PAGE 1

Rocky Flats

Environmental Technology Site

95-QAPjP-0050

Version 9

ROCKY FLATS ENVIRONMENTAL TECHNOLOGY SITE TRU WASTE CHARACTERIZATION
PROGRAM QUALITY ASSURANCE PROJECT PLAN

Responsible K-H Organization:  TRU Waste Programs			Effective Date:
  02/11/2004

Approved By:  RFETS TWCP Site Project Manager 		/		2/5/04

		Title	Date

           G.A. O’Leary				/		/S/

Print Name							Approval Signature

Review/concurrence documentation is contained in the Document History
File.

IMPORTANT NOTES

ISR review not required.	This plan supersedes 95-QAPjP-0050, Version 8.

SES/USQD review not required.	Periodic Review Frequency:  1 year from
effective date.

		Exempt from Classification Review

	Exemption Number: CEX-032-00

This page is intentionally blank

APPROVALS

The approvals listed below apply to Version 9 of this document.

Approved by:

Kerry W. Watson   /S/			2/3/04

CBFO Assistant Manager, National TRU Program (Kerry W. Watson)	Date

Martin P. Navarette for A. L. Holland   /S/			2/2/04

CBFO Quality Assurance Manager (Ava Holland)	Date

Lam Xuan   /S/			1/28/04

DOE Rocky Flats Field Office (Lam Xuan)	Date

G. A. O’Leary   /S/			1/28/04

RFETS TWCP Site Project Manager (G.A. O’Leary)	Date

C. L. Ferrera   /S/			1/28/04

RFETS TWCP Site Project Quality Assurance Officer (C.L. Ferrera)	Date

This page is intentionally blank

TABLE OF CONTENTS

Section	Page

	TITLE PAGE	1

	APPROVALS	3

	TABLE OF CONTENTS	5

	Version change summary	14

Chapter 	Page

  TOC \o \t "LEVEL 1,1,LEVEL 2,2,LEVEL 3,3,LEVEL 4,4"

A.	Introduction	  PAGEREF _Toc43090703 \h  17

A-1	Scope		  PAGEREF _Toc43090704 \h  17

A-2	Overview	  PAGEREF _Toc43090705 \h  17

A-3	Description of RFETS	  PAGEREF _Toc43090706 \h  18

A-4	Project Description	  PAGEREF _Toc43090707 \h  19

A-5	RFETS Organization and Responsibilities	  PAGEREF _Toc43090708 \h
21

A-5a	TWCP Site PM	  PAGEREF _Toc43090709 \h  21

A-5a(1)	Project Data Control Officer (PDCO)	  PAGEREF _Toc43090710 \h
23

A-5a(2)	Headspace Analytical Services	  PAGEREF _Toc43090711 \h  24

A-5b	TWCP Site PQAO	  PAGEREF _Toc43090712 \h  25

A-5c	Technical Operations	  PAGEREF _Toc43090713 \h  26

A-5c(1)	Waste Systems	  PAGEREF _Toc43090714 \h  26

A-5c(2)	Waste Requirements Group	  PAGEREF _Toc43090715 \h  27

A-5d	Waste Operations	  PAGEREF _Toc43090716 \h  27

A-5d(1)	Nondestructive Testing (NDT)	  PAGEREF _Toc43090717 \h  28

A-5e	TRU Waste Certification Official (WCO)	  PAGEREF _Toc43090718 \h
29

A-5f	Material Stewardship QA Manager	  PAGEREF _Toc43090719 \h  30

A-5f(1)	Headspace Analytical Services Quality Assurance Officer (HASQAO)
  PAGEREF _Toc43090720 \h  30

A-5g	Remediation, Industrial D&D, and Site Services (RISS)	  PAGEREF
_Toc43090721 \h  31

A-5g(1)	Analytical Laboratories Manager	  PAGEREF _Toc43090722 \h  31

A-5g(2)	Analytical Laboratories Project Quality Assurance Officer
(LPQAO)	  PAGEREF _Toc43090723 \h  32

A-5h	Building Closure Projects	  PAGEREF _Toc43090724 \h  33

A-5h(1)	Waste Generators	  PAGEREF _Toc43090725 \h  33

A-5i	INEEL TWCP Responsibilities	  PAGEREF _Toc43090726 \h  33

A-6	Hierarchy of Documents	  PAGEREF _Toc43090727 \h  34

A-7	Indoctrination and Training	  PAGEREF _Toc43090728 \h  34

B.	WASTE ANALYSIS PLAN	  PAGEREF _Toc43090729 \h  37

B-1	Identification of TRU Waste to be Managed at the WIPP Facility
PAGEREF _Toc43090730 \h  39

B-1a	Waste Stream Identification	  PAGEREF _Toc43090731 \h  39

B-1b	Waste Summary Category Groups and Hazardous Waste Accepted at the
WIPP Facility	  PAGEREF _Toc43090732 \h  39

B-1c	Waste Prohibited at the WIPP Facility	  PAGEREF _Toc43090733 \h  39

B-1d	Control of Waste Acceptance	42

B-1e	Waste Generating Processes at the WIPP Facility (termed “derived
waste”)	  PAGEREF _Toc43090734 \h  42

B-2	Waste Parameters	  PAGEREF _Toc43090735 \h  42

B-3	Characterization Methods	  PAGEREF _Toc43090736 \h  43

B-3a	Sampling and Analytical Methods	  PAGEREF _Toc43090737 \h  43

B-3a(1)	Headspace Gas Sampling and Analysis	  PAGEREF _Toc43090738 \h
43

B-3a(2)	Homogeneous Waste Sampling and Analysis	  PAGEREF _Toc43090739
\h  45

B-3a(3)	Laboratory Qualification	  PAGEREF _Toc43090740 \h  45

B-3b	Acceptable Knowledge	46

B-3c	Radiography and Visual Examination	  PAGEREF _Toc43090741 \h  46

B-3d	Characterization Techniques and Frequency for Newly Generated and
Retrievably Stored Waste	  PAGEREF _Toc43090742 \h  48

B-3d(1)	Newly Generated Waste	  PAGEREF _Toc43090743 \h  50

B-3d(2)	Retrievably Stored Waste	  PAGEREF _Toc43090744 \h  52

TABLE OF CONTENTS (continued)

Chapter	Page

B-4	Data Verification and Quality Assurance	  PAGEREF _Toc43090745 \h
54

B-4a	Data Generation and Project Level Verification Requirements
PAGEREF _Toc43090746 \h  54

B-4a(1)	Data Quality Objectives	  PAGEREF _Toc43090747 \h  54

B-4a(2)	Quality Assurance Objectives	  PAGEREF _Toc43090748 \h  55

B-4a(3)	Sample Control	  PAGEREF _Toc43090749 \h  55

B-4a(4)	Data Generation	  PAGEREF _Toc43090750 \h  56

B-4a(5)	Data Verification	  PAGEREF _Toc43090751 \h  56

B-4a(6)	Data Transmittal	  PAGEREF _Toc43090752 \h  56

B-4a(7)	Records Management	  PAGEREF _Toc43090753 \h  57

B-4b	WIPP Facility Level: Waste Screening and Verification of TRU Waste
 PAGEREF _Toc43090754 \h  58

B-4b(1)	Phase I Waste Stream Screening and Verification	  PAGEREF
_Toc43090755 \h  58

B-4b(2)	Phase II Waste Shipment Screening and Verification	  PAGEREF
_Toc43090756 \h  59

B1.	WASTE CHARACTERIZATION SAMPLING METHODS	  PAGEREF _Toc43090757 \h
79

B1-1	Headspace Gas Sampling	  PAGEREF _Toc43090758 \h  79

B1-1a	Method Requirements	  PAGEREF _Toc43090759 \h  79

B1-1a(1)	Summary Category S5000 Requirements	  PAGEREF _Toc43090760 \h
79

B1-1a(2)	Summary Category S3000/S4000 Requirements	  PAGEREF
_Toc43090761 \h  80

B1-1a(3)	General Requirements	  PAGEREF _Toc43090762 \h  81

B1-1a(4)	Manifold Headspace Gas Sampling	  PAGEREF _Toc43090763 \h  85

B1-1a(5)	Direct Canister	  PAGEREF _Toc43090764 \h  87

B1-1a(6)	Sampling Heads	  PAGEREF _Toc43090765 \h  88

B1-1b	Quality Control	  PAGEREF _Toc43090766 \h  91

B1-1b(1)	Field Blanks	  PAGEREF _Toc43090767 \h  92

B1-1b(2)	Equipment Blanks/Manifold Blank	  PAGEREF _Toc43090768 \h  93

B1-1b(3)	Field Reference Standards	  PAGEREF _Toc43090769 \h  93

B1-1b(4)	Field Duplicates	  PAGEREF _Toc43090770 \h  93

B1-1c	Equipment Testing, Inspection, and Maintenance	  PAGEREF
_Toc43090771 \h  94

B1-1c(1)	Headspace Gas Sample Canister Cleaning	  PAGEREF _Toc43090772
\h  94

B1-1c(2)	Sampling Equipment Initial Cleaning and Leak-Check	  PAGEREF
_Toc43090773 \h  94

B1-1c(3)	Sampling Equipment Routine Cleaning and Leak-Check	  PAGEREF
_Toc43090774 \h  94

B1-1c(4)	Manifold Cleaning After Field Reference Standard Collection
PAGEREF _Toc43090775 \h  95

B1-1c(5)	Sampling Head Cleaning	  PAGEREF _Toc43090776 \h  95

B1-1d	Equipment Calibration and Frequency	  PAGEREF _Toc43090777 \h  95

B1-2	Sampling of Homogeneous Solids and Soil/Gravel	  PAGEREF
_Toc43090778 \h  96

B1-2a	Method Requirements	  PAGEREF _Toc43090779 \h  96

B1-2a(1)	Core Collection	  PAGEREF _Toc43090780 \h  96

B1-2a(2)	Sample Collection	  PAGEREF _Toc43090781 \h  99

B1-2b	Quality Control Requirements	  PAGEREF _Toc43090782 \h  99

B1-2b(1)	Field Duplicates	  PAGEREF _Toc43090783 \h  99

B1-2b(2)	Equipment Blanks	  PAGEREF _Toc43090784 \h  99

B1-2b(3)	Sample Equipment Cleaning	  PAGEREF _Toc43090785 \h  100

B1-2c	Equipment Testing, Inspection, and Maintenance	  PAGEREF
_Toc43090786 \h  101

B1-2d	Equipment Calibration and Frequency	  PAGEREF _Toc43090787 \h  101

B1-3	Radiography	  PAGEREF _Toc43090788 \h  102

B1-3a	Methods Requirements	  PAGEREF _Toc43090789 \h  102

B1-3b	Quality Control	  PAGEREF _Toc43090790 \h  104

B1-3b(1)	Formal Training	  PAGEREF _Toc43090791 \h  105

B1-3b(2)	On-the-Job Training	  PAGEREF _Toc43090792 \h  105

B1-3b(3)	Visual Examination (to Confirm RTR)	  PAGEREF _Toc43090793 \h
108

B1-3b(4)	Formal Training	  PAGEREF _Toc43090794 \h  110

B1-3b(5)	On-the-Job Training	  PAGEREF _Toc43090795 \h  110

TABLE OF CONTENTS (continued)

Chapter	Page

B1-4	Custody of Samples	  PAGEREF _Toc43090796 \h  111

B1-4a	Gas Samples	  PAGEREF _Toc43090797 \h  112

B1-4a(1)	Sequence of Activities for Gas Canisters, COC form, and Other
Sample Documents	  PAGEREF _Toc43090798 \h  112

B1-4a(2)	COC Practices	  PAGEREF _Toc43090799 \h  115

B1-4a(3)	Headspace Sample Size, and Sample Canister Holding Temperatures
and Storage

	Conditions	  PAGEREF _Toc43090800 \h  115

B1-4a(4)	WIPP Sample Identification Number	  PAGEREF _Toc43090801 \h
116

B1-4a(5)	Canister Identification Number	  PAGEREF _Toc43090802 \h  116

B1-4a(6)	Laboratory Sample Identification Number	  PAGEREF _Toc43090803
\h  116

B1-4b	Homogeneous Solids and Soil/Gravel Sample Container	  PAGEREF
_Toc43090804 \h  117

B1-4b(1)	Chain-of-Custody	  PAGEREF _Toc43090805 \h  117

B1-4b(2)	Handling	  PAGEREF _Toc43090806 \h  117

B1-4b(3)	Homogeneous Solids and Soil/Gravel Sample Containers	  PAGEREF
_Toc43090807 \h  118

B1-5	Sample Packing and Shipping	  PAGEREF _Toc43090808 \h  119

B2.	statistical methods used in sampling and analysis	  PAGEREF
_Toc43090809 \h  139

B2-1	Approach for Statistically Selecting Waste Containers for Visual

	Examination (to Confirm RTR)	  PAGEREF _Toc43090810 \h  139

B2-2	Approach for Selecting Waste Containers for Statistical Sampling
PAGEREF _Toc43090811 \h  141

B2-2a	Statistical Selection of Containers for Total (or TCLP) Analysis
PAGEREF _Toc43090812 \h  141

B2-2b	Statistical Selection of Containers for Headspace Gas Analysis
PAGEREF _Toc43090813 \h  143

B2-3	Upper Confidence Limit for Statistical Sampling	  PAGEREF
_Toc43090814 \h  144

B2-3a	Upper Confidence Limit for Statistical Solid Sampling	  PAGEREF
_Toc43090815 \h  144

B2-3b	Upper Confidence Limit for Statistical Headspace Gas Sampling
PAGEREF _Toc43090816 \h  144

B2-4	Control Charting for Newly Generated Waste Stream Sampling
PAGEREF _Toc43090817 \h  145

B3.	Quality assurance objectives and data validation techniques for
Waste characterization sampling and analytical methods	  PAGEREF
_Toc43090818 \h  149

B3-1	Validation Methods	  PAGEREF _Toc43090819 \h  149

B3-1a	Precision	  PAGEREF _Toc43090820 \h  149

B3-1b	Accuracy	  PAGEREF _Toc43090821 \h  150

B3-1c	Method Detection Limit	  PAGEREF _Toc43090822 \h  150

B3-1d	Completeness	  PAGEREF _Toc43090823 \h  151

B3-1e	Comparability	  PAGEREF _Toc43090824 \h  151

B3-1f	Representativeness	  PAGEREF _Toc43090825 \h  152

B3-1g	Nonconformance to DQOs	  PAGEREF _Toc43090826 \h  152

B3-1h	Identification of Tentatively Identified Compounds	  PAGEREF
_Toc43090827 \h  152

