action will be taken in accordance with WMP 400, Section 1.3.1, " TRU Corrective Action Management," to resolve nonconformances. Also see subsection 5.3 of this certification plan for more details about the NCR/ CAR process.

3.1.1 DOE Operations and Safety Requirements for WIPP <IP_ADDRESS> Requirements The WIPP CH DSA addresses CH TRU waste handling and emplacement operations at the WIPP site. The waste accepted for emplacement in the WIPP must conform to the WIPP CH DSA and the associated technical safety requirements. The WIPP CH DSA documents the safety analyses that develop and evaluate the adequacy of the WIPP safety bases necessary to ensure the safety of workers, the public, and the environment from the hazards posed by WIPP waste receiving, handling, and emplacement operations. The WIPP CH DSA establishes and evaluates the adequacy of the safety bases in response to plant normal and abnormal operations and postulated accident conditions.

<IP_ADDRESS> Compliance and Verification CH waste sent to WIPP will be certified in accordance with the requirements of HNF 2599 ( Hanford Site Transuranic Waste Characterization Quality Assurance Project Plan and this Certification Plan. Thus, waste containers certified by Hanford will be compliant with the WIPP CH DSA and associated technical safety requirements.

3.1.2 NRC Transportation Safety Requirements for the TRUPACT II <IP_ADDRESS> Requirements Acceptable methods for payload compliance are defined in the TRUPACT II Certificates of Compliance ( C of C) and implemented by the CH TRAMPAC. For shipments to WIPP, a site specific CH TRAMPAC, Section 4.0 of this Certification Plan, will be prepared describing how it will ensure compliance with each payload parameter. This site specific CH TRAMPAC HNF 2600, REV 15 Page 44 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN shall contain sufficient detail to allow reviewers to adequately understand and evaluate the compliance methodology for each payload parameter.

A packaging QA program that defines the QA activities that apply to the use of NRC approved transportation packagings equivalent to 10 CFR Part 71, Subpart H, shall be prepared.

<IP_ADDRESS> Compliance and Verification CH waste sent to WIPP will be certified in accordance with HNF 2599 and HNF 2600 requirements. Section 4.0 of this Certification Plan outlines the site specific CH TRAMPAC requirements to meet NRC transportation safety requirements for use of the TRUPACT II shipping vessel. A site specific QA plan is outlined in section 5.0 of this Certification Plan, consistent with 10 CFR Part 71, Subpart H.

3.1.3 NMED Hazardous Waste Facility Permit Requirements <IP_ADDRESS> Requirements TRU waste is classified as TRU mixed waste if it contains hazardous constituents regulated under Resource Conservation and Recovery Act ( RCRA). Only TRU mixed waste and TRU waste that have been characterized in accordance with the WIPP WAP and meet the treatment, storage, and disposal facility ( TSDF) waste acceptance criteria as presented in permit conditions II. C. 3. a through II. C. 3. k of the WIPP Hazardous Waste Facility Permit will be accepted at the WIPP facility for disposal in the permitted underground hazardous waste disposal unit.

Before disposal, HNF 2599, addressing all the applicable requirements specified in the WIPPWAP shall be implemented. In accordance with attachment B5 of the WIPP WAP, HNF 2599 will include the qualitative or quantitative criteria for making a hazardous waste determination. HNF 2599 will be reviewed and approved by the CBFO.

<IP_ADDRESS> Compliance and Verification CH waste sent to WIPP will be certified in accordance with HNF 2599 and HNF 2600 requirements. HNF 2599 implements the applicable requirements in the WIPP WAP for mixed and non mixed TRU waste characterization activities and includes the qualitative and quantitative criteria for making hazardous waste determinations. HNF 2599 is approved by CBFO.

3.1.4 EPA Requirements <IP_ADDRESS> EPA Compliance Certification Decision Title 40 CFR Part 194.24( c) required that the DOE specifies the limiting values for waste components for acceptance to WIPP. The EPA's Compliance Certification Decision identified the repository limits for several waste components, including free water and metals, and cellulose, plastic, and rubber ( CPR). Although the Compliance Certification Decision did not specify limiting values for the activities and masses of specific radionuclides, it did identify the HNF 2600, REV 15 Page 45 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN listed values for a number of radionuclides that are considered in the performance assessment. To demonstrate that the cumulative total activities of the specified radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) are consistent with the levels used for the performance assessment and the compliance certification decision, reporting and tracking of the specified radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) are necessary, as required by the Compliance Certification Decision. TRU waste payload containers shall contain more than 100 nanocuries per gram of waste ( nCi/ g) of alpha emitting TRU isotopes with half lives greater than 20 years.

The WIPP limit for free water is a maximum of 1684 m3 and is met by the residual liquid criterion.

The limits for metals are a minimum of 2 × 107 kg for ferrous metals and 2 × 103 kg for nonferrous metals. These limits will be met in the total repository inventory by the metals that constitute the payload containers alone; thus, WIPP tracks the number and type of payload containers emplaced in the repository as reported in the WWIS by Hanford.

The WIPP limit for CPR is a maximum of 2 × 107 kg. The CPR weights must be estimated and reported in the WWIS on a payload container basis.

Ten specific radionuclides must be quantified and reported for masses and activity for the purpose of tracking the total radionuclide inventory at WIPP. The presence or absence of these specific radionuclides is determined from AK, radioassay, or both in accordance with Appendix E. The results of this determination are reported in the WWIS on a payload container basis.