B3-2	Headspace Gas Sampling	  PAGEREF _Toc43090828 \h  155

B3-2a	Quality Assurance Objectives	  PAGEREF _Toc43090829 \h  155

B3-2b	Precision	  PAGEREF _Toc43090830 \h  155

B3-2c	Accuracy	  PAGEREF _Toc43090831 \h  155

B3-2d	Completeness	  PAGEREF _Toc43090832 \h  156

B3-2e	Comparability	  PAGEREF _Toc43090833 \h  156

B3-2f	Representativeness	  PAGEREF _Toc43090834 \h  157

B3-3	Sampling of Homogeneous Solids and Soils/Gravel	  PAGEREF
_Toc43090835 \h  158

B3-3a	Quality Assurance Objectives	  PAGEREF _Toc43090836 \h  158

B3-3b	Precision	  PAGEREF _Toc43090837 \h  158

B3-3c	Accuracy	  PAGEREF _Toc43090838 \h  159

B3-3d	Completeness	  PAGEREF _Toc43090839 \h  159

B3-3e	Comparability	  PAGEREF _Toc43090840 \h  159

B3-3f	Representativeness	  PAGEREF _Toc43090841 \h  159

TABLE OF CONTENTS (continued)

Chapter	Page

B3-4	Radiography	  PAGEREF _Toc43090842 \h  160

B3-4a	Quality Assurance Objectives	  PAGEREF _Toc43090843 \h  160

B3-4b	Precision	  PAGEREF _Toc43090844 \h  160

B3-4c	Accuracy	  PAGEREF _Toc43090845 \h  160

B3-4d	Completeness	  PAGEREF _Toc43090846 \h  161

B3-4e	Comparability	  PAGEREF _Toc43090847 \h  161

B3-5	Gas Volatile Organic Compound Analysis	  PAGEREF _Toc43090848 \h
162

B3-5a	Quality Assurance Objectives	  PAGEREF _Toc43090849 \h  162

B3-5b	Precision	  PAGEREF _Toc43090850 \h  162

B3-5c	Accuracy	  PAGEREF _Toc43090851 \h  162

B3-5d	Calibration	  PAGEREF _Toc43090852 \h  163

B3-5e	Method Detection Limit	  PAGEREF _Toc43090853 \h  163

B3-5f	Program Required Quantitation Limit	  PAGEREF _Toc43090854 \h  163

B3-5g	Completeness	  PAGEREF _Toc43090855 \h  163

B3-5h	Comparability	  PAGEREF _Toc43090856 \h  164

B3-5i	Representativeness	  PAGEREF _Toc43090857 \h  164

B3-5j	Method Performance Samples (MPS)	  PAGEREF _Toc43090858 \h  164

B3-6	Total Volatile Organic Compound Analysis	  PAGEREF _Toc43090859 \h
165

B3-6a	Quality Assurance Objectives	  PAGEREF _Toc43090860 \h  165

B3-6b	Precision	  PAGEREF _Toc43090861 \h  165

B3-6c	Accuracy	  PAGEREF _Toc43090862 \h  166

B3-6d	Calibration	  PAGEREF _Toc43090863 \h  167

B3-6e	Method Detection Limit	  PAGEREF _Toc43090864 \h  167

B3-6f	Program Required Quantitation Limit	  PAGEREF _Toc43090865 \h  167

B3-6g	Completeness	  PAGEREF _Toc43090866 \h  167

B3-6h	Comparability	  PAGEREF _Toc43090867 \h  168

B3-6i	Representativeness	  PAGEREF _Toc43090868 \h  168

B3-7	Total Semivolatile Organic Compound Analysis	  PAGEREF _Toc43090869
\h  169

B3-7a	Quality Assurance Objectives	  PAGEREF _Toc43090870 \h  169

B3-7b	Precision	  PAGEREF _Toc43090871 \h  169

B3-7c	Accuracy	  PAGEREF _Toc43090872 \h  170

B3-7d	Calibration	  PAGEREF _Toc43090873 \h  171

B3-7e	Method Detection Limit	  PAGEREF _Toc43090874 \h  171

B3-7f	Program Required Quantitation Limit	  PAGEREF _Toc43090875 \h  171

B3-7g	Completeness	  PAGEREF _Toc43090876 \h  171

B3-7h	Comparability	  PAGEREF _Toc43090877 \h  172

B3-7i	Representativeness	  PAGEREF _Toc43090878 \h  172

B3-8	Total or TCLP Metal Analysis	  PAGEREF _Toc43090879 \h  173

B3-8a	Quality Assurance Objectives	  PAGEREF _Toc43090880 \h  173

B3-8b	Precision	  PAGEREF _Toc43090881 \h  173

B3-8c	Accuracy	  PAGEREF _Toc43090882 \h  174

B3-8d	Calibration	  PAGEREF _Toc43090883 \h  175

B3-8e	Program Required Detection Limits	  PAGEREF _Toc43090884 \h  175

B3-8f	Program Required Quantitation Limit	  PAGEREF _Toc43090885 \h  175

B3-8g	Completeness	  PAGEREF _Toc43090886 \h  175

B3-8h	Comparability	  PAGEREF _Toc43090887 \h  176

B3-8i	Representativeness	  PAGEREF _Toc43090888 \h  176

B3-9	Acceptable Knowledge	  PAGEREF _Toc43090889 \h  177

TABLE OF CONTENTS (continued)

Chapter	Page

B3-10	Data Review, Validation, and Verification Requirements	  PAGEREF
_Toc43090890 \h  178

B3-10a	Data Generation Level	  PAGEREF _Toc43090891 \h  179

B3-10a(1)	Independent Technical Review	  PAGEREF _Toc43090892 \h  181

B3-10a(2)	Technical Supervisor Review	  PAGEREF _Toc43090893 \h  182

B3-10a(3)	QA Officer Review	  PAGEREF _Toc43090894 \h  183

B3-10b	Project Level	  PAGEREF _Toc43090895 \h  183

B3-10b(1)	TWCP Site PQAO Review	  PAGEREF _Toc43090896 \h  184

B3-10b(2)	TWCP Site PM Review	  PAGEREF _Toc43090897 \h  185

B3-10b(3)	Preparation of theTWCP Site PQAO Summary and the TWCP Site PM
Data Validation Summary	  PAGEREF _Toc43090898 \h  185

B3-10b(4)	Preparation of the Waste Stream Characterization Package
PAGEREF _Toc43090899 \h  186

B3-10b(5)	Sample Disposition	  PAGEREF _Toc43090900 \h  186

B3-11	Reconciliation with Data Quality Objectives	  PAGEREF _Toc43090901
\h  187

B3-11a	Reconciliation at the Project Level	  PAGEREF _Toc43090902 \h
187

B3-12	Data Reporting Requirements	  PAGEREF _Toc43090903 \h  189

B3-12a	Data Generation Level to the Project Level	  PAGEREF _Toc43090904
\h  189

B3-12b	Project Level to DOE/CBFO Level	  PAGEREF _Toc43090905 \h  189

B3-12b(1)	Waste Stream Profile Form	  PAGEREF _Toc43090906 \h  190

B3-12b(2)	Characterization Information Summary	  PAGEREF _Toc43090907 \h
 191

B3-12b(3)	Waste Stream Characterization Package	  PAGEREF _Toc43090908
\h  191

B3-12c	WIPP Waste Information System (WWIS)	  PAGEREF _Toc43090909 \h
192

B3-13	Nonconformances and Corrective Actions	  PAGEREF _Toc43090910 \h
192

B3-13a	Nonconformances	  PAGEREF _Toc43090911 \h  193 2

B3-13b	Corrective Actions	  PAGEREF _Toc43090912 \h  195

B3-14	Special Training Requirements and Certification	  PAGEREF
_Toc43090913 \h  196

B3-15	This section has been deleted	  PAGEREF _Toc43090914 \h  196

B3-16	Hydrogen and Methane Analysis	  PAGEREF _Toc43090915 \h  197

B3-16a	Methods Requirements	  PAGEREF _Toc43090916 \h  197

B3-16b	Quality Control	  PAGEREF _Toc43090917 \h  197

B3-16c	Instrument Testing, Inspection, and Maintenance Requirements
PAGEREF _Toc43090918 \h  197

B4.	TRU WASTE CHARACTERIZATION USING ACCEPTABLE KNOWLEDGE	  PAGEREF
_Toc43090919 \h  221

B4-1	Introduction	  PAGEREF _Toc43090920 \h  221

B4-2	Acceptable Knowledge Documentation	  PAGEREF _Toc43090921 \h  222

B4-2a	Required TRU Waste Management Program Information	  PAGEREF
_Toc43090922 \h  222

B4-2b	Required TRU Waste Stream Information	  PAGEREF _Toc43090923 \h
223

B4-2c	Supplemental Acceptable Knowledge Documentation	  PAGEREF
_Toc43090924 \h  225

B4-3	Acceptable Knowledge Training, Procedures and Other Requirements
PAGEREF _Toc43090925 \h  226

B4-3a	Qualifications and Training Requirements	  PAGEREF _Toc43090926 \h
 226

B4-3b	Acceptable Knowledge Assembly, Compilation, and Confirmation
Procedures and Required Administrative Controls	  PAGEREF _Toc43090927
\h  228

B4-3b(1)	Procedures Used to Assemble the Acceptable Knowledge Record
PAGEREF _Toc43090928 \h  229

B4-3b(2)	Procedures Used to Compile the Acceptable Knowledge Record
PAGEREF _Toc43090929 \h  229

B4-3b(3)	Procedures Used to Ensure Unacceptable Waste is Identified and
Segregated	  PAGEREF _Toc43090930 \h  230

B4-3b(4)	Procedures Used to Evaluate Acceptable Knowledge, Resolve
Discrepancies, Assign Hazardous Waste Numbers, etc.	  PAGEREF
_Toc43090931 \h  231

B4-3b(5)	Procedures Used to Identify Hazardous Waste	  PAGEREF
_Toc43090932 \h  231

B4-3b(6)	Procedures Used to Confirm Acceptable Knowledge and to
Re-Evaluate Acceptable Knowledge	  PAGEREF _Toc43090933 \h  232

B4-3b(7)	Procedures Used to Cross-Reference to the Applicable Waste
Summary Category Group	  PAGEREF _Toc43090934 \h  234

B4-3b(8)	Procedures Used to Ensure that Audit Results are Available
PAGEREF _Toc43090935 \h  234

B4-3b(9)	Procedures Used for Administrative Control	  PAGEREF
_Toc43090936 \h  234

B4-3c	Criteria for Assembling an Acceptable Knowledge Record and
Delineating the Waste Stream	  PAGEREF _Toc43090937 \h  236

TABLE OF CONTENTS (continued)

Chapter	Page

B4-3d	Requirements for Confirmation of Acceptable Knowledge	  PAGEREF
_Toc43090938 \h  237

B4-3d(1)	Re-Evaluation Based on RTR and Visual Examination	  PAGEREF
_Toc43090939 \h  238

B4-3d(2)	TRU Heterogeneous Debris	  PAGEREF _Toc43090940 \h  238

B4-3d(3)	Headspace Gas Sampling	  PAGEREF _Toc43090941 \h  239

B4-3d(4)	Homogeneous Solids and Soil/Gravel	  PAGEREF _Toc43090942 \h
240

B4-3e	Acceptable Knowledge Data Quality Requirements	  PAGEREF
_Toc43090943 \h  241

B4-3e(1)	Precision	  PAGEREF _Toc43090944 \h  241

B4-3e(2)	Accuracy	  PAGEREF _Toc43090945 \h  241

B4-3e(3)	Completeness	  PAGEREF _Toc43090946 \h  241

B4-3e(4)	Comparability	  PAGEREF _Toc43090947 \h  241

B4-3e(5)	Representativeness	  PAGEREF _Toc43090948 \h  242

B4-3f	Audits of Acceptable Knowledge	  PAGEREF _Toc43090949 \h  242

B4-4	Additional Final Confirmation of Acceptable Knowledge at the WIPP
Facility	  PAGEREF _Toc43090950 \h  243

B5.	quality assurance project plan requirements	  PAGEREF _Toc43090951
\h  245

B5-1	Site-Specific Quality Assurance Project Plan	  PAGEREF _Toc43090952
\h  245

B5-2	Document Review, Approval, and Control	  PAGEREF _Toc43090953 \h
245

B5-3	Quality Assurance Records Management	  PAGEREF _Toc43090954 \h  247

B5-3a	Waste Records Center	  PAGEREF _Toc43090955 \h  247

B5-3b	Flow of Data Records	  PAGEREF _Toc43090956 \h  248

B5-4	QA Reports to Management	  PAGEREF _Toc43090957 \h  248

B5-5	QA Grading	  PAGEREF _Toc43090958 \h  249

B6.	RFETS audit and surveillance program	  PAGEREF _Toc43090959 \h  253

B6-1	Internal Management Assessments and Independent Surveillances
PAGEREF _Toc43090960 \h  253

B6-2	External Audits	  PAGEREF _Toc43090961 \h  253

C.	RECORDS PROCESSING	  PAGEREF _Toc43090962 \h  255

D.	REFERENCES	  PAGEREF _Toc43090963 \h  257

D-1	External References	  PAGEREF _Toc43090964 \h  257

D-2	RFETS References	  PAGEREF _Toc43090965 \h  261

E.	Glossary	  PAGEREF _Toc43090966 \h  269

E-1	Acronyms and Abbreviations	  PAGEREF _Toc43090967 \h  269

E-2	Definitions	  PAGEREF _Toc43090968 \h  274

TABLE OF CONTENTS (continued)

FIGURES AND TABLES 	Page

  TOC \t "TABLE TITLE,1"  Table B-1, Summary of Hazardous Waste
Characterization Requirements for         Transuranic Waste	  PAGEREF
_Toc43091108 \h  60

Table B-2, Maximum Allowable VOC Room-Averaged HeadspaceConcentration
                  Limits (PPMV)	  PAGEREF _Toc43091109 \h  66

Table B-3, Headspace Gas: Target Analyte List and Methods	  PAGEREF
_Toc43091110 \h  67

Table B-4, Required Organic Analyses and Test Methods Organized by
Organic         Analytical Groups	  PAGEREF _Toc43091111 \h  68

Table B-5, Summary of Sample Preparation and Analytical Methods for
Metals	  PAGEREF _Toc43091112 \h  69