<IP_ADDRESS> Compliance and Verification CH waste sent to WIPP will be certified in accordance with HNF 2599 and this Certification Plan. Subsection 3.3.1 and Appendix E of this Certification Plan outline the specific requirements and compliance activities related to radiological properties performed consistent with the CH WAC. HNF 2599 identifies compliance activities meeting the other EPA compliance certification requirements ( e. g., residual liquids, metals, CPR).

<IP_ADDRESS> EPA Approval for PCB Disposal TRU and TRU mixed wastes containing PCBs, including PCB remediation waste, PCB bulk product waste, etc. may be disposed of at the WIPP. Applicable waste acceptance criteria are addressed in subsections 3.2.5 ( Container Identification/ Labeling), 3.4.1 ( Residual Liquids), and 3.5.6 ( Polychlorinated Biphenyls) of the CH WAC.

<IP_ADDRESS> Compliance and Verification CH waste sent to WIPP will be certified in accordance with HNF 2599 and this Certification Plan. Subsections 3.2.5 ( Container Identification/ Labeling), 3.4.1 ( Residual Liquids), 3.5.6 ( Polychlorinated Biphenyls) outline the specific requirements and compliance activities related to PCBs consistent with the CH WAC. HNF 2600, REV 15 Page 46 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 3.1.5 Land Withdrawal Act Requirements <IP_ADDRESS> Requirements The term " WIPP" means the Waste Isolation Pilot Plant project authorized under Section 213 of the Department of Energy National Security and Military Applications of Nuclear Energy Authorization Act of 1980 ( Pub. L. 96 164; 93 Stat. 1259 1265) to demonstrate the safe disposal of radioactive waste materials generated by Atomic Energy defense activities. Hence, by law, WIPP can accept only radioactive waste generated by Atomic Energy defense activities of the United States.

The DOE and its predecessor agencies were engaged in a broad range of activities that fall under the heading of Atomic Energy defense activities. A TRU waste is eligible for disposal at WIPP if it has been generated in whole or in part by one or more of the following functions:

  Naval reactors development   Weapons activities, including defense inertial confinement fusion   Verification and control technology   Defense nuclear materials productions   Defense nuclear waste and materials by products management   Defense nuclear materials security and safeguards and security investigations   Defense research and development.

Using AK, DOE sites must determine that each waste stream to be disposed of at WIPP is " defense" TRU waste.

High level radioactive waste or spent nuclear fuel shall neither be transported, emplaced, nor disposed of at WIPP. Also, no TRU waste may be transported by or for the DOE to or from WIPP, except in packages ( 1) the design of which has been certified by the NRC, and ( 2) that have been determined by the NRC to satisfy its QA requirements.

<IP_ADDRESS> Compliance and Verification Only CH TRU defense waste characterized in accordance with the WIPP WAP, CH WAC, and consistent with HNF 2599 and this certification plan will be transported to WIPP for disposal. Each TRU waste stream is evaluated to determine whether the waste is designated defense. This determination is documented in the AK documentation as required by WMP 400, Section 7.1.9, " Acceptable Knowledge Documentation Management."

3.1.6 Energy and Water Development Appropriations Act ( Title III, General Provisions)

<IP_ADDRESS> Requirements The first sentence of the following language has appeared in various sections of Title III of the Energy and Water Development Appropriations Act for every fiscal year since 1999. HNF 2600, REV 15 Page 47 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN None of the funds in this Act may be used to dispose of transuranic waste in the Waste Isolation Pilot Project Plant which contains concentrations of plutonium in excess of 20 percent by weight for the aggregate of any material category on the date of enactment, or is generated after such date. For the purposes of this section, the material categories of transuranic waste at the Rocky Flats Environmental Technology Site include: ( 1) ash residues; ( 2) salt residues; ( 3) wet residues, ( 4) direct package residues; and ( 5) scrub alloy as referenced in the " Final Environmental Impact Statement on Management of Certain Plutonium Residues and Scrub Alloy Stored at the Rocky Flat Environmental Technology Site."

Note: The first sentence of the language above is the only portion of the section that applies to transuranic ( TRU) waste generator/ storage sites other than Rocky Flats.

The CBFO strongly encourages the TRU waste generator/ storage sites to work with DOE Headquarters General Counsel to obtain a determination of compliance with this language for high plutonium content material/ waste that is ultimately planned for disposal at the WIPP prior to initiating TRU waste characterization activities. Evidence used to support a determination of compliance as well as the compliance decision must be included in the waste stream AK documentation. This information must also be included in the AK summary accompanying waste stream profile forms submitted to the CBFO.

<IP_ADDRESS> Compliance and Verification The Hanford TRU Program will work with DOE Headquarters General Counsel to obtain a determination of compliance with this language for high plutonium content material/ waste that is ultimately planned for disposal at the WIPP, during the waste stream development process. Evidence used to support a determination of compliance as well as the compliance decision will be included in the waste stream AK documentation consistent with WMP 400, Section 7.1.9, Acceptable Knowledge Documentation Management. This information will be included in the AK summary accompanying waste stream profile forms submitted to the CBFO.

3.2 CONTAINER PROPERTIES CRITERIA AND REQUIREMENTS 3.2.1 Payload Container Description <IP_ADDRESS> Requirements Each CH TRU Payload Container shall be assigned to a payload shipping category. Authorized payload container types include the following:

  55 gallon drums   55 gallon drums ( containing a pipe overpack)   85 gallon drums ( the term " 85 gallon drum" includes 75 to 88 gallon drums)   standard waste boxes ( SWBs, either direct loaded, containing up to four 55 gallon drums, or containing one bin)   ten drum overpacks ( TDOPs, either direct loaded, containing up to ten 55 gallon drums, up to six 85 gallon drums, or one SWB) HNF 2600, REV 15 Page 48 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Payload containers shall meet U. S. Department of Transportation ( DOT) Specification 7A, Type A packaging requirements. Payload containers must be made of steel and be in good and unimpaired condition prior to shipment from the generator/ storage sites. To demonstrate compliance with the requirement that payload containers be in good and unimpaired condition, the exterior of all payload containers shall undergo 100% visual examination prior to loading into a TRUPACT II. The results of this visual examination shall be documented using the payload container integrity checklist in Appendix D of the CH WAC. A payload container in good and unimpaired condition consists of the following:

1. Does not have significant rusting,

2. Is of sound structural integrity, and 3. Does not leak.

Significant rusting is a readily observable loss of metal due to oxidation ( e. g., flaking, bubbling, or pitting) that causes degradation of the payload container's structural integrity. Rusting that causes discoloration of the payload container surface or consists of minor flaking is not considered significant. A payload container is not of sound structural integrity if it has breaches or significant denting/ deformation. Breaching is defined as a penetration in the payload container that exposes the internals of the container. Significant denting/ deformation is defined as damage to the payload container that results in creasing, cracking, or gouging of the metal, or damage that affects payload container closure. Dents or deformations that do not result in creasing, cracking, or gouging or affect payload container closure are not considered significant. Generator sites will report to the WWIS the number and types of payload containers planned for shipment to the WIPP.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.2.2 Container Weight and Center of Gravity <IP_ADDRESS> Requirements Each payload container, payload assembly, and loaded TRUPACT II shall comply with the weight limits shown in table 3.2 1 of this Certification Plan. Weight calculations for the payload assembly must include the measurement error in accordance with the CH TRAMPAC. For TRUPACT II payloads, the total weight of payload container( s) in the top layer of the payload assembly shall be less than or equal to the total weight of the payload container( s) in the bottom layer of the payload assembly. In the case of drums over packed in a TDOP, the total weight of the top layer of drums shall be less than or equal to the total weight of the bottom layer of drums. Calibrations of the scales used to make these weight determinations shall be in accordance with the National Institute of Standards and Technology ( NIST) Handbook 44 or an equivalent standard. HNF 2600, REV 15 Page 49 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table 3.2 1 Weight Limits Loaded Units Maximum Gross Weight ( lbs) Payload Containers 55 gallon drum   1000 55 gallon drum containing a six inch diameter pipe component ( i. e., a standard pipe overpack)   328 55 Gallon drum containing a twelve inchdiameter pipe component ( i. e., a standard pipe overpack)   547 55 gallon drum containing a neutron shielded six inch diameter pipe component ( i. e., an S100 pipe overpack)   550 55 gallon drum containing a gamma shielded twelve inch diameter pipe component ( i. e., an S200 pipe overpack)   547 85 gallon drum   1,000 SWB   4,000 TDOP   6,700 Payload Assemblies1 TRUPACT II payload assemblies including fourteen 55 gallon drums, fourteen pipe overpacks ( standard, S100, or S200), eight 85 gallon drums, two SWBs, or one TDOP   7,265 Packages/ Truck TRUPACT II   19, 250 Truck ( tractor/ trailer)   80,000 1Refer to section 3.2.3 of this document for an explanation of how payload assemblies are built.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.2.3 Assembly Configurations <IP_ADDRESS> Requirements Payload container assembly configurations authorized for shipment in the TRUPACT II shall be in accordance with table 3.2 2 below. HNF 2600, REV 15 Page 50 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table 3.2 2 TRUPACT II Payload Assembly Configurations Number of Payload Containers in Assembly1 Payload Container Configuration 14 55 gal. drums 14 55 gal. drums configured as, standard pipe overpacks2 14 55 gallon drums configured as S100 pipe overpacks 14 55 gallon drums configured as S200 pipe overpacks3 8 85 gallon drums4 2 SWBs 1 TDOP 1Payloads shall be comprised of a single payload container type. In the case of standard pipe overpacks assembled in a payload with 55 gallon drums, however, the standard pipe overpacks are considered 55 gallon drums and are subject to the applicable limits. 2Standard pipe overpacks must be assembled into seven packs of six inch standard pipe overpacks only or twelve inch standard pipe overpacks only. 3A mixture of S200 A and S 200 B pipe overpacks may be assembled into a single payload. 4Only the short 85 gallon drum is authorized for transport within the TRUPACT II as a payload container. A TRUPACT II payload may contain assembles of payload containers belonging to the same shipping category, equivalent shipping categories or different ( nonequivalent) shipping categories.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.2.4 Removable Surface Contamination ( Payload Containers)

<IP_ADDRESS> Requirements The removable surface contamination for each CH TRU waste payload container or payload container assembly must be measured and documented before shipment. Removable surface contamination on CH TRU waste payload containers, payload assemblies, and packagings shall not be greater than 20 disintegrations per minute ( dpm) per 100 cm2 for alpha emitting radionuclides or 200 dpm per 100 cm2 for beta gamma emitting radionuclides. Fixing surface contamination to meet the above criteria is not permitted. HNF 2600, REV 15 Page 51 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN <IP_ADDRESS> Compliance and Verification A Hanford site radiological control technician ( RCT) surveys TRU waste containers and container assemblies for removable surface contamination before the containers are loaded for shipment. The RCT assesses removable contamination and documents the results in accordance with WRP1 OP 1225, " Radiological Support of TRUPACT II Shipping and Receiving." If the RCT determines that removable contamination exceeds 20 dpm per 100 cm2 for alpha emitting radionuclides or 200 dpm per 100 cm2 for beta gamma emitting radionuclides, project personnel determine whether surface contamination can be removed to meet established limits. If compliance with removable surface contamination limits cannot be achieved, project personnel segregate and disposition noncompliant container( s) in accordance with nonconformance and corrective action procedures. The survey results are added to the container data package as described in WMP 400, Section 7.1.8, " Transuranic Waste Certification." The TCO and WCO confirm removable surface contamination survey results in accordance with WMP 400, Sections 2.1.5, TRU Waste Transportation Certification and Logistics and 7.1.8 respectively.