Table B-6, Summary of Parameters, Characterization Methods, and
Rationale for CH Transuranic Waste	  PAGEREF _Toc43091113 \h  70

Table B-7, Required Program Records Maintained in RFETS Project Files
PAGEREF _Toc43091114 \h  71

Table B-8, WIPP Waste Information System Data Fields	  PAGEREF
_Toc43091115 \h  72

Figure B-1, WIPP Waste Stream Profile Form	  PAGEREF _Toc43091116 \h  73

FIGURE b-2, DATA COLLECTION DESIGN FOR CHARACTERIZATION OF NEWLY
GENERATED WASTE	75

Figure B-3, Data Collection Design for Characterization of Retrievably
Stored Waste	  PAGEREF _Toc43091117 \h  76

Figure B-4, Levels of Data Verification	  PAGEREF _Toc43091119 \h  77

Figure B-5, TRU Mixed Waste Screening Flow Diagram	  PAGEREF
_Toc43091120 \h  78

Table B1-1, Headspace Gas: SUMMA® Canisters, Canister Volumes and
Holding        Temperatures	  PAGEREF _Toc43091121 \h  120

Table B1-2, Headspace Gas: Summary of Field Quality Control Sample
Frequencies	  PAGEREF _Toc43091122 \h  120

Table B1-3, Headspace Gas: Summary of Field Quality Control Sample
Acceptance          Criteria	  PAGEREF _Toc43091123 \h  121

Table B1-4, Sample Handling Requirements for Homogeneous Solids and
Soil/Gravel	  PAGEREF _Toc43091124 \h  121

TABLE B1-5, HEADSPACE GAS DRUM AGE CRITERIA SAMPLING SCENARIOS	  PAGEREF
_Toc43091125 \h  122

TABLE B1-6, SCENARIO 1 DRUM AGE CRITERIA (in days) MATRIX	  PAGEREF
_Toc43091126 \h  123

TABLE B1-7, SCENARIO 2 DRUM AGE CRITERIA (in days) MATRIX	  PAGEREF
_Toc43091127 \h  124

TABLE B1-8, SCENARIO 3 PACKAGING CONFIGURATION GROUPS	  PAGEREF
_Toc43091128 \h  125

TABLE B1-9, SCENARIO 3 DRUM AGE CRITERIA (in days) MATRIX FOR S5000
WASTE BY PACKAGING CONFIGURATION GROUP	  PAGEREF _Toc43091129 \h  128

TABLE B1-10, SCENARIO 3 DRUM AGE CRITERIA (in days) MATRIX FOR S3000 AND
S4000 WASTE BY PACKAGING CONFIGURATION GROUP	  PAGEREF _Toc43091130 \h
130

TABLE OF CONTENTS (continued)

FIGURES AND TABLES 	Page

Figure B1-1, Example of the Chain-of-Custody for Headspace Gas Sample
Canisters	  PAGEREF _Toc43091131 \h  132

Figure B1-2, Example of the Sample Canister Information Document
PAGEREF _Toc43091132 \h  133

Figure B1-3, Example of the Sample Canister Tag	  PAGEREF _Toc43091133
\h  134

Figure B1-4, Example of the Chain-of-Custody/Sample Analysis Request
(WIPP)	  PAGEREF _Toc43091135 \h  135

Figure B1-5, Example Custody Seal	  PAGEREF _Toc43091136 \h  136

Figure B1-6, Overall Programmatic Approach to Visual Examination of the
Waste for Confirmation of RTR	  PAGEREF _Toc43091137 \h  137

Figure B1-7, Headspace Gas Drum Age Criteria Sampling Scenario Selection
Process	  PAGEREF _Toc43091138 \h  138

Table B2-1, Number of Waste Containers Requiring Visual Examination
PAGEREF _Toc43091139 \h  147

Figure B2-1, Statistical Approach to Sampling and Analysis of Waste
Streams of   Retrievably Stored Homogeneous Solids and Soil/Gravel
PAGEREF _Toc43091140 \h  148

Table B3-1, Physical form of waste (waste material parameter) and
Descriptions	  PAGEREF _Toc43091141 \h  198

Table B3-2, Gas Volatile Organic Compounds Target Analyte List and
Quality            Assurance Objectives When Using SUMMA® Canisters or
On-Line Systems	  PAGEREF _Toc43091143 \h  199

Table B3-3, Summary of Laboratory Quality Control Samples and
Frequenciesfor Gas Volatile Organic Compounds AnalysisWhen Using SUMMA®
Canisters or On-Line       Systems	  PAGEREF _Toc43091146 \h  200

Table B3-4, Volatile Organic Compounds Target Analyte List and Quality
Assurance Objectives	  PAGEREF _Toc43091147 \h  201

Table B3-5, Summary of Laboratory Quality Control Samples and
Frequencies for     Volatile Organic Compounds Analysis	  PAGEREF
_Toc43091148 \h  202

Table B3-6, Semi-Volatile Organic Compounds Target Analyte List and
Quality          Assurance Objectives	  PAGEREF _Toc43091149 \h  203

Table B3-7, Summary of Laboratory Quality Control Samples and
Frequencies for              Semi-Volatile Organic Compounds Analysis
PAGEREF _Toc43091150 \h  204

Table B3-8, Metals Target Analyte List and Quality Assurance Objectives
 PAGEREF _Toc43091151 \h  206

Table B3-9, Summary of Laboratory QC Samples and Frequencies for Metals
Analysis	  PAGEREF _Toc43091152 \h  207

TABLE B3-10, MINIMUM TRAINING AND QUALIFICATIONS REQUIREMENTS	  PAGEREF
_Toc43091153 \h  208

Table B3-11, Testing Batch Data Report Contents	  PAGEREF _Toc43091154
\h  209

Table B3-12, Sampling Batch Data Report Contents	  PAGEREF _Toc43091155
\h  212

Table B3-13, Analytical Batch Data Report Contents	  PAGEREF
_Toc43091156 \h  215

TABLE OF CONTENTS (continued)

FIGURES AND TABLES 	Page

Table B3-14, Data Reporting Flags	  PAGEREF _Toc43091157 \h  217

Table B3-15, TC Levels Expressed as RTL Values in the Waste	  PAGEREF
_Toc43091158 \h  218

Table B3-16A, Hydrogen and Methane Analysis Quality Assurance Objectives
  PAGEREF _Toc43091159 \h  219

Table B3-16B, Summary of Laboratory Quality Control Samples and
Frequencies for Hydrogen and Methane Analysis	  PAGEREF _Toc43091160 \h
219

Table B5-1, Minimum Requirements for Review, Approval, Implementation
and Control             of QAPjP	  PAGEREF _Toc43091161 \h  250

Figure B5-1, Flow of Data Records for the Project	  PAGEREF _Toc43091162
\h  251

VERSION CHANGE SUMMARY

The following changes are necessary to update the document to Version 9.

Page	Section	Description of Change

1	Cover Page	Changed “Version 8” to “Version 9.”  Revised
“Important Notes” to indicate this plan supersedes Version 8.

3	Approvals	Changed “Version 8” to “Version 9.”

14-16	VCS	Updated Version Change Summary.

17	A	Revised second paragraph of this section to read “This version of
the document supersedes 95-QAPjP Version 8.  Content changes from the
previous version are marked with a version bar.”

Entire	Document	Revised header on every page from “Version 8” to
“Version 9” and updated effective date.

The following changes are necessary to address offsite sample analysis.

Page	Section	Description of Change

111	B1-4	Added “for solid samples” to 1st paragraph.  Added
“and/or analyzed” to 3rd paragraph.

117	B1-4b	Added “collected and analyzed at RFETS” to 3rd sentence.

	B1-4b(1)	Inserted new paragraph, formally last two sentences of Section
B1-4b.

119	B1-5	Revised section to address shipment of samples offsite.

264, 265	D-2	Added reference to MAN-T91-STSM-001, Site Transportation
Safety Manual (STSM); and PRO-908-ASD-004, On-Site Transfer and Off-Site
Shipment of Samples.

The following changes are necessary as part of document maintenance.

Page	Section	Description of Change

18	A-3	Revised  6th and 8th paragraphs to describe current sample
analysis activities at RFETS.

22	A-5a	Replaced “of data approval” with “for sample release” in
2nd sub-bullet.

26	A-5b	Corrected “Initiating” to “Initiates” for 4th bullet.

32	A-5g(2)	Revised 1st bullet since position no longer matrixed.
Deleted 6th bullet since this is conducted by TWCP Site PQAO.

VERSION CHANGE SUMMARY (continued)

Document maintenance changes (continued).

Page	Section	Description of Change

143	B2-2a	Replaced reference to 95-WP/SAP-001, Transuranic (TRU/TRM)
Waste Sampling Plan with RMRS-WIPP-98-100, Acceptable Knowledge TRU/TRM
Waste Stream Summaries.

181	B3-10a(1)	Added “or version” to 1st bullet.

196	B3-14	Revised 3rd paragraph to reference correct place in the
TWCP-TIP for site-specific titles.  Updated TWCP-TIP Section 7.6 title
to Continuing Training in 4th paragraph.

208	Table B3-10	Revised notes b and c to reference correct sections of
the TWCP-TIP.

226	B4-3	Revised 1st sentence to reference correct section of updated
TWCP-TIP.

The following changes are necessary as part of document maintenance and
consist of notes added to referenced documents indicating they are
inactive and superseded.

Page	Referenced Documents

	61, 63, 65, 84, 92, 94, 155, 164, 197, 233, 239, 263, 264	Added note to
L-4053, Headspace Gas V&V (Data Generator Level) indicating the
procedure is inactive as of June 18, 2003, superseded by
PRO-1669-HGAS-V&V, Headspace Gas V&V (Data Generator Level).

	Added note to L-4231, Headspace Gas Sampling and Analysis Using an
Automated Manifold indicating the procedure is inactive as of June 18,
2003, superseded by PRO-1676-HGAS-S&A, Headspace Gas Sampling and
Analysis Using an On-Line Integrated System.

The following changes are necessary as part of document maintenance and
consist of document number or title changes for referenced documents.

Page	Referenced Documents

	23, 64, 97-98, 232, 266	Corrected number for 1-PRO-077-WIPP-005 to
PRO-077-WIPP-005.

	Corrected title for PRO-1569-SAP-001, Polymerized Organic and Inorganic
Liquid Process – Sampling and Analysis Plan.

	Corrected title for PRO-1729-903-SOIL, TRU Soil Removal From
Pre-Selected Areas, 903 Pad.

	Corrected title for PRO-1730-903-001, TRU 903 Pad Soil Removal/Repack
and Characterization Plan.

The following changes are necessary as part of document maintenance and
consist of notes added to referenced documents indicating they are
inactive or will be deactivated.

Page	Referenced Documents

	60-65, 84, 98, 102-103, 105, 107-109, 115, 117, 161, 165-176, 227, 230,
232-234, 239, 245, 247, 262-267	PRO-1471-VE-771, Visual Examination for
Confirmation of RTR .

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

	L-4038, WIPP Data Review and Validation for Volatile Organic Compounds.

	L-4165, GC/MS Determination of Volatile Organic Compounds (Solids,
Liquids, and TCLP Extracts).

	L-4035, Metals Data Verification and Validation Data Generation Level.

	L-4039, WIPP Data Review and Validation for Semi-Volatile Organic
Compounds.

	L-4150, Total Metals Acid Digestion Procedure of Solid, Liquid, and
TCLP Extract Samples.

	L-4151, Waste Analysis by Atomic Absorption Spectroscopy.

	L-4152, Mercury Analysis in Waste (Cold-Vapor Technique).

	L-4153, Trace Metals by ICP Spectrometry (Solids, Liquids, and TCLP
Extracts).

	L-4214, Extraction of Total SVOCs for GC/MS Analysis for WIPP.

	L-4215, GC/MS Determination of Total SVOCs for WIPP.

	L-4217, Metals Analysis Data Compilation and Reporting.

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

	PRO-1266-SS-002, Tank Sludge Removal from Pre-Selected Areas, Building
774.

	L-4028, Sample Administration for the Radiological Laboratories.

	PRO-1628-A2-001, Tank Sludge Removal from Pre-Selected Areas, Tank
T-207.

	4-I19-NDT-00569, Real-Time Radiography Testing of Transuranic and
Low-level Waste in Building 569.

	RS-012-005, Cone and Quartering Method – Solid Sampling and Analysis
Plan.

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

	L-4108, Toxicity Characteristic Leaching Procedure (TCLP) for Metals in
Waste.

	L-1000, Requirements for Laboratory Procedures.

A.	Introduction

The Rocky Flats Environmental Technology Site (RFETS) intends to dispose
of transuranic (TRU) waste at the Waste Isolation Pilot Plant (WIPP)
facility.  It has developed this TRU Waste Characterization Program
Quality Assurance Project Plan (TWCP QAPjP) to comply with the WIPP
Hazardous Waste Permit, Attachment B, Waste Analysis Plan (WIPP-WAP).
In this document, the term TRU waste includes TRU and TRU-mixed waste.
This document complies with quality requirements of the Department of
Energy, Carlsbad Field Office Quality Assurance Program Document (QAPD)
(DOE 2003b).  The structure of this document parallels the structure of
the WIPP-WAP.

This version of the document supersedes 95-QAPjP-0050, Version 8.
Content changes from the previous version are marked with a version bar.

A-1	Scope

This document describes how the requirements of the WIPP-WAP are met at
RFETS. This document identifies the quality of data necessary, and the
procedures developed by RFETS to attain and maintain quality in the
TWCP.

RFETS complies with the existing requirements in the WIPP-WAP.  Any
conflicts between this document and existing requirements will be
resolved by the TWCP Site Project Manager (TWCP Site PM).

A-2	Overview

RFETS is a United States (U.S.) government-owned, private contractor
operated facility that is part of the nationwide nuclear weapons
production complex.  Since its inception in 1952, the principal mission
of the Rocky Flats Plant was the production of nuclear weapons
components from plutonium, uranium, beryllium, and various alloys of
stainless steel.  Additional RFETS missions included plutonium recovery
and reprocessing, and waste management.  To support its weapons
component production mission, Rocky Flats Plant operation included
facilities for the storage, treatment and transport of waste, chemical
laboratories, research and development, and facilities for plutonium
recovery.  The production mission of the Rocky Flats Plant was
officially discontinued in 1992 with the end of the Cold War.  The new
mission focuses on environmental restoration, waste management,
decontamination and decommissioning, stabilization of nuclear material
and residues, and economic development.  As part of the transition, the
name for the Rocky Flats Plant was changed to the Rocky Flats
Environmental Technology Site.  RFETS is owned by the U. S. DOE, and is
operated under an integrating contract with Kaiser-Hill.  Throughout the
changing missions, RFETS has generated and will continue to generate TRU
and TRM waste.

A-3	Description of RFETS

RFETS is located in northern Jefferson County, Colorado, and is
approximately 16 miles northwest of Denver.   More than 270 buildings
and structures, of which about 75 are trailers, are located at the
plant.  Major manufacturing, processing, plutonium recovery, and waste
treatment facilities occupy about 1.6 million square feet of this space.
 The remaining floor space is occupied by laboratories, administrative
offices, warehouses, utilities, security, storage, and construction
contractor facilities.

At present, RFETS waste handling operations include storage,
transportation, treatment, and packaging of waste materials.  Waste
managed at RFETS includes nonhazardous, hazardous, radioactive, and
mixed radioactive.

The facilities used to support TWCP activities include: Buildings 371,
440, 559, 569, 664, 707, 771, 776/777, 991, and mobile characterization
services.

Prior to October 22, 2002 headspace gas samples were collected using
both SUMMA( or equivalent canisters and on-line integrated
sampling/analysis systems, operated by the RFETS Analytical
Laboratories.  Currently, all headspace gas sampling and analysis is
conducted at RFETS utilizing on-line integrated systems, operated by
Headspace Analytical Services.  Information relative to headspace
sampling with SUMMA( canisters is included for historical traceability
and consistency with the WIPP-WAP.

Sampling of headspace gases has been performed in processing facilities
located within Buildings 371, 440, 776, and 991.  The Building 440, Room
113 Perma-Con, and Room 123 C-Cell are used to obtain headspace gas
samples.  Buildings 371, 440, and 771 may be used for performing visual
confirmation of waste container contents.  The Building 776 Size
Reduction Vault (SRV) airlocks, (Room 146B or 146C); Advanced Size
Reduction Facility (ASRF) Transfer Airlock (TA); the Manual Disassembly
Airlock (MDA); and the Barrel Dump Glovebox were formerly used to obtain
headspace gas samples, obtain solid waste matrix samples, or for
performing visual confirmation of waste container contents.

Analysis of headspace gas samples and/or solid waste matrix samples was
performed in the Building 559, 707, and 777 analytical laboratories.
Specific analytical techniques include Inductively Coupled Plasma (ICP)
Mass Spectrometry, Gas Chromatography/Mass Spectrometry (GC/MS), Gas
Mass Spectrometry, and Atomic Absorption (AA) Spectroscopy.  To allow
for decommissioning of RFETS Analytical Laboratories, solid waste matrix
samples collected after December 31, 2003 are shipped off-site for
analysis.  Currently, analysis of headspace gas samples is performed in
Building 440 by the Automated Manifold System using GC/MS and GC/Thermal
Conductivity Detector (TCD) techniques.

Real-Time Radiography (RTR) is performed on waste containers using the
RTR units located in Building 664, and the Mobile RTR system in the
Building 664 Yard.  Prior to building closure for decommissioning, RTR
was also conducted in Building 569.  Nondestructive Assay (NDA) is
performed using the NDA systems identified in 1-MAN-008-WM-001,
Transuranic (TRU) Waste Management Manual (TWMM).

In addition to the facilities identified above, some RFETS wastes are
solid sampled and analyzed at the Idaho National Engineering and
Environmental Laboratory (INEEL).  Solid samples collected at RFETS
after December 31, 2003 are shipped to INEEL for analysis.  The INEEL
TWCP provides sampling and analysis support for client TRU waste sites
as described in the Statement of Work (SOW) for the INEEL TRU Waste
Characterization Program (DOE 2003a).

A-4	Project Description

To ensure that TRU waste is characterized according to established
requirements, RFETS has established the TWCP, which consists of teams
that retrieve, sample, and analyze waste; validate and report data; and
provide project management, quality assurance, audit and assessment, and
records management support.

TWCP personnel characterize TRU waste on a waste stream basis.  A waste
stream is defined as waste material generated from a single process or
activity that is similar in material, physical form, and hazardous
constituents.  TWCP personnel characterize TRU waste by obtaining
chemical, radiological, and physical data as described in this document.

Once a waste stream or an initial portion of the waste stream has been
identified using Acceptable Knowledge (AK), characterization information
must be developed in order to complete and submit the WIPP Waste Stream
Profile Form (WSPF) to the Carlsbad Field Office (CBFO).  Waste
characterization methods used for completing the WSPF include AK,
headspace gas sampling and analysis, and homogeneous waste sampling and
analysis, nondestructive assay (NDA) (addressed in the TWMM), RTR, and
visual examination (VE).  Data generated by these methods are assessed
on a waste stream basis.  For each waste stream characterized, the TWCP
Site PM determines if sufficient data have been collected to determine
the waste parameters required for completion of the WSPF.  After a WSPF
has been submitted to and approved by CBFO, characterization activities
continue on subsequent portions of the waste stream in order to verify
consistency with the WSPF.

TWCP personnel use the waste description nomenclature outlined in the
DOE Waste Treatability Group Guidance (DOE 1995a).  The nomenclature
includes three broad matrix categories of waste: homogeneous solids
(summary category S3000), soil/gravel (summary category S4000), and
debris waste (summary category S5000).  The waste matrix codes describe
the physical form of the waste, and are used to determine
characterization requirements.

A-4	Project Description   (continued)

Retrievably stored waste is defined as TRU waste generated after 1970
and before the New Mexico Environment Department (NMED) notifies the
WIPP facility, by approval of the final audit report, that the
characterization requirements of the WIPP-WAP have been implemented
appropriately at RFETS.  Newly generated waste is defined as TRU waste
generated after NMED approves the final audit report for RFETS.  All of
this waste is containerized, stored indoors in various buildings located
throughout RFETS, and can be easily inspected.  All newly generated
waste will also be stored in this manner.

In recent years, RFETS has focused on the stabilization of nuclear
material and radioactive waste.  The Residues Projects (Salt Residue
Stabilization/Repack; Ash Residue Repack; Combustible Residue Repack;
and Dry Residue Repack) were created to manage the radioactive waste
that was left over from the recovery and purification of fissile
materials used in the fabrication of nuclear weapons.  Buildings within
the Protected Area are being shutdown as D&D at RFETS progresses, and
therefore the Residue Projects were consolidated into Building 371.  The
Residues Projects assist in the solid sampling of TRU waste, i.e. Grid
and Cone and Quartering of applicable waste streams.

Approximately 50 percent of the current inventory of RFETS TRU waste
contains hazardous waste that is regulated under the Resource
Conservation and Recovery Act (RCRA).  Waste that is regulated under
both the Atomic Energy Act and RCRA is commonly known as mixed waste.
Throughout this document, the term TRU waste includes both TRU and
TRU-mixed waste.

Over the WIPP facility’s 35-year disposal phase, RFETS plans to
dispose of approximately 3,500 m3 of contact handled TRU waste.  Because
of historic activities, activities in recent years, and current
activities, the categories of TRU waste that exist at RFETS include:

Newly generated waste [Section B-3d and Section B-3d(1)]

Repackaged retrievably stored waste [Section B-3d and newly generated
waste requirements]

Retrievably stored waste  [Section B-3d and Section B-3d(2)]

Table B-1, Summary of Hazardous Waste Characterization Requirements for
Transuranic Waste, lists the parameters to be determined by the various
characterization activities, the techniques to be used, and the
regulatory compliance programs to be undertaken by data users.  All the
constituents to be determined by sampling and analysis of wastes are
also included in Table B-1.

A-5	RFETS Organization and Responsibilities

Material Stewardship, TRU Waste Project, provides program management of
the TWCP.  The TRU Waste Project Manager fulfills the functional role of
the TWCP Site PM.  The TWCP Site PM and the TWCP Site Project Quality
Assurance Officer (PQAO) report within the Material Stewardship
organization.  The principal organizations involved in supporting the
TWCP, their project level positions, and their primary responsibilities
are described in the TWMM, Section 3.1.1 - Organization and QA Program.
Functional organizational charts are also presented in the TWMM,
Appendix 1.  The following subsections describe functional roles/groups
primarily involved in TWCP WIPP-WAP characterization activities.

A-5a	TWCP Site PM

The TWCP Site PM performs the following:

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

Performs oversight and/or management of TWCP characterization
activities.

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

Manages CBFO and NMED audit preparations for TWCP characterization and
Residues processing.

Ensures through the TWCP Site PQAO that surveillances are scheduled and
performed.

Ensures development and maintenance of program documents, plans and
procedures necessary to implement the TWCP:

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

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

Reviews and concurs on TWCP characterization plans and procedures [e.g.,
headspace gas, visual examination (VE), Real-Time Radiography (RTR)];

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

Ensures that projects that support TWCP activities utilize processes
that comply with TWCP requirements.

Concurs with appointment of the TWCP Site PQAO and the PDCO.

Designates the Project Training Officer.

Ensures that applicable personnel are trained and qualified to TWCP
requirements.

A-5a	TWCP Site PM  (continued)

Provides for waste selection and tracking.

Provides for data validation and verification:

Approves Batch Data Reports;

Provides notification to Headspace Analytical Services, the Analytical
Laboratory, and the INEEL TWCP, as applicable for sample release.

Provides for data reconciliation with DQOs:

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

Provides direction to the TWCP Site PQAO, Project Data Control Officer
(PDCO), and project staff regarding analytical data validation and
reconciliation with QAOs as necessary.

Provides for the assignment of EPA Hazardous Waste Codes:

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

Implements Field Sample Quality Control procedures.

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

Approves WSPFs.

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

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

Provides for data transmission to CBFO:

Signs transmittal of the final Batch Data Reports;

Provides for submittal of the required data packages (through WEMS) to
the WIPP prior to each TRU waste shipment (contains complete package and
shipping information).

A-5a	TWCP Site PM  (continued)

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

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

Ensures that operator training is conducted according to requirements;

Ensures that visual waste characterization data are obtained for
appropriate waste containers used in the TWCP;

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

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

Ensures that data are recorded and complete;

Ensures that waste-characterization data forms and reports are
transmitted to the PDCO as soon as possible after data generation; and

Ensures 100% validation of VE raw data.

A-5a(1)	Project Data Control Officer (PDCO)

The Project Data Control Officer (PDCO) performs the following:

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

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

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

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

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

Provides training to WIPP records custodians.

A-5a(2)	Headspace Analytical Services

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

A-5a(2)(i)	Headspace Analytical Services Manager

NOTE:	Responsibilities for this function may be delegated to subordinate
managers.

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

Ensures that headspace personnel are trained and qualified.

Ensures participation in the PDPs for analytical testing.

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

Coordinates and schedules analytical work to support the TWCP.

Ensures that corrective and preventive actions have been completed.

Reviews and approves all Headspace Analytical Services SOPs and reports.

Assigns headspace staff.

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

Verifies that analytical requirements of the WIPP-WAP and QAPjP have
been met.

A-5b	TWCP Site PQAO

The TWCP Site PQAO performs the following:

Ensure that the TRU Waste Program QA program (defined in Section 3 of
the TWMM) provides RFETS compliance with the QAPD.

Schedules, performs, or directs, surveillance of TRU waste
characterization, generation, packaging, control, and acceptance
activities.

Tracks, reviews and approves the disposition of TWCP nonconformances.

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

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

Verifies data QA documentation through the data validation and
verification of Batch Data Reports.

Tracks, performs trend analysis, and reports on quality problem areas.

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

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

Provides QA/QC reports to the TWCP Site PM for review, transmittal to
CBFO, and distribution to the RFFO.

A-5b	TWCP Site PQAO  (continued)

Ensures conformance to QA requirements through:

Review and approval of procedures that implement the TWCP QA program;

Review and concurrence on the TWCP QAPjP, the GGTP QAPjP, and the TWMM;

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

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

Provides day-to-day guidance on quality assurance-related matters, as
necessary, to TWCP staff.

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

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

Interfaces with generators of TWCP data and quality-related records.

A-5c	Technical Operations

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

A-5c(1)	Waste Systems

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

Maintains the content and accuracy of the Backlog Waste Reassessment
Baseline Book (BWRBB) and coordinates reassessment of characterization
information for packaged waste.

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

A-5c(2)	Waste Requirements Group

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

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

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

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

Specifies labeling and marking of waste packages according to DOT and
TSDF requirements in accordance with the appropriate Labeling and
Marking Procedures for Radioactive Waste Material Packages.

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

A-5d	Waste Operations

Maintains storage area for off-site shipments.

Stores RCRA regulated wastes in compliance with applicable regulations.

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

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

Performs loading operations of TRUPACT-II packages.

Labels and marks packages according to DOT and TSDF requirements.

A-5d(1)	Nondestructive Testing (NDT)

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

Responsible for performing RTR of waste packages.

Responsible for the oversight of mobile RTR vendors.

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

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

Reviews and approves RTR data reports and forms;

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

Coordinates and schedules NDT work to support the TWCP;

Reviews and approves the NDT SOPs and forms and reports;

Verifies that TWCP QAPjP requirements are met;

Reviews and concurs with the TWCP QAPjP;

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

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

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

Assigns NDT personnel;

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

Ensures the preventive and routine maintenance is conducted in
accordance with the requirements of this document; and

Ensures that nonconformances are reported and corrective actions have
been completed.

A-5e	TRU Waste Certification Official (WCO)

The TRU Waste Certification Official (WCO) performs the following:

Reports to the Manager of Waste Certification and Oversight (WC&O) who
reports to the Manager, Environmental Compliance.

Maintains independence from waste generating organizations.

Reviews and concurs with process and quality controls.

Reviews and approves NDA Qualification Reports.

Serves as a point-of-contact for TRU waste NCRs.

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

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

Certifies by signature that the TRU waste is properly classified,
packaged, marked, labeled, and loaded in the TRUPACT-II package, and
meets WIPP-WAC requirements.

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

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

Reviews and concurs with TRU waste management procedures.

A-5f	Material Stewardship QA Manager

Designates and provides oversight of the TWCP Site PQAO

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

Schedules and conducts assessments of the TRU Waste Program.

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

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

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

Provides for technical guidance for RFETS Waste Inspectors.

Ensures that Waste Inspectors meet responsibilities identified in waste
inspection procedures.