3.2.5 Container Identification/ Labeling <IP_ADDRESS> Requirements Each CH TRU waste payload container shipped in a TRUPACT II shall be uniquely identified by means of labels permanently attached in conspicuous locations. The labels shall contain a unique container identification number ( CIN) consisting of site and container information. The CIN shall be in medium to low density Code 39 bar code symbology ( per ANSI/ AIM BC1 1995) in characters at least 1 inch high, and alphanumeric characters at least 0.5 inches high. The bar code identification labels shall be placed at three locations about 120 degrees apart so that at least one label is clearly visible when drums are assembled into a payload ( e. g., a label must be visible after slip sheets and wrapping are applied). Labels are required on the flat sides of SWBs. For TDOPs, a minimum of one bar code is required. Containers shall be marked in accordance with 10 CFR Part 835 and/ or 40 CFR § 262.32, as applicable. See subsection 3.2.6 of this Certification Plan for dunnage container labeling requirements.

Payload containers shall be marked " Caution Radioactive Material" with the yellow and magenta label, consistent with 10 CFR Part 835. Those payload containers that are RCRA regulated will have the hazardous waste label affixed in accordance with 40 CFR § 262.32. For TRU and TRU mixed wastes containing PCBs, the payload containers shall be marked in accordance with 40 CFR § 761.40. Additionally, DOT Type B packages ( i. e., the TRUPACT II) containing PCBs must be properly marked in accordance with 40 CFR § 761.40.

If an empty 55 or 85 gallon, drum is used as dunnage to complete a payload configuration, the dunnage container shall be labeled with the following information:

  Unique payload container identification number   " EMPTY" or " DUNNAGE" HNF 2600, REV 15 Page 52 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN If a seven pack of only dunnage 55 gallon drums, a four pack of only dunnage 85 gallon drums, or a dunnage SWB is used in the TRUPACT II, the containers( s) shall be labeled only " EMPTY" or " DUNNAGE" and the unique container identification number label is not required for these containers.

<IP_ADDRESS> Compliance and Verification Waste containers currently in the Central Waste Complex ( CWC) have a permanent bar code label containing a unique identification number. Generators procure waste containers with bar code labels affixed in accordance with the Hanford site's container management program. Before loading containers in the TRUPACT II, WIPP bar code labels are added in three locations to each drum such that each bar code label is approximately 120 degrees apart around the drum. For SWBs, labels are required on flat sides. One label is required per TDOP.

After verifying all payload parameters, project personnel mark each container with the appropriate site and container information). The TCO verifies compliance with container marking requirements by visually inspecting all TRU waste containers and their labels and comparing them to the container data package before shipment, in accordance with WMP 400, Section 2.1.5. The TCO verifies the container marking as described in WMP 400, Section 2.1.5.

3.2.6 Dunnage <IP_ADDRESS> Requirements If too few loaded payload containers meeting all payload container and transportation requirements are available, dunnage must complete one of the configurations specified in table 3.2 2. Empty 55 gallon drums, 85 gallon drums, or an empty SWB may be used as dunnage, as specified in section 3.2.5 of the CH WAC and section 2.9 of the CH TRAMPAC, with the exception that dunnage containers shall have at least one open vent port ( i. e., not filtered or plugged). If an empty 55 or 85 gallon, drum is used as dunnage to complete a payload configuration in a shipment to WIPP, the dunnage container shall contain a unique payload container identification number, be labeled " EMPTY" or " DUNNAGE" and have a container marking in accordance with subsection 3.2.5 of this certification plan, as appropriate. . If a seven pack of only dunnage 55 gallon drums, a four pack of only dunnage 85 gallon drums, or a dunnage SWB is used in the TRUPACT II, the container( s) shall be labeled only " empty" or " dunnage" and the unique identification number label is not required for these containers. The use of dunnage should be minimized. The use of dunnage is reviewed and approved concurrently with the review and approval of shipment assemblies by the WWIS data administrator on a case by case basis.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>. HNF 2600, REV 15 Page 53 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 3.2.7 Filter Vents <IP_ADDRESS> Requirements Payload containers that have been stored in an unvented condition ( i. e., no filter and/ or unpunctured liner) shall be aspirated for a specific length of time as described in the CH TRAMPAC to ensure equilibration of any gases that may have accumulated in the closed payload container.

Each payload container shall have one or more filter vents that meet the specifications of Section 2.5 of the CH TRAMPAC and Attachment B1 of the WIPP Hazardous Waste Facility Permit. The model number of each filter vent or combination of filter vents installed on a payload container shall be reported to the WWIS. A listing of available CBFO filter vent models is provided on the CBFO web page ( http:// www. wipp. ws/ transport. htm). This Internet link is provided for informational purposes only and may change.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.3 RADIOLOGICAL PROPERTIES CRITERIA AND REQUIREMENTS 3.3.1 Radiological Properties With respect to the required radiological properties identified within this section, they can be divided into two distinct groups.

The first group includes the activities and masses of the ten WIPP tracked radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) and the TRU alpha activity concentrations ( i. e., > 100 nCi/ g of alpha emitting TRU isotopes with half lives greater than 20 years) of the waste. This set of radiological properties is regulated by the EPA in accordance with 40 CFR Parts 191 and 194. Estimates of their activities and masses shall be derived from a system of controls certified by CBFO that includes AK, computations, measurements, sampling, etc. Appendix A of the CH WAC provides the methods and requirements by which to characterize the radiological composition of the CH TRU waste utilizing radioassay techniques.

The second group includes the remaining radionuclides contributing to the 239Pu fissile gram equivalent ( FGE), the 239Pu equivalent curies ( PE Ci), and the decay heat of the payload container. This set of radiological data is regulated both by the NRC as specified in the CH TRAMPAC and the CBFO as required by the WIPP Technical Safety Requirements. PE Ci quantities shall be calculated for each payload container in accordance with Appendix B of the CH WAC. Any CH TRAMPAC compliant method may be used to quantify the remaining radiological properties. However, the resulting data ( e. g., AK from Safeguards and Security data), the source/ method from which the data was generated, and the basis for the reliability of the data shall be submitted to and approved by CBFO prior to use. HNF 2600, REV 15 Page 54 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 3.3.2 Radionuclide Composition <IP_ADDRESS> Requirements The activities and masses of 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs shall be established on a payload container basis for purposes of tracking their contributions to the total WIPP radionuclide inventory. The estimated activities and masses, including their associated total measurement uncertainties ( TMU) expressed in terms of one standard deviation, for these ten radionuclides shall be reported to the WWIS on a payload container basis. For any of these ten radionuclides whose presence can be substantiated from AK, direct measurement, computations, or a combination thereof, and whose measured data are determined to be below the lower limit of detection ( LLD) for that radionuclide, the site shall report the character string "< LLD" to the WWIS for the activity and mass of that radionuclide; otherwise a value of zero shall be reported. Quantitative estimates for LLD shall not be used when calculating related radiological properties of the waste such as TRU alpha activity concentration, 239Pu fissile gram equivalent, decay heat, etc. Section A. 3, item 1, of the CH WAC has information pertaining to the development and application of LLD.

In addition to the ten WIPP tracked radionuclides, the activity of other radionuclides contributing to the 239Pu fissile gram equivalent ( FGE), the 239Pu equivalent curies ( PE Ci), or decay heat of the payload container that are used to determine ( e. g., correlate or scale) the activity of one of the ten WIPP tracked isotopes or otherwise contributes to at least 95 percent of the total radiological hazard must also be determined in order to meet the CH TRAMPAC, DOT, and/ or NRC requirements. PE Ci shall be determined in accordance with Appendix E of this Certification Plan, and any CH TRAMPAC compliant method may be used to determine the other radiological properties. Appendix E of this Certification Plan provides radioassay requirements by which to characterize the waste. However, the resulting data ( e. g., AK from Safeguards and Security data), the source/ method from which the data was generated, and the basis for the reliability of the data shall be submitted to and approved by CBFO before use. These other isotopes shall be reported on the TRUPACT II bill of lading ( BOL) or manifest in accordance with 49 CFR § 172.203 and 49 CFR § 173.433. The activities and masses of these other radioisotopes shall also be reported to the WWIS along with their associated TMU, expressed in terms of one standard deviation for each waste container.

<IP_ADDRESS> Compliance and Verification Nondestructive assay ( NDA) personnel perform measurements of each TRU waste container using calorimetry, gamma energy assay ( GEA), imaging passive/ active neutron ( IPAN), or passive neutron ( e. g., SuperHENC) systems to determine the radioactive material composition and quantify radionuclide masses. The requirements for NDA are presented in Appendix E of this certification plan, and the equipment and procedures are approved by CBFO.

NDA personnel at the Waste Receiving and Processing ( WRAP) facility follow NDA procedures described in WRP1 OP 0906, " Gamma Energy Assay Operations," WRP1 OP 0905, " Imaging Passive/ Active Neutron Assay Operations," WRP1 OP 0907, " Gamma Energy Assay Operations Using NDA2000," or TRU OP 002, " Operation of the SuperHENC Assay Systems." NDA HNF 2600, REV 15 Page 55 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN personnel at WRAP quantify radionuclide values in accordance with WMP 350, Waste Receiving and Processing Facility, Section 2.2, " Calculation of Assay Results." NDA personnel at WRAP use acceptable knowledge ( AK) data and assay measurements and calculations to establish an isotopic profile of each waste container, which is reported in batch data reports in accordance with WMP 350, Section 2.3, " Data Management," and Section 2.8, " WRAP NDA Measurement Control Program."

NDA personnel at the Plutonium Finishing Plant ( PFP) follow one of two NDA procedures listed below:

  ZA 948 392, " NDA Using NDA 2000" or   ZA 948 393, " NDA Using the Room 172 ANTECH Calorimeters"

NDA personnel at PFP calibrate the various assay systems in accordance with one of the two procedures listed below:

  ZA 400 303, " Energy and Efficiency Setup and Baseline Determination Using NDA 2000" or   ZA 400 304, " ANTECH Calorimeter Calibration"

NDA personnel at PFP quantitate radionuclide values in accordance with ZA 400 302, " Calculation of Assay Results." NDA personnel at PFP use AK data and assay measurements and calculations to create an isotopic profile of each waste container, which is reported in batch data reports in accordance with FSP PFP 5 8, Plutonium Finishing Plant Administration, Section 16.2, " Data Management."

The WCO reports NDA data to WWIS and appropriate container certifications in accordance with WMP 400, Sections 7.1.5 and 7.1.8. The TCO reports NDA data to shipping documents in accordance with WMP 400, Section2.1.5.