A-5f(1)	Headspace Analytical Services Quality Assurance Officer (HASQAO)

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

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

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

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

Provides quality surveillance of headspace TWCP-related activities.

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

Verifies the implementation of project QA requirements.

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

Initiates, recommends, and tracks corrective actions to closure.

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

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

Ensures that all headspace requirements of the WIPP-WAP and QAPjP have
been met.

A-5g	Remediation, Industrial D&D, and Site Services (RISS)

The RISS organization is supported by the Metrology, Laboratory, and
Analytical Services groups.  The Laboratory group is responsible for the
following:

Provides analytical chemistry services in support of waste
characterization.

Performs the material testing.

Performs the destructive analysis of wastes and radioactive materials.

Appointing the Analytical Laboratories Manager.

A-5g(1)	Analytical Laboratories Manager

NOTE:	Responsibilities for this function may be delegated to subordinate
managers.

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

Ensures that analytical personnel are trained and qualified.

Ensures participation in the PDPs for analytical testing.

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

Coordinates and schedules analytical work to support the TWCP.

Ensures that corrective and preventive actions have been completed.

Reviews and approves all Analytical Laboratory SOPs and reports.

Assigns laboratory staff.

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

Verifies that analytical requirements of the WIPP-WAP and QAPjP have
been met.

A-5g(2)	Analytical Laboratories Project Quality Assurance Officer
(LPQAO)

Directs all of the Analytical Laboratories’ WIPP-related QA
activities.

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

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

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

Provides quality surveillance of analytical laboratory TWCP-related
activities.

Verifies the implementation of project QA requirements.

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

Initiates, recommends, and tracks corrective actions to closure.

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

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

Ensures that all analytical laboratory requirements of the WIPP-WAP and
QAPjP have been met.

A-5h	Building Closure Projects

Manage the generation, packaging, and some characterization operations
for the higher radioactive activity, contact-handled wastes formerly
managed as recyclable residues and newly generated waste. Specific areas
of responsibility supporting the TWCP are listed below.

Management of waste generation and packing operations associated with
TRU waste.

Develop PCPs as applicable to identify specific waste stream Item
Description Codes (IDCs), their physical and chemical characteristics,
and the controls established to ensure consistent production to WIPP
requirements.

Ensuring independent Building Closure Projects Project Quality Assurance
activities are performed.

A-5h(1)	Waste Generators

Properly segregate regulated wastes from each other and from those not
regulated by using procedures and reference information sources that
include:

The WSRIC Building Books

Analytical data

Material Safety Data Sheets (MSDSs)

Documented recommendations from RFETS Waste Characterization SMEs

Knowledge of process materials

WGIs

Provides the physical control of packages before TID sealing using
locking fixtures or enclosures.

Maintain the accuracy of the WSRIC Building Books.

Ensure on-site transfers of waste packages meet the requirements of
RFETS procedures.

Attend required classroom and OJT.

Certify by signature on the W/RT that all waste generated is properly
identified, segregated, and characterized according to applicable
written procedures.

A-5i	INEEL TWCP Responsibilities

The INEEL TWCP conducts solids sampling and analysis of some RFETS waste
according to the Attachment to the SOW for the INEEL TWCP (DOE 2003a).

A-6	Hierarchy of Documents

The following items, found in the TWMM, outline the flowdown
requirements and hierarchy of TWCP programmatic documents:

Section 2.1, CBFO Requirements Documents

Figure 2-1, CBFO Requirements Flowdown Characterization

Figure 2-2, CBFO Requirements Flowdown Certification

Figure 2-3, CBFO Requirements Flowdown Quality Assurance

Correspondingly, Section B5-2, Document Review, Approval, and Control,
of this document, provides a description of the program documents used
for demonstrating compliance to CBFO requirements.  A summary of these
documents is found in the TWMM, Table 2-1, Summary of RFETS Program
Documents.

A-7	Indoctrination and Training

The management of each organization is responsible for ensuring that
personnel assigned to the TWCP from their organization meet the training
requirements stated in the WIPP-WAP.  This is in addition to meeting the
training requirements defined in MAN-131-QAPM, Quality Assurance Program
Manual (QAPM) and implemented in accordance with MAN-094-TPM, Training
Program Manual (TPM).  Implementation of the QAPM and TPM requirements
occurs through prime operating contractor training programs (program
manuals and implementing procedures or instructions).  PLN-97-007, TWCP
Training Implementation Plan (TWCP TIP), specifically addresses the
requirements of the WIPP-WAP and this document for education,
experience, training and qualification of TWCP participants.  The TWCP
TIP includes references to the prime contractor training program
documentation, which implement personnel qualification and training
programs in accordance with the WIPP-WAP, the QAPD, and 10 CFR 830.120.

A TWCP indoctrination class provides TWCP personnel with information on
scope, purpose and objectives of the program, and references information
on specific QAOs for their assigned tasks (for a listing of courses
refer to the TWCP TIP, Appendix 1, TWCP Project Training Matrix, and
Appendix 3, Residues Program Training Matrix).  The TWCP TIP requires
that all assigned personnel complete this indoctrination course.  A
supplemental WIPP-WAP Indoctrination is also required for all personnel
covering the scope, purpose, objectives, and QAOs in the WIPP-WAP.

The TWCP TIP (Section 7.1, Job Analyses and Training Needs Assessments)
requires completion of job analyses (JA) for each job position
responsible for TWCP tasks and activities.  This position JA documents
the assessment of the position description and the functions, tasks,
work processes and procedures involved in the job.  The position JA
yields requirements for the education and experience (E&E) of assigned
personnel and a training needs assessment (TNA) which contains the
training and qualification requirements for the position.  The JA and
TNA are periodically reviewed to identify changes in requirements and
additional necessary training.

A-7	Indoctrination and Training  (continued)

All E&E, training and qualification requirements are documented in the
TWCP TIP appendices by functional area and position.  Management
evaluates the resumes of assigned personnel and personnel who change
positions or are assigned to short-term or temporary work.  Management
documents that they meet the E&E requirements (refer to the TWCP TIP,
Section 7.2, Personnel Selection and Assignment).  Completion of the
training and qualification requirements by TWCP participants is reviewed
by management and the Project Training Officer (refer to the TWCP TIP,
Section 7.4, Administration of Training) to ensure that personnel
maintain proficiency.

The education, experience and specialized training requirements for
headspace gas and laboratory system Operators and Technical Supervisors
as presented in the WIPP-WAP, Table B3-10, Minimum Training and
Qualification Requirements, are covered in the TWCP TIP, Appendix 1,
TWCP Project Training Matrix, which is applicable to Chemical Analysis
personnel.  Other WIPP-WAP requirements for training are discussed in
Sections B1-3b, B3-14, and B4-3a of this document.  Section B1-3b of
this document discusses the RFETS position title and training
requirements for RTR operators pursuant to the WIPP-WAP Table B3-10,
Minimum Training and Qualification Requirements.

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B.	WASTE ANALYSIS PLAN

RFETS disposes of TRU waste (i.e., TRU and TRU-mixed waste) at the WIPP
facility, and has developed this document to comply with the applicable
requirements of the WIPP-WAP and the WIPP Waste Acceptance Criteria
(WIPP-WAC; DOE/WIPP-02-3122).  In this document, the term TRU waste
includes TRU and TRU-mixed waste.

TRU waste is designated and separately packaged as either
contact-handled (CH) or remote-handled (RH), based on the radiological
dose rate at the surface of the waste container.  RH TRU wastes (i.e.,
TRU waste with a surface dose rate of 200 millirem per hour or greater)
will not be shipped to the WIPP facility for disposal.

The hazardous components of the TRU waste to be shipped for disposal at
the WIPP facility from RFETS are designated in the WIPP Hazardous Waste
Permit, Attachment O (NMED 1999).

Retrievably stored waste is defined as TRU waste generated after 1970
and before NMED notifies the WIPP facility, by approval of the final
audit report, that the characterization requirements of the WIPP-WAP
have been implemented appropriately at RFETS.  Newly generated waste is
defined as TRU waste that is generated after NMED approves the final
audit report for RFETS.  Acceptable Knowledge (AK) information is
assembled for both retrievably stored and newly generated waste.
Retrievably stored TRU waste will be characterized on an ongoing basis,
as the waste is retrieved.  Newly generated TRU waste is typically
characterized as it is generated, although some characterization occurs
post generation.  Waste characterization requirements for retrievably
stored and newly generated TRU wastes differ, as discussed in Sections
B-3d(1) and B-3d(2) of this document.

Characterization requirements for individual containers of TRU waste are
specified on a waste stream basis.  A waste stream is defined as waste
material generated from a single process or from an activity that is
similar in material, physical form, and hazardous constituents.  Waste
streams are grouped by Waste Matrix Code Groups that relate to the
physical and chemical properties of the waste.  The Site uses the
characterization techniques described in the WIPP-WAP to assign
appropriate Waste Matrix Code Groups for WIPP disposal.

The Waste Matrix Code Groups are solidified inorganics, solidified
organics, salt waste, soils, lead/cadmium metal, inorganic nonmetal
waste, combustible waste, graphite, filters, heterogeneous debris waste,
and uncategorized metal.  Initially the Waste Matrix Code Groups are
categorized into the three broad Summary Category Groups that are
related to the final physical form of the wastes.  Waste
characterization requirements for these Summary Category Groups are
specified separately in Section B-2 of this document.  Each of the three
broad groups is described below.

S3000 - Homogeneous Solids

Homogeneous solids, or solid process residues, are defined as solid
materials, excluding soil, that do not meet the NMED criteria for
classification as debris (<IP_ADDRESS>0 NMAC (incorporating 40 CFR
§268.2[g] and [h])).  Included in the series of solid process residues
are inorganic process residues, inorganic sludges, salt waste, and
pyrochemical salt waste.  Other waste streams are included in this
Summary Category Group based on the specific waste stream types and
final waste form.  This Summary Category Group is expected to contain
toxic metals and spent solvents.  This category includes wastes that are
at least 50 percent by volume solid process residues.

B.	WASTE ANALYSIS PLAN  (continued)

S4000 - Soils/Gravel

This Summary Category Group includes S4000 waste streams that are at
least 50 percent by volume soil/gravel.  This Summary Category Group is
expected to contain toxic metals.  Soils/gravel are further categorized
by the amount of debris included in the matrix.

S5000 - Debris Wastes

This Summary Category Group includes heterogeneous waste that is at
least 50 percent by volume materials that meet the criteria specified in
<IP_ADDRESS>0 NMAC (incorporating 40 CFR §268.2 (g)).

Debris means solid material exceeding a 2.36 inch (60 millimeter)
particle size that is intended for disposal and that is:

1.	a manufactured object, or

2.	plant or animal matter, or

3.	natural geologic material.

Particles smaller than 2.36 inches in size may be considered debris if
the debris is a manufactured object and if it is not a particle of S3000
or S4000 material.

If a waste does not include at least 50 percent of any given category by
volume, characterization shall be performed using the waste
characterization process required for the category constituting the
greatest volume of waste for that waste stream (see Section B-3d).

Once the required waste characterization is complete, RFETS completes a
WSPF to document the results of their characterization activities (see
Section B-1d).  The WSPFs and the Characterization Information Summary
for the waste stream resulting from waste characterization activities
are transmitted to the WIPP facility, reviewed for completeness, and
screened for acceptance prior to loading any TRU waste into the Contact
Handled Packaging as described in  Section B-4.  Only TRU waste that has
been characterized in accordance with this document and that meets the
Treatment Storage Disposal Facility Waste Acceptance Criteria (TSDF-WAC)
of the WIPP Hazardous Waste Permit  is shipped to the WIPP facility for
disposal.

If WIPP requests detailed information on a waste stream, RFETS will
provide a Waste Stream Characterization Package (Section B3-12b(3)).
For each waste stream, this package will include the WSPF, the
Characterization Information Summary, and the complete AK summary.  The
Waste Stream Characterization Package will also include specific Batch
Data Reports and raw analytical data associated with waste container
characterization as requested by WIPP.

B-1	Identification of TRU Waste to be Managed at the WIPP Facility

B-1a	Waste Stream Identification

TRU waste destined for disposal at WIPP is characterized on a waste
stream basis.  RFETS delineates waste streams using acceptable
knowledge.  Required acceptable knowledge is specified in Section B-3b
and Section B4 of this document.  If acceptable knowledge for
retrievably stored waste does not comply with these requirements (e.g.,
heterogeneous Debris Waste in Summary Category S5000), the waste is
reexamined (and characterized) in the same manner as newly generated
waste.

All of the waste within a waste stream may not be available for sampling
and analysis at one time.  In these instances, the waste streams may be
divided into waste stream lots based on staging, transportation, or
handling issues.  Characterization activities are then undertaken on a
waste stream lot basis.  A WSPF need not be submitted for subsequent
waste stream lots unless warranted by the characterization information.

B-1b	Waste Summary Category Groups and Hazardous Waste Accepted at the
WIPP Facility

Once a waste stream has been delineated, a Waste Matrix Code is assigned
to the waste stream based on the physical form of the waste.  Waste
streams are then assigned to one of three broad Summary Category Groups:
S3000-Homogeneous Solids, S4000-Soils/Gravel, and S5000-Debris Wastes.
These Summary Category Groups are used to determine further
characterization requirements.

RFETS ships only those TRU waste streams which have EPA Hazardous Waste
Codes already listed on the WIPP Hazardous Waste Permit, Attachment O
(NMED 1999).  If during the characterization process, new Hazardous
Waste Codes are identified, those wastes will not be shipped for
disposal to the WIPP facility until the code is added to the permit
(refer to the TWMM, Section 5.5.2, Hazardous Waste, and Section <IP_ADDRESS>,
Methods of Compliance; 1-PRO-087-WEMS-WP-1201, WEMS Waste Package
Inventory, Tracking and Control; and 4-G83-WEM-WP-1209, WEMS Waste
Package Verification and Certification).

B-1c	Waste Prohibited at the WIPP Facility

The following TRU waste are prohibited at WIPP and therefore these
wastes will not be shipped to the WIPP facility for disposal:

Liquid waste (waste shall contain as little residual liquid as is
reasonably achievable by pouring, pumping and/or aspirating, and
internal containers shall contain less than 1 inch or 2.5 centimeters of
liquid in the bottom of the container.  Total residual liquid in any
payload container (e.g., 55-gallon drum or standard waste box) may not
exceed 1 percent volume of that container.  Payload containers with U134
waste shall have no detectable liquid).  Refer to the TWMM, Section
5.4.1, Residual Liquids; and Section B4-3b(3) of this document.

Non-radionuclide pyrophoric materials (refer to the TWMM, Section 5.5.1,
Pyrophoric Materials; and Section B4-3b(3) of this document).

Hazardous wastes not occurring as co-contaminants with TRU waste
(non-mixed hazardous waste).  Refer to the TWMM, Section 5.5.2,
Hazardous Waste; and Section B4-3b(3) of this document.

Wastes incompatible with backfill, seal and panel closures materials,
container and packaging materials, shipping container materials, or
other wastes (refer to the TWMM, Section 5.5.3, Chemical Compatibility;
and Section B4-3b(3) of this document).

B-1c	Waste Prohibited at the WIPP Facility  (continued)

Wastes containing explosives or compressed gases (refer to the TWMM,
Section 5.5.4, Explosives, Corrosives, and Compressed Gases; and Section
B4-3b(3) of this document).

Wastes with polychlorinated biphenyls (PCBs) not authorized under an EPA
PCB waste disposal authorization.  (Refer to the TWMM, Section 5.5.6,
Polychlorinated Biphenyls; and Section B4-3b(3) of this document).

Wastes exhibiting the characteristic of ignitability, corrosivity, or
reactivity (EPA Hazardous Waste Numbers of D001, D002, or D003).  Refer
to the TWMM, Section 5.5.2; 1-PRO-087-WEMS-WP-1201, WEMS Waste Package
Inventory, Tracking, and Control; 4-G83-WEM-WP-1209, WEMS Waste Package
Verification and Certification; Section B1-b of this document; and
Section B4-3b(3) of this document.

RH TRU waste (waste with a surface dose rate of 200 millirem per hour or
greater).  Refer to the TWMM, Section 5.3.5, Radiation Dose Rate; and
Section B4-3b(3) of this document.

Any waste container that does not have VOC concentration values reported
for the headspace (refer to Section B-3a(1) of this document and to the
TWMM, Section 5.5.5, Headspace Gas Concentrations; and Section 5.6, Data
Package Contents).

Any waste container which has not undergone either radiographic
examination or VE (refer to Section B-3c and Section B1-3 of this
document).

Any waste container from a waste stream which has not been preceded by
an appropriate, certified WSPF (refer to Section B-1d of this document
and PRO-944-WIPP-008, Completion of Waste Stream Profile Form for Waste
to be Disposed of at WIPP).

RTR, visual examination to confirm RTR, and visual verification are all
techniques used to confirm acceptable knowledge that prohibited waste is
not present in waste containers to be shipped to WIPP.  This
confirmation is accomplished by examining the waste container contents
for the following:

Specific prohibited waste items (such as free liquid and compressed
gases) that are readily discernable upon examination, and

Conditions/items that would indicate the presence of prohibited waste
items that cannot be readily discerned by examination.  For example:

Compliance with the prohibition for waste exhibiting the characteristic
of ignitability, corrosivity, or reactivity is verified if the
examination does not detect free liquids or conditions which would
indicate that abnormal reactions are occurring (e.g., bulging
containers).

Compliance with the requirement that the packaged waste be compatible
with the packaging material, shipping container, backfill, etc. is
established by verification of compliance with the TRUCON Code.

B-1c	Waste Prohibited at the WIPP Facility  (continued)

Final characterization of a waste is done in conjunction with acceptable
knowledge confirmation.

Before shipping a container holding TRU waste to the WIPP facility,
RFETS examines the RTR or VE data records (refer to Section B-4 and
Section B1-3) to verify that the container holds no unvented compressed
gas containers and that residual liquid does not exceed 1 percent volume
in any payload container.  If discrepancies or inconsistencies are
detected during the data form review, the RTR audio/videotape or the VE
(to Confirm RTR) audio/videotape are reviewed to verify that the
observed physical form of the waste is consistent with the waste stream
description provided by the generator and to ensure that no prohibited
items are present in the waste.  Section B-4 includes a description of
the waste verification process that is conducted prior to shipping waste
to the WIPP facility.

Containers are vented through carbon composite particulate filters or
filters with equivalent VOC dispersion characteristics.  This venting
allows any gases that are generated by radiolytic and microbial
processes within a waste container to escape, thereby preventing over
pressurization or development of conditions within the container that
would lead to the development of ignitable, corrosive, reactive, or
other characteristic wastes (refer to the TWMM, Section 5.2.7, Filter
Vents).

To ensure the integrity of the WIPP facility, waste streams identified
to contain incompatible materials or materials incompatible with waste
containers are not shipped to WIPP until after they have been treated to
remove the incompatibility.  Only those waste streams that are
compatible or have been treated to remove incompatibilities are shipped
to WIPP (refer to the TWMM, Section 5.5.3, Chemical Compatibility; and
Section B4-3b(3) of this document).

The VOC concentrations in the headspace of waste containers have been
limited to those which, when averaged on a room basis, will ensure
compliance with the performance standards.  These limits apply at the
WIPP facility but do not apply to RFETS, and are presented in Table B-2,
Maximum Allowable VOC Room-Averaged Headspace Concentration Limits, as
maximum allowable VOC room-averaged headspace concentration limits.
There are no maximum allowable headspace gas concentration limits for
individual containers, as some containers can exceed these values as
long as container headspace averages in a disposal room do not.  At
RFETS, a container which has been analyzed and is reported to contain
higher VOC concentrations than the averaged limits specified in Table
B-2 may be approved for disposal by the WIPP M&O Contractor on a
case-by-case basis.  Approval for containers exceeding the averaged
limits will be done through the WIPP Waste Information System (WWIS)
exception process (refer to the TWMM, Section 5.5.5, Headspace Gas
Concentrations).

B-1d	Control of Waste Acceptance

Every waste stream shipped to WIPP is preceded by a WSPF (Figure B-1).
The required WSPF information and the Characterization Information
Summary elements are found in Section B3-12b.

RFETS provides the WSPF and the Characterization Information Summary for
each waste stream to the WIPP facility for acceptance prior to shipping
the waste (refer to PRO-944-WIPP-008, Completion of Waste Stream Profile
Form for Waste to be Disposed of at WIPP).  When requested by CBFO,
RFETS will provide a Waste Stream Characterization Package as described
in Section B3-10b(4).  If continued waste characterization reveal
discrepancies that identify different hazardous waste codes or indicates
that the waste belongs to a different waste stream, the waste is
redefined to a separate waste stream and a new WSPF is submitted.

B-1e	Waste Generating Processes at the WIPP Facility (termed “derived
waste”)

The requirements contained in Attachment B-1e of the WIPP-WAP are
specific to the WIPP facility.  Therefore these requirements have not
been addressed in this document.

B-2	Waste Parameters

The following waste analysis parameters are characterized at RFETS:

Confirmation of physical form and exclusion of prohibited items
specified in Section B-1c.

Toxicity characteristic contaminants listed in <IP_ADDRESS> NMAC
(incorporating 40 CFR, §261.24), Table 1 (excluding pesticides), as
specified in the WIPP Hazardous Waste Permit, Attachment O (NMED 1999).

F-listed and P-listed solvents or waste (F001, F002, F003, F004, F005,
F006, F007, F009, P015) found in <IP_ADDRESS> NMAC (incorporating 40 CFR
§261.31).

Hazardous constituents included in <IP_ADDRESS> NMAC (incorporating 40 CFR
§261) Appendix VIII as specified in Tables B-1, B-3 and B-4, as well as
any other hazardous constituent identified through acceptable knowledge.

Tables B-1, B-3, B-4 and B-5 provide the parameters of interest for the
various constituent groupings and analytical methodologies.  The
following sections provide a description of the acceptable methods to
evaluate these parameters for each Summary Category Group.

B-3	Characterization Methods

The characterization techniques used by RFETS include acceptable
knowledge, which incorporates confirmation by headspace gas sampling and
analysis; RTR; VE; and homogeneous waste sampling and analysis.  All
confirmation characterization activities are performed in accordance
with the WIPP-WAP.  Table B-6, Summary of Parameters, Characterization
Methods, and Rationale for CH Transuranic Waste,  provides a summary of
the characterization requirements for TRU waste.

TRU waste is characterized either in lots or in batches (i.e., sampling
batch, analytical batch, or on-line batch).  Refer to Section E-2 for a
definition of these terms, and refer to Section B3 for additional
clarification regarding the expected contents of Batch Data Reports.

Coring, solid sampling, and analysis of some RFETS waste is conducted at
INEEL.  These confirmation activities are conducted in accordance with
the WIPP-WAP as described in the Attachment to the SOW for the INEEL
TWCP (DOE 2003a).

B-3a	Sampling and Analytical Methods

B-3a(1)	Headspace Gas Sampling and Analysis

Headspace gas samples are used to determine the types and concentrations
of VOCs in the void volume of waste containers.  VOC constituents will
be compared to those assigned by acceptable knowledge and hazardous
waste codes will be assigned as warranted.  The comparison will consider
radiolysis when assessing the presence of listed waste, and whether
radiolysis would generate waste which exhibits the toxicity
characteristic.  TRU mixed waste containers or statistically selected
containers from waste streams that meet the conditions for reduced
headspace gas sampling listed in this section are sampled and analyzed
to determine the concentrations of VOCs (presented in Table B-3) in
headspace gases.  If composite samples are used, containers used in the
composite sample are from the same waste stream with no more than 20
containers included in a single composite sample.  Sampling protocols,
equipment, and QA/QC methods for headspace gas sampling are provided in
Section B1 of this document.  In accordance with EPA convention,
identification of hazardous constituents detected by gas
chromatography/mass spectrometry methods that are not on the list of
target analytes are reported.  These compounds are reported as
tentatively identified compounds (TICs) in the analytical batch data
report and are added to the target analyte list if detected in a given
waste stream, if they appear in the <IP_ADDRESS> NMAC (incorporating 40
CFR §261) Appendix VIII, and if they are reported in 25% of the waste
containers sampled from a given waste stream.  This site-specific
procedure which addresses adding TICs to the target analyte list is
PRO-944-WIPP-008, Completion of Waste Stream Profile Form for Waste to
be Disposed of at WIPP.  The headspace gas analysis Quality Assurance
Objectives (QAOs) are specified in Section B3 of this document.

B-3a(1)(i)	Reduced HSG Sampling Requirements for Homogeneous Solid or
Soil/Gravel Waste Streams with no VOC-related Hazardous Waste Codes

Headspace gas VOCs that do not exceed the PRQLs in Table B3-2 are not
significant and do not impact the acceptable knowledge confirmation,
assignment of additional hazardous waste codes, or worker/public health.
 Headspace gas samples that do not exceed the PRQLs are not significant
to the activities that use the results of headspace gas sampling defined
in the WIPP Hazardous Waste Permit.  Therefore, 100% headspace gas
sampling of homogeneous solid and soil/gravel wastes that have no
VOC-related hazardous waste codes assigned is unnecessary and does not
provide additional protection of human health and the environment.  Such
waste streams may qualify for reduced headspace sampling if they meet
certain criteria.

In order for a waste stream to qualify for reduced headspace gas
sampling, the waste stream or waste stream lot must consist of more than
10 containers and the following conditions must be met:

The waste stream must be a homogeneous solid or soil/gravel waste stream
that has no VOC-related hazardous waste codes assigned to it.

The results of the solid sampling and analysis must confirm that no
VOC-related hazardous waste codes should be assigned to the waste
stream.

If a waste stream meets these conditions for reduced headspace gas
sampling, RFETS may choose to randomly select containers for headspace
gas sampling and analysis using the statistical approach described in
Section B2-2b.

B-3a(1)(ii)	Reduced HSG Sampling Requirements for Thermally Processed
Waste Streams

The potential sources of VOCs in the headspace of TRU waste containers
are:  the matrix, the packaging, and the byproducts of radiolysis.  If
the waste matrix contains no significant VOCs due to high-temperature
thermal processes, the contribution from each of these potential sources
can be quantified without the use of 100% headspace gas sampling, while
maintaining data quality sufficient for the purposes specified in the
WIPP Hazardous Waste Permit.  If the waste matrix contains no
significant VOCs because high-temperature thermal processes were used in
generating the waste or the waste was subject to high-temperature
thermal processes, then any significant concentrations of VOCs measured
in the headspace gas will likely not have originated from the waste
matrix.

Consequently, the only remaining sources for VOCs present in the
headspace gas are the packaging and the byproducts of radiolysis.
Hazardous waste codes are not assigned based on headspace gas VOCs that
are the result of packaging or radiolysis.  It is not necessary to
sample 100% of the containers for headspace gas VOCs to establish a
representative concentration of VOCs present in the headspace gas due to
packaging and radiolysis.  Such waste streams may qualify for reduced
headspace sampling if they meet certain criteria.

In order for a waste stream to qualify for reduced headspace gas
sampling, the waste stream or waste stream lot must consist of more than
10 containers and the following conditions must be met:

The waste stream must have either been generated using a
high-temperature thermal process or been subjected to a high-temperature
thermal process after generation that resulted in the reduction of
matrix-related VOCs in the headspace to concentrations below the PRQLs
listed in Table B3-2.

The site must have documentation demonstrating that high-temperature
thermal processes were used.

If a waste stream meets these conditions for reduced headspace gas
sampling, RFETS may choose to randomly select containers for headspace
gas sampling and analysis using the statistical approach described in
Section B2-2b.

B-3a(2)	Homogeneous Waste Sampling and Analysis

Sampling of homogeneous and soil/gravel wastes results in the collection
of a sample that is used to confirm hazardous waste code assignment by
acceptable knowledge.  Sampling is accomplished through core or other
EPA approved sampling, which is described in Section B1 of this
document.  For those waste streams defined as Summary Category Groups
S3000 or S4000, debris that may also be present within these wastes need
not be sampled.   The waste containers for sampling and analysis are
selected randomly from the population of containers for the waste
stream.  The random selection methodology is specified in Section B2-2
of this document.