3.3.3 Fissile Material Quantity ( 239Pu Fissile Gram Equivalents [ FGE])

<IP_ADDRESS> Requirements For each payload container and loaded TRUPACT II, the sum of 239Pu FGE plus two times its associated TMU, expressed in terms of one standard deviation, shall comply with the limits in either table 3.3 1 or table 3.3 2 as applicable. The values calculated for 239Pu FGE and its associated TMU ( expressed in terms of one standard deviation) shall be reported to the WWIS for each payload container. HNF 2600, REV 15 Page 56 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table 3.3 1 239Pu FGE Limits for Payload Containers Payload Containers Beryllium Mass Limit1 239Pu FGE Limit2 Applicable to Non Machine Compacted Waste 55 ( excluding pipe overpacks) and 85 gallon drums   1% by weight of the waste   200 55 gallon drum configured as a pipe overpack ( i. e., a standard S100 or S200 pipe overpack   5 kg   200 SWB   1% by weight of the waste up to 18.14 kg and is particulate3   325 TDOP   1% by weight of the waste up to 18.14 kg and is particulate3   325 55 ( excluding pipe overpacks) and 85 gallon drums > 1% by weight of the waste up to 100 kg   100 SWB > 1% by weight of the waste up to 18.14 kg and is particulate3   100 TDOP > 1% by weight of the waste up to 18.14 kg and is particulate3   100 Machine Compacted Waste Not Implemented at Hanford 1Beryllium includes both the metal ( Be) and its oxide ( BeO). 2The FGE limit given applies to the payload container regardless of 240Pu content in the package. 3Particulate beryllium includes fines or shavings. HNF 2600, REV 15 Page 57 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table 3.3 2 239Pu FGE Limits for Packages Payload Packages 239Pu FGE Limit ( No Credit for 240Pu Poisoning) 239Pu FGE Limit ( Credit for 240Pu Poisoning1)

Applicable to Beryllium2 Mass   1% by Weight of the Waste and Non Machine Compacted Waste 5 g 240Pu   340 15 g 240Pu   360 TRUPACT II ( containing either 14 55 gallon drums, 8 85 gallon drums, 2 SWBs, or 1 TDOP3)   325 25 g 240Pu   380 TRUPACT II ( containing either 14 standard pipe overpacks, 14 S100 pipe overpacks, or 14 S200 pipe overpacks)   2800 Unauthorized HalfPACT ( Not implemented at Hanford) Applicable to Beryllium2 Mass > 1% by Weight of the Waste and Non Machine Compacted Waste TRUPACT II ( containing either 14 55 gallon drums, 8 85 gallon drums, 2 SWBs, or 1 TDOP)   100 Unauthorized HalfPACT ( Not implemented at Hanford) Applicable to Beryllium2 Mass   1% by Weight of the Waste and Machine Compacted Waste4 Not Implemented at Hanford Applicable to Beryllium2 Mass > 1% by Weight of the Waste and Machine Compacted Waste4 Unauthorized 1The numbers 0, 5, 15, and 25 represent the minimum 240Pu content of the payload expressed in grams that must be exceeded to take credit for the higher FGE loading limit. The minimum 240Pu content for the payload shall be determined after subtraction of two times the error. 2Beryllium includes both the metal ( Be) and its oxide ( BeO). 3The TDOP cannot take credit for 240Pu poisoning. 4See Table 4.4 1, Summary of FGE Limits. HNF 2600, REV 15 Page 58 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN <IP_ADDRESS> Compliance and Verification See Subsection <IP_ADDRESS> of this Certification Plan.

3.3.4 TRU Alpha Activity Concentration <IP_ADDRESS> Requirements TRU waste payload containers shall contain more than 100 nCi/ g of alpha emitting TRU isotopes with half lives greater than 20 years. Without taking into consideration the TMU, the TRU alpha activity concentration for a payload container is determined by dividing the TRU alpha activity of the waste by the weight of the waste. The weight of the waste is the weight of the material placed into the payload container ( i. e., the net weight of the container). The weight of the waste is typically determined by subtracting the tare weight of the payload container ( including the weight of the rigid liner and any shielding external from the waste, if applicable) from the gross weight of the payload container. In the event waste containers ( e. g., 55 gallon drums) that have been radioassayed are overpacked in a payload container ( e. g., in an SWB), sites shall sum the individual TRU alpha activity values of the individual waste containers and divide by the sum of the individual net waste weights ( i. e., less container, shielding, and liner weights as appropriate) to determine the activity per gram for the payload container. Waste containers selected for payload management shall comply with the policy for the management of TRU alpha activity concentrations. Loading a 55 gallon pipe overpack with cans is considered direct loading   not overpacking for the purposes of calculating the weight of the container. The TRU alpha activity concentration shall be reporting to the WWIS; however, there are no reporting requirements for its associated TMU.

<IP_ADDRESS> Compliance and Verification NDA personnel measure TRU alpha activity concentration in accordance with the NDA process described in Appendix E. Assay data are validated and verified at WRAP in accordance with WMP 350, Section 2.3, or at PFP in accordance with FSP PFP 5 8, Section 16.2, and submitted in batch data reports to the site project office ( SPO). The WCO confirms TRU alpha activity in accordance with WMP 400, Section 7.1.8, and reports it to WWIS in accordance with WMP 400, Section 7.1.5. ( There are no reporting requirements for the TRU alpha activity TMU.) Project personnel manage waste containers with TRU alpha activity concentrations that do not exceed 100 nCi/ g as low level waste.