As appropriate, Totals or Toxicity Characteristic Leaching Procedure
(TCLP) analyses for VOCs, SVOCs, and RCRA-regulated metals (refer to
Table B-4 and Table B-5) are used to determine waste parameters in
soils/gravels and solids that may be important to the performance within
the disposal system.  To determine if a waste exhibits a toxicity
characteristic for compounds specified in <IP_ADDRESS> NMAC (incorporating
40 CFR §261, Subpart C), TCLP may be used instead of total analyses.
The results from these analyses are used to determine if a waste
exhibits a toxicity characteristic.  The mean concentration of toxicity
characteristic contaminants is calculated for each waste stream such
that it can be reported with an upper 90 percent confidence limit
(UCL90).  The UCL90 values for the mean measured contaminant
concentrations in a waste stream are compared to the specified
regulatory levels in <IP_ADDRESS> NMAC (incorporating 40 CFR §261,
Subpart C), expressed as total/TCLP values, to determine if the waste
stream exhibits a toxicity characteristic.  A comparison of total
analyses and TCLP analyses is presented in Appendix C3 of the WIPP RCRA
Part B Permit Application (DOE 1997a), and a discussion of the UCL90  is
included in Section B2 of this document.  If toxicity characteristic
(TC) wastes are identified, these will be compared to those determined
by acceptable knowledge and TC waste codes will be revised, as
warranted.  Refer to Section B4 of this document for additional
clarification regarding hazardous waste code assignment and homogeneous
solid and soil/gravel analytical results.

B-3a(3)	Laboratory Qualification

RFETS conducts analyses using laboratories and equipment that are
qualified through participation in the Performance Demonstration Program
(DOE 1999a and DOE 1999b).  Required QAOs are specified in Section B3 of
this document.

Analytical methods used by Headspace Analytical Services and the
Analytical Laboratories: 1) satisfy all of the appropriate QAOs, and
2) are implemented through standard operating procedures.  These
analytical QAOs are discussed in detail in Section B3 of this document.

As described in the Attachment to the SOW for the INEEL TWCP (DOE
2003a), the INEEL TWCP laboratories are qualified through participation
in the Performance Demonstration Program and analytical methods used
satifisfy all appropriate QAOs through implementation of standard
operationg procedures.

B-3b	Acceptable Knowledge

Acceptable knowledge (AK) is used in TRU waste characterization
activities in three ways:

To delineate TRU waste streams.

To assess whether TRU heterogeneous debris wastes exhibit a toxicity
characteristic [New Mexico Hazardous Waste Management Regulations in
Title20 New Mexico Administrative Code, Chapter 4, Part 1, Section 200
(<IP_ADDRESS> NMAC), incorporating 40 CFR §261.24].

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

Acceptable knowledge is discussed in detail in Section B4 of this
document, which outlines the minimum set of requirements that are met by
RFETS in order to use acceptable knowledge.

B-3c	Radiography and Visual Examination

Real-Time Radiography (RTR) is a nondestructive qualitative and
quantitative technique that involves X-ray scanning of waste containers
to identify and verify waste container contents.  Visual examination
(VE) constitutes opening a container and physically examining its
contents.  At RFETS there are three specific reasons for utilizing VE as
follows:

VE performed to confirm RTR: VE that is performed as a confirmation of
RTR data requires audio/videotaping.  This VE is performed on a
statistically selected subpopulation of waste containers that have
already undergone RTR (refer to Section B2-1 for a discussion of the
statistical selection of these waste containers).

VE performed in lieu of RTR: VE that is performed in lieu of RTR
requires audio/videotaping.  (VE in lieu of RTR is not currently
conducted at RFETS.)

VE performed as a visual verification of acceptable knowledge.  This VE
is referred to as the VE Technique in the WIPP-WAP, and at RFETS this is
commonly known as Visual Verification (VV): VE that is performed for
newly generated waste or when repackaging retrievably stored waste does
not require audio/videotaping.

For Repackaged Retrievably Stored Waste from Residues Projects
(characterized by VE), the VV activity requires two operators.  The
first operator confirms 1) that the physical form of the waste agrees
with the assigned IDC, the Waste Stream description, the Waste Matrix
Code (includes Summary Category Group), the Waste Material Parameter,
and the TRUCON Code, and 2) confirms that the waste does not contain
prohibited items.  The second operator, who is equally trained to the
requirements, provides real-time verification of the waste by reviewing
the contents of the waste container as the container is being packaged.
The results are recorded on the Visual Verification and Packaging Data
Form, and a Visual Verification Batch Report is prepared as detailed in
Section B3-10 and Table B3-11 (for procedures refer to Table B-1,
Physical Waste Form – Repackaging of Retrievably Stored Waste).

B-3c	Radiography and Visual Examination  (continued)

For Newly Generated Waste (characterized by VE), such as D&D waste, and
Repackaged Retrievably Stored Waste the VV activity requires a waste
originator and a waste validator.  The waste originator confirms 1) that
the physical form of the waste agrees with the assigned IDC, the Waste
Stream description, the Waste Matrix Code (includes Summary Category
Group), the Waste Material Parameter, and the TRUCON Code, and 2)
confirms that the waste does not contain prohibited items. The waste
validator, who is equally trained to the requirements, provides
real-time verification of the waste by reviewing the contents of the
waste container as the container is being packaged.  The waste container
contents, the date of the visual verification, the signature of the
Waste Originator, and the signature of the Waste Validator are
documented on the TRU/TRM Waste Visual Verification and Packaging Log
Sheet (refer to PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification
(VV) and Data Review).  A Visual Verification Batch Report is prepared
as detailed in Section B3-10 and Table B3-11 according to
PRO-1031-WIPP-1112, TRU/TRM Waste Visual Verification (VV) and Data
Review.

RTR and/or VE are used to examine every waste container to verify its
physical form.  These techniques can detect liquid wastes and
containerized gases, which are prohibited for WIPP disposal.  The
prohibition of liquids and containerized gases prevents the shipment of
corrosive, ignitable, or reactive wastes.

RTR and/or VE are also used to confirm that the physical form of the
waste matches its waste stream description (i.e., Homogeneous Solids,
Soil/Gravel, or Debris Waste [including uncategorized metals]).  If the
physical form does not match the waste stream description, the waste is
designated as another waste stream and assigned the preliminary
hazardous waste codes associated with that new waste stream assignment.
That is, if RTR and/or VE indicate that the waste does not match the
waste stream description arrived at by acceptable knowledge
characterization, a waste nonconformance report (WNCR) is completed and
the inconsistency is resolved as specified in Section B4 of this
document.  The proper waste stream assignment is determined (including
preparation of a new WIPP WSPF when necessary), the correct hazardous
waste codes are assigned, and the resolution is documented.  Refer to
Section B4 of the QAPjP for a discussion of acceptable knowledge and its
confirmation process.

RFETS may conduct VE of waste containers in lieu of RTR.  If TWCP
chooses to use VE in lieu of RTR, the detection, through shaking, of any
liquid waste in non-transparent inner containers is handled by assuming
that the container is filled with liquid and adding this volume to the
total liquid in the payload container (e.g., 55-gallon drum or SWB).
The payload container would then be rejected and/or repackaged to
exclude the container if it does not meet the requirements of Section
B-1c of this document.

When RTR is used, or VE of transparent containers is performed, if any
liquid in inner containers is detected, the volume of liquid is added to
the total for the payload container.  RTR is normally used on the
existing/stored waste containers to verify that the physical
characteristics of the TRU waste correspond with its waste stream
identification/waste stream Waste Matrix Code, and to identify
prohibited items.  However, where RTR is ineffective, VE is performed.

RTR results are confirmed through the use of VE.  In this case, VE is
performed on a statistically selected subpopulation of TRU waste
containers in each TRU waste summary category group as specified in
Section B2-1 of this document.  Radiographic examination protocols and
QA/QC methods are provided in Section B1 of this document.

B-3d	Characterization Techniques and Frequency for Newly Generated and
Retrievably Stored Waste

RFETS uses acceptable knowledge to delineate all TRU waste containers
into waste streams for the purposes of grouping waste for further
characterization.  The analyses performed does not differ based on the
waste stream, only on the physical form of the waste (i.e.,
heterogeneous debris waste cannot be sampled for totals analyses).  Both
retrievably stored and newly generated wastes are delineated in this
fashion, though the types of acceptable knowledge used may differ.
Section B-3b discusses the use of acceptable knowledge, sampling, and
analysis in more detail.  Acceptable knowledge is discussed more
completely in Section B4.  Every waste stream will be assigned hazardous
waste codes based upon acceptable knowledge, and these hazardous waste
codes are confirmed using headspace gas (all Summary Category Groups)
and solid sampling and analysis (Summary Category Groups S3000 and S4000
only).

RTR and/or VE are used to verify the physical form of retrievably stored
TRU waste.  For newly generated waste and for repackaged retrievably
stored waste, the physical form of the waste and absence of prohibited
items are either verified during packaging (using Visual Verification,
refer to Section B-3c) or are verified after packaging using radiography
(or VE in lieu of radiography).  RFETS may use either VV or radiography,
separately or together, as long as 100 percent of the containers undergo
confirmation of AK.  RTR and/or VE are also used in conjunction with
acceptable knowledge to characterize heterogeneous debris wastes.  RTR
and/or VE, and the associated information compiled from acceptable
knowledge (e.g., age of the waste, generating process) are used to
determine the RCRA-regulated constituents present in the waste.  VE, VV,
and/or radiography are performed prior to any treatment designed to
supercompact waste prior to shipment.

All waste containers (retrievably stored and newly generated) or
randomly selected containers from waste streams that meet the conditions
for reduced headspace gas sampling listed in Section B-3a(1) are sampled
and analyzed for VOCs in the headspace gas.  A statistically selected
portion of each homogeneous solids and soil/gravel waste stream is
sampled and analyzed for RCRA-regulated total VOCs, SVOCs, and metals
(see Section B2-2).  Sampling and analysis methods used for waste
characterization are discussed in Section B-3a.

B-3d	Characterization Techniques and Frequency for Newly Generated and
Retrievably Stored Waste (continued)

In the process of performing organic headspace and solid sample
analyses, nontarget compounds may be identified.  These compounds are
reported as TICs.  TICs reported in 25% of the samples and listed in
<IP_ADDRESS> NMAC (incorporating 40 CFR §261) Appendix VIII, are compared
with acceptable knowledge data to determine if the TIC is in a listed
hazardous waste in the waste stream (refer to PRO-944-WIPP-008,
Completion of Waste Stream Profile Form for Waste to be Disposed of at
WIPP, and 4-H19-WSRIC-001, WSRIC Characterization and Reverification).
TICs identified through headspace gas analyses that meet the Appendix
VIII list criteria and the 25 percent reporting criteria for a waste
stream are added to the headspace gas waste stream target list,
regardless of the hazardous waste listing associated with the waste
stream.  TICs subject to inclusion on the target analyte list that are
toxicity characteristic parameters are added to the target analyte list
regardless of origin because the hazardous waste designation for these
codes is not based on source.  However, for toxicity characteristic and
non-toxic F003 constituents, RFETS may take concentration into account
when assessing whether to add a hazardous waste code.  TICs reported
from the Totals VOC or SVOC analyses may be excluded from the target
analyte list for a waste stream if the TIC is a constituent in an
F-listed waste whose presence is attributable to waste packaging
materials or radiolytic degradation from acceptable knowledge
documentation.  Refer to Section B3 for additional information on TIC
identification.  If the TIC associated with a total VOC or SVOC analysis
cannot be identified as a component of waste packaging materials or as a
product of radiolysis, RFETS will add these TICs to the list of
hazardous constituents for the waste stream and assign additional EPA
listed hazardous waste codes if appropriate.  RFETS will notify the
INEEL TWCP and CBFO for the addition of TICs to the target list for
RFETS waste sampled and analyzed at INEEL.  For toxicity characteristic
compounds and non-toxic F003 constituents, RFETS may consider waste
concentration when determining whether to change a hazardous waste code.

Waste characterization solid sampling and analysis activities may differ
for retrievably stored waste and newly generated waste.  The waste
characterization data collection design for each type of waste is
described in the following sections.  Table B-1 provides a summary of
hazardous waste characterization requirements for all TRU waste by waste
characterization parameters.

Table B-6 summarizes the parameters, methods, and rationales for stored
and newly generated CH TRU wastes according to their waste forms.

It is acceptable to ship TRU waste which has been repackaged or treated
to the WIPP facility.  Repackaged or treated waste undergoes
characterization required of newly generated waste except that solids
sampling for repackaged or treated S3000 waste may be characterized as
retrievably stored waste if RFETS demonstrates that control charting
cannot be applied effectively to the repackaging or treatment process.
Repackaged waste also undergoes headspace gas analysis, and payload
container headspace is sampled after repackaging, as long as the
criteria specified in Section B1-1 are met.  Treated waste retains the
original waste stream's listed hazardous waste code designation.

B-3d(1)	Newly Generated Waste

The RCRA-regulated constituents in newly generated wastes are documented
at the time of generation based on acceptable knowledge for the waste
stream.  Newly generated TRU waste characterization begins with the
verification that the processes generating the waste have operated
within established written procedures.  Waste containers are delineated
into waste streams using acceptable knowledge.  Visual verification (VV)
that the physical form of the waste (Summary Category Group) corresponds
to the physical form of the assigned waste stream is accomplished either
during packaging (refer to Section B-3c, bullet number 3, for detailed
information on VV) or by performing radiography as specified in Section
B1-3 for retrievalby stored waste.  RFETS may use either VV or
radiography, separately or together, as long as100 percent of the
containers undergo confirmation of AK.

This VV activity consists of the operator confirming that the waste is
assigned to a waste stream that has the correct Summary Category Group
for the waste being packaged.  If a confirmation cannot be made,
corrective actions will be taken as specified in Section B3 of this
document.  A second operator, who is equally trained to the requirements
stipulated in Section B1of this document, provides additional
verification by reviewing the contents of the waste container to ensure
correct reporting.  If the second operator cannot provide concurrence,
corrective actions are taken as specified in Section B3.  The subsequent
waste characterization activities depend on the assigned Summary
Category Group, since waste within the Homogeneous Solids and
Soils/Gravel Summary Category Groups is characterized using different
techniques than the waste in the Debris Waste Summary Category Group.
The packaging configuration, type and number of filters, and rigid liner
vent hole presence and diameter necessary to determine the appropriate
drum age criteria (DAC) in accordance with Section B1-1, is documented
as part of the characterization information collected during packaging
of newly generated waste or repackaging of retrievably stored waste.
The rigid liner vent hole diameter for newly generated waste has been
established as 0.75-inch based on RFETS procurement specifications (see
SPEC-11170-0485 and ELD-057-01).  If retrievably stored waste is
characterized in the same manner as newly generated waste due to
unacceptable AK (see Section B-1a), the option to perform radiography in
lieu of or in combination with VV does not apply.