Hanford is not implementing payload management.

3.3.5 239Pu Equivalent Activity ( PE Ci)

<IP_ADDRESS> Requirements 239Pu equivalent curie ( PE Ci) quantities shall be calculated in accordance with Appendix E for each payload container. Assay methods will be approved by CBFO before use. In accordance with the limits stated in Table 3.3 3, PE Ci quantities shall be limited to the following for each payload container. HNF 2600, REV 15 Page 59 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table 3.3 3 PE Ci Limits Waste Container Packing Configuration PE Ci Limit Direct load   all approved waste forms   80 Direct load   solidified/ vitrified waste only   1,800 Overpacked into an 85 gal. drum, SWB, or TDOP   all approved waste forms   1,100 55 gal. drum in good condition Overpacked into an 85 gal. drum, SWB, or TDOP   solidified/ vitrified waste only   1,800 Overpacked into an 85 gal. drum, SWB, or TDOP   all approved waste forms   80,   130,   130 respectively 55 gal. drum in damaged condition Overpacked into an 85 gal. drum, SWB, or TDOP   solidified/ vitrified waste only   1,800 55 gal. pipe overpack in good condition Direct load   all approved waste forms   1,800 Direct load   all approved waste forms   80 Direct load   solidified/ vitrified waste only   1,800 Overpacked into a TDOP   all approved waste forms   1,100 85 gal. drum in good condition Overpacked into a TDOP   solidified/ vitrified waste only   1,800 Overpacked into a TDOP   all approved waste forms   130 85 gal. drum in damaged condition Overpacked into a TDOP   solidified/ vitrified waste only   1,800 Direct load ( or a bin)   all approved waste forms   130 Direct load ( or a bin)   solidified/ vitrified waste only   1,800 Overpacked into a TDOP   all approved waste forms   1,100 SWB in good condition Overpacked into a TDOP   solidified/ vitrified waste only   1,800 Overpacked into a TDOP   all approved waste forms   130 SWB in damaged condition Overpacked into a TDOP   solidified/ vitrified waste only   1,800 Direct load   all approved waste forms   130 TDOP in good condition Direct load   solidified/ vitrified waste only   1,800 PE Ci quantities shall be reported to WIPP using WWIS. There are no TMU reporting requirements. HNF 2600, REV 15 Page 60 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN <IP_ADDRESS> Compliance and Verification NDA personnel calculate the activity of the CH TRU waste container as PE Ci according to the methodology in Appendix E and report this to WIPP using WWIS. Project personnel identify payload containers exceeding limits stated in table 3.3 3, segregate them, and disposition them in accordance with approved nonconformance and corrective action management. The WCO verifies compliance of the PE Ci limits in accordance with WMP 400, Section 7.1.8. PE Ci quantity will be reported in WWIS consistent with WMP 400, Section 7.1.5. ( There are no reporting requirements for PE Ci TMU.)

3.3.6 Radiation Dose Rate <IP_ADDRESS> Requirements The external radiation dose equivalent rate of individual payload containers shall be limited to   200 mrem/ hr at contact with the exception of the S100 pipe overpacks which are limited to   179 mrem/ h at contact. The external radiation dose equivalent rate of the TRUPACT II shall be   200 mrem/ h at contact and   10 mrem/ hr at 2 meters, as specified in 3.3.5 of the CH WAC. Internal payload container shielding shall not be used to meet these requirements, except for authorized shielded payload container configurations such as the use of 55 gallon drums containing a pipe component. In addition, S100 and S200 pipe overpacks shall meet the curie limits in section 3.3 of the CH TRAMPAC. Total dose rate, including neutron contributions shall be reported for each payload container in the WWIS.

<IP_ADDRESS> Compliance and Verification For dose rate measurement, see subsection <IP_ADDRESS>. These measurements will be reported to WIPP using WWIS consistent with WMP 400, Section 7.1.5.

3.3.7 Decay Heat <IP_ADDRESS> Requirements The decay heat for each payload container plus its TMU shall be less than or equal to the limit of the assigned shipping category specified in Section 5.2.3 of the CH TRAMPAC.

For all other approved Content Codes to be shipped in payload containers that exceed the decay heat limit of the assigned shipping category, a determination of compliance with the flammable ( gas/ VOC) limit as specified in the CH TRAMPAC allows the payload container to be shipped in the TRUPACT II package, respectively, under test category ( also refer to section 3.5.5 in the CH WAC). The values calculated for decay heat and its associated TMU ( expressed in terms of one standard deviation) shall be reported to the WWIS for each payload container. The total decay heat from all payload containers shall be less than 40 watts in a TRUPACT II.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>. HNF 2600, REV 15 Page 61 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 3.4 PHYSICAL PROPERTIES CRITERIA AND REQUIREMENTS 3.4.1 Residual Liquids <IP_ADDRESS> Requirements Liquid waste is prohibited at WIPP. Residual liquids containing PCBs are prohibited at WIPP. CH TRU waste shall contain as little residual liquid as is reasonably achievable by pouring, pumping, and/ or aspirating. Internal containers ( e. g., bottles, cans) shall contain less than 1 inch ( 2.5 cm) of liquid in the bottom of the container. The aggregate volume of residual liquid in a payload container shall be less than 1 percent by volume of the container. For sites that choose to use VE in lieu of NDE, the detection of any liquid waste in nontransparent inner containers, detected from shaking the container, will be handled by assuming that the container is filled with liquid and adding this volume to the total liquid volume for the payload container.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.4.2 Sealed Containers <IP_ADDRESS> Requirements Sealed containers that are greater than 4 liters ( nominal) are prohibited except for Waste Material Type II. 2 packaged in a metal container. All waste containers with unvented rigid containers greater than 4 liters ( exclusive of rigid poly liners) shall be subject to innermost layer of containment sampling or shall be vented prior to initiating drum age and equilibrium criteria. To satisfy both of these requirements, payload containers shall be verified to be free of sealed containers greater than 4 liters.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.5 CHEMICAL PROPERTIES CRITERIA AND REQUIREMENTS 3.5.1 Pyrophoric Materials <IP_ADDRESS> Requirements Pyrophoric radioactive materials shall be present only in small residual amounts ( less than 1 percent by weight) in payload containers and shall be generally dispersed in the waste. Radioactive pyrophorics in concentrations equal to or greater than 1 percent by weight and all nonradioactive pyrophorics shall be reacted ( or oxidized) and/ or otherwise rendered nonreactive before placement in the payload container. Nonradionuclide pyrophoric materials are not acceptable at WIPP. HNF 2600, REV 15 Page 62 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN <IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.5.2 Hazardous Waste <IP_ADDRESS> Requirements Hazardous wastes not occurring as co contaminants with TRU wastes ( non mixed hazardous wastes) are not acceptable at WIPP. Each CH TRU mixed waste container shall be assigned one or more hazardous waste codes as appropriate. Only EPA hazardous waste codes listed as allowable in the Hazardous Waste Facility Permit may be managed at WIPP. Some of the waste may also be identified by unique state hazardous codes. These wastes are acceptable at WIPP as long as the Treatment, Storage, and Disposal Facility waste acceptance criteria are met. Wastes exhibiting the characteristic of ignitability, corrosivity, or reactivity ( EPA hazardous waste numbers of D001, D002, or D003) are not acceptable at WIPP. In the context of the CH WAC, hazardous waste codes are synonymous with hazardous waste numbers.

<IP_ADDRESS> Compliance and Verification Project personnel review AK information and implement one or more of the procedures identified in Appendix A to characterize waste streams through headspace gas sampling and analysis ( on all waste containers) and homogeneous waste sampling and analysis ( for nondebris waste streams). For homogeneous waste streams, toxicity characteristic and spent solvent EPA hazardous waste numbers are assigned based upon the analytical results and AK. For debris waste, EPA hazardous waste numbers are assigned based on AK. Toxicity characteristic ( TC) and spent solvent EPA hazardous waste numbers are assigned to debris waste streams based on headspace gas sampling and analytical results if AK indicates the waste might contain a constituent in excess of the regulatory level. If data are insufficient to demonstrate that the concentration of the constituent is less than the regulatory level, the EPA hazardous waste number for the identified constituent is applied to the waste stream. The SPM ( or designee) reviews the analytical data to ensure that chemical constituents in the waste are allowable ( section 3.5.2 of the CH WAC). At the discretion of the SPM, additional sampling of the waste stream from which any nonconforming container originated may be performed to determine whether the container is anomalous or is representative of the entire waste stream.

Project personnel identify hazardous constituents in CH TRU wastes and record the data in accordance with applicable data management procedures. The WCO verifies that data are entered in the WWIS. The TCO ensures the uniform hazardous waste manifest ( UHWM) reflects the hazardous waste codes as described in WMP 400, Section 2.1.5, The TCO and WCO confirm the hazardous waste criteria in accordance with WMP 400, Sections 2.1.5 and 7.1.8 respectively. HNF 2600, REV 15 Page 63 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 3.5.3 Chemical Compatibility <IP_ADDRESS> Requirements CH TRU mixed waste must not contain chemicals that would cause adverse reactions with other payload containers during handling or disposal. The CH TRU mixed waste must be compatible with backfill, seal, and panel closure materials at the WIPP facility; container and packaging material; and other waste. Only wastes that have been shown to meet the requirements consistent with section 3.5.3 of the CH WAC are acceptable at WIPP.

Other chemicals or materials not consistent with the chemicals listed in the CH TRAMPAC, Tables 4.3 1 through 4.3 8, as applicable. Other chemicals or materials not identified in these tables are allowed provided that they meet the requirements as specified in Section 4.3.1 of the CH TRAMPAC.

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.5.4 Explosives, Corrosives, and Compressed Gases <IP_ADDRESS> Requirements Waste shall contain no explosives, corrosives, or compressed gases ( pressurized containers).

<IP_ADDRESS> Compliance and Verification See subsection <IP_ADDRESS>.

3.5.5 Headspace Gas VOC Concentrations <IP_ADDRESS> Requirements The headspace gas of payload containers shall be sampled and analyzed in accordance with HNF 2599, as defined in the WIPP WAP, to determine volatile organic compound ( VOC) concentrations.

Flammable VOCs are restricted to equal to or less than 500 ppm in the payload container headspace. For those payload containers that exceed the flammable VOC limit, a determination of compliance with the flammable ( gas/ VOC) concentration limit as described in the CHTRAMPAC allows the payload container to be shipped under the test category.

Test category payload containers shall be tested to determine if all applicable limits are met for hydrogen/ methane, VOC, and total gas generation rates ( as appropriate) HNF 2600, REV 15 Page 64 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN <IP_ADDRESS> . Compliance and Verification Headspace gas sampling of payload containers shall be sampled and analyzed in accordance with HNF 2599. Hydrogen/ methane sampling of payload containers shall be done in accordance with Appendix F and site procedure LA 523 426, Determination of Permanent Gases in TRU Waste Container Headspace. Evaluation of results is done in accordance with subsection 4.6.2 of this Certification Plan.