All containers of newly generated waste or newly generated waste
containers randomly selected from waste streams that meet the conditions
for reduced headspace gas sampling listed in Section B-3a(1) will
undergo headspace gas analysis for VOC concentrations prior to shipment.
 If RFETS believes that the HSG sampling and analysis frequency can be
reduced in the future based on trends in analytical results, they may
provide technical arguments for such reduction to WIPP and request that
WIPP consider the preparation of a permit modification.  The headspace
gas sampling method is provided in Section B1.  Headspace gas data is
used to confirm acceptable knowledge waste characterization, as
specified in Section B4.

B-3d(1)(a)	Sampling of Newly Generated Homogeneous Solids

Newly generated mixed waste streams of homogeneous solids are randomly
sampled a minimum of once per year for total VOCs, SVOCs, and metals, as
applicable.  An initial ten-sample set, however, is collected to develop
the baseline control chart.  Sampling frequency of once per year is only
allowed if a process has operated within procedurally established bounds
without any process changes or fluctuations which would result in either
a new waste stream or the identification of a new hazardous waste
constituent in that waste stream.  Otherwise, the waste is considered as
process batches and each batch undergoes sampling and analysis.

B-3d(1)(a)	Sampling of Newly Generated Homogeneous Solids (continued)

Process changes and process fluctuations are determined using
statistical process control charting techniques; these techniques
require the ten-sample set and historical data for determining limits
for indicator species and subsequent periodic sampling to assess process
behavior relative to historical limits.

If the limits are exceeded, the waste stream is recharacterized, and the
characterization is performed according to procedures required for
retrievably stored waste (i.e., waste sampling frequency will be
increased).  The process for control charting technique is described in
Section B2-4 of this document.

Also, as another control of waste generated from a particular process,
the bounds for a waste generating process are established by specific
written procedures for that process.  Examples of parameter bounds that
could affect a waste generated by a process are volumes of input
material, change in the input material, and any other changes that would
change the output of that process.

RFETS procedures used to control waste generating processes contain the
following information:

Responsible organizations for implementing the requirements of the
procedure

Material inputs

Waste streams generated

Process controls and range of operation (bounds) that affect final
hazardous waste determinations

Rate and quantity of hazardous waste generated

List of applicable operating procedures relevant to the hazardous waste
determination

Events where procedurally established bounds are exceeded or any
condition of normal operation is not being met could trigger an
increased sampling frequency of a waste stream.  As long as a process
does not change outside of established bounds within a year, the waste
generated by that process has the same characteristics, and therefore, a
minimum of one sample is collected annually to verify the lack of
variability of that waste stream.

To date, no waste streams have been identified for which control
charting is appropriate.  When and if a waste stream is identified for
which control charting is appropriate, the records generated by the
process procedures will be examined weekly for indications of process
changes or limits being exceeded that would change the hazardous waste
constituents identified in the waste stream or that would add relevant
prohibited materials.  If process changes are discovered, RFETS will not
ship any additional waste from the waste stream until a follow-up sample
is collected and analyzed to assess whether the waste has the same
characteristics identified on the WSPF.  If RFETS changes a process but
determines that increased sampling is not required because the change
will not affect waste generated by that process, RFETS notifies the WIPP
facility in the form of a memorandum to the CBFO Waste Characterization
Manager.  The WIPP facility will concur with the decision to not
increase the sampling frequency before any additional waste from that
process is shipped.

B-3d(1)(b)	Sampling of Newly Generated Soils/Gravels

The toxicity characteristics of newly generated soils/gravel waste
streams are determined using total analysis of toxicity characteristic
contaminants or TCLP.  To determine if a waste exhibits a toxicity
characteristic for compounds specified in <IP_ADDRESS> NMAC (incorporating
40 CFR §261, Subpart C), TCLP may be used instead of total analyses.
The sampling methods for homogeneous solids and soil/gravel wastes are
provided in Section B1.

Newly generated soils/gravel waste is generated primarily by remediation
or decontamination and decommissioning (D&D) activities.  Process
controls for these types of waste cannot readily be defined and,
therefore, sampling cannot follow that used for newly generated
homogeneous waste.  The number of newly generated soils/gravel waste
containers to be sampled is determined using the procedure specified in
Section B-3a(2), wherein a statistically selected portion of the waste
is sampled.  RFETS estimates the number of containers to be sampled
within the waste stream based on the expected volume of the waste stream
and whether SWB or 55-gallon drums will be used.  Refer to Section B2 of
this document for additional information.

B-3d(2)	Retrievably Stored Waste

All retrievably stored waste containers are first delineated into waste
streams using acceptable knowledge.  All retrievably stored waste
containers are examined using RTR to confirm the physical waste form
(Summary Category Group), to verify the absence of prohibited items, and
to determine the waste characterization techniques to be used based on
the Summary Category Groups (i.e., S3000, S4000, S5000).  Repackaged
retrievably stored waste, or any retrievably stored waste with
inadequate acceptable knowledge, is characterized using either the
retrievably stored or newly generated waste characterization process,
whichever results in greater sampling requirements, unless it is
demonstrated that control charting cannot be applied effectively.
Solids sampling for repackaged or treated S3000 waste may be
characterized as retrievably stored waste if RFETS demonstrates that
control charting cannot be applied effectively to the repackaging or
treatment process.  This determination is documented on the
Characterization Information Summary for the waste stream and is
examined by WIPP during audits.  In this case, the minimum number of
solids samples required for any S3000 waste stream or waste stream lot
is the number of samples determined in accordance with Section B2-2a.
Radiographic results are compared to acceptable knowledge results to
ensure correct Waste Matrix Code assignment and identification of
prohibited items.  If radiographic analysis does not confirm the
physical waste form, waste is reassigned as specified in Section B-3c.
RFETS may elect to substitute VE for radiographic analysis.

To confirm the results of RTR, a statistically selected number of the
TRU waste container population undergoes VE by opening containers to
inspect waste contents to verify RTR results.  Section B2-1 contains the
approach used to statistically select the number of containers to
undergo VE.  For homogeneous waste and soils/gravels selected for
sampling, the containers opened for sampling may be used to help fulfill
the VE requirements.

All retrievably stored containers or retrievably stored containers
randomly selected from waste streams that meet the conditions for
reduced headspace gas sampling listed in Section B-3a(1) will undergo
headspace gas analysis for VOC concentrations.  Retrievably stored waste
that is repackaged will be subject to the DAC determination specified in
Section B-3d(1).  The headspace gas sampling method is provided in
Section B1-1.  All headspace gas data is used to confirm acceptable
knowledge waste characterization, as specified in Section B4.

B-3d(2)	Retrievably Stored Waste (continued)

A statistically selected portion of retrievably stored homogeneous
solids and soil/gravel wastes are sampled and analyzed for total VOCs,
SVOCs, and metals.  The approach used to statistically select drums for
homogeneous solids and soil/gravel wastes is different than the method
used to select waste containers for VE.  This method is included in
Section B2-2.  The sampling methods for these wastes are provided in
Section B1.

The toxicity characteristic of retrievably stored homogeneous solids and
soil/gravel wastes is determined using total analysis of toxicity
characteristic parameters or TCLP.  To determine if a waste exhibits a
toxicity characteristic for compounds specified in 20 4.1.200 NMAC
(incorporating 40 CFR §261, Subpart C), TCLP may be used instead of
total analyses.  Appendix C3 of the WIPP RCRA Part B Permit Application
(DOE 1997a) discusses comparability of totals analytical results to
those of the TCLP method.

Representativeness is ensured by using a truly random process to select
containers for VE and sampling (because representativeness is a quality
characteristic that expresses the degree to which a sample or group of
samples represent the population being studied, the random sampling of
waste streams ensures representativeness).

B-4	Data Verification and Quality Assurance

Data validation, usability and reporting controls are used to ensure
that the TRU waste shipped to the WIPP facility for disposal meets WAP
requirements.  Verification steps are taken at three levels: 1) the
RFETS data generation level, or INEEL TWCP data generation level, 2) the
RFETS project level, and 3) the WIPP facility level.  The validation and
verification process and requirements at each level are described in
Section B3-10.

B-4a	Data Generation and Project Level Verification Requirements

B-4a(1)	Data Quality Objectives

To satisfy the RCRA regulatory compliance requirements, the following
DQOs are established in the WIPP-WAP:

Headspace Gas Sampling and Analysis

To identify VOCs and quantify the concentrations of VOC constituents in
the total waste inventory to ensure compliance with the environmental
performance standards of <IP_ADDRESS>0 NMAC (incorporating 40 CFR,
§264.601(c)), and to confirm hazardous waste identification by
acceptable knowledge.

Homogeneous Waste Sampling and Analysis

To compare UCL90 values for the mean measured contaminant concentrations
in a waste stream with specified toxicity characteristic levels in
<IP_ADDRESS> NMAC (incorporating 40 CFR §261), to determine if the waste
is hazardous, and to confirm hazardous waste identification by
acceptable knowledge.

To report the average concentration of hazardous constituents in a waste
stream, as specified in <IP_ADDRESS> NMAC (incorporating 40 CFR §261)
Appendix VIII, with a 90 percent confidence interval, with all averages
greater than PRQL considered a detection and subsequent assignment of
the waste (if an adequate explanation for the constituent cannot be
determined) as a hazardous waste, and to confirm hazardous waste
identification by acceptable knowledge.

RTR

To verify the TRU waste streams by Waste Matrix Code for purposes of
physical waste form identification and determination of sampling and
analytical requirements, to identify prohibited items, and to confirm
the waste stream delineation by acceptable knowledge.

Visual Examination

To verify the TRU waste streams by Waste Matrix Code for purposes of
physical waste form identification, determination of sampling and
analytical requirements, and to identify prohibited items.

To provide a process check on a sample basis by verifying the
information determined by RTR, and to confirm the waste stream
delineation by acceptable knowledge.

Reconciliation of these DQOs by the TWCP Site PM is addressed in Section
B3.  Reconciliation requires determining whether sufficient type,
quality, and quantity of data have been collected to ensure the DQOs
cited above can be achieved.

B-4a(2)	Quality Assurance Objectives

RFETS demonstrates compliance with each QAO associated with the various
characterization methods as presented in Section B3-2 through B3-9.  The
TWCP Site PM performs a reconciliation at the project

level of the data sets submitted by the various RFETS and INEEL
organizations with the DQOs established in the WIPP-WAP.  The TWCP Site
PM concludes that all of the DQOs have been met for the characterization
of the waste stream prior to submitting a WSPF to the WIPP facility for
approval (refer to Section B3).  The following QAO elements are
considered for each technique, as a minimum:

Precision

Precision is a measure of the mutual agreement among multiple
measurements.

Accuracy

Accuracy is the degree of agreement between a measurement result and the
true or known value.

Completeness

Completeness is a measure of the amount of valid data obtained from a
method compared to the total amount of data obtained that is expressed
as a percentage.

Comparability

Comparability is the degree to which one data set can be compared to
another.

A more detailed discussion of the QAOs, including a mathematical
representation, where appropriate, can be found in Section B3, which
describes the QAOs associated with each method of sampling and analysis.

B-4a(3)	Sample Control

RFETS has implemented a sample handling and control program that
includes the maintenance of field documentation records, proper
labeling, and a chain-of-custody (COC) record.  This document, or
procedures referenced in this document, document this program and
include COC forms to control the sample from the point of origin to the
final analysis result reporting.  Details of this sample control program
are provided in Section B1 and are summarized below to include:

Field Documentation of samples including: point of origin, date of
sample, container ID, sample type, analysis requested, and COC number.

Labeling and/or tagging including: sample numbering, sample ID, sample
date, sampling conditions, and analysis requested.

COC control including: name of sample relinquisher, sample receiver, and
the date and time of the sample transfer.

Proper sample handling and preservation.

B-4a(4)	Data Generation

RFETS utilizes Batch Data Reports, in a format approved by WIPP, for
reporting waste characterization data.  This format is included in this
TWCP QAPjP, in controlled electronic databases, or in site-specific
procedures (refer to Table B-1) and includes the elements required by
the WIPP-WAP for Batch Data Reports (refer to Section B3).  The Batch
Data Report formats utilized by RFETS have been approved by WIPP by
virtue of the numerous audits that have been conducted at RFETS.

Headspace Analytical Services and the Analytical Laboratory's QA/QC
program include the following:

Facility organization

A list of equipment/instrumentation

Operating procedures

Headspace and laboratory QA/QC procedures

Quality assurance review

Headspace and laboratory records management

For select RFETS waste solid sampling and analysis conducted at INEEL,
Batch Data Reports are prepared by the INEEL TWCP.  The INEEL TWCP Batch
Data Report format and QA/QC program are described in the Attachment to
the SOW for the INEEL TWCP (DOE 2003a).

B-4a(5)	Data Verification

Batch Data Reports document the testing, sampling, and analytical
results from the required characterization activities and document
required QA/QC activities.  Data validation and verification at both the
data generation level and the project level are performed as required by
the WIPP-WAP before the required data are transmitted to the WIPP
facility.  Section B3 discusses the data validation process in more
detail.

B-4a(6)	Data Transmittal

Batch Data Reports for each container include the information specified
in Section B3-10 and are transmitted by hard copy or electronically
(provided a hard copy is available on demand) from the data generation
level to the project level.  INEEL transmission of Batch Data Reports to
the RFETS TWCP is conducted by hard copy.

As part of the waste characterization data submittal, RFETS enters data
into WEMS (refer to 4-G83-WEM-WP-1209, WEMS Waste Package Verification
and Certification), and electronically transmits the data on a container
basis to WWIS using the WEMS off-site shipping module (refer to
4-K47-WEM-WP1210, WEMS Offsite Shipping Module).  The data is
transmitted to WWIS in the exact format required by the database.

Once a waste stream is fully characterized, the TWCP Site PM also
submits to the WIPP facility a WSPF (Figure B-1) accompanied by the
Characterization Information Summary for that waste stream which
includes reconciliation with DQOs (refer to Section B3-12b).  The WSPF,
the Characterization Information Summary, and information from the WWIS
is used as the basis for acceptance of waste characterization
information on TRU wastes to be disposed of at the WIPP.

B-4a(7)	Records Management

Records related to waste characterization sampling and analysis are
maintained in the testing, sampling, or analytical facility files or at
the Waste Records Center.  Contract laboratories forward testing,
sampling, and analytical records along with Batch Data Reports, to the
Waste Records Center.  Raw data obtained by testing, sampling, and
analyzing TRU waste in support of this document is identifiable,
legible, and provides documentary evidence of quality.  Refer to Section