 iii  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste iii REVISION LOG Revision Number Date Approved Pages Affected Description of Revision 0 08/ 01/ 02 All Initial issue. DCR 1230. Document issue date was 07/ 17/ 02. DOE/ WIPP approval was received 07/ 30/ 02 thus the change in effective date to 08/ 01/ 02.

1 12/ 19/ 02 Various DCR 1820. Correct procedure titles and numbers. Added verbiage to include manual data review. Added DOE ID to the Document Approval Sheet in accordance with MP DOCS 18.4. Document issue date was 12/ 19/ 02. DOE/ WIPP approval was received 01/ 14/ 03 thus the change in effective date to 02/ 06/ 03.

2 06/ 11/ 03 Various DCR 2117: Incorporate WIPP WAC Rev. 0.1 and QAPD Rev. 4 requirements. Correct procedure references in Section 4. Document issue date was 03/ 20/ 03. DOE/ WIPP approval was received 04/ 03/ 03. The original signature page was lost and was resigned, thus the change in effective date is 06/ 11/ 03.  iv  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste iv TABLE OF CONTENTS 1.0 INTRODUCTION...................................................................................................... 1 2.0 RESPONSIBILITIES................................................................................................. 4 2.1 DOE Headquarters............................................................................................ 4 2.2 DOE Carlsbad Field Office .............................................................................. 4 2.3 DOE Field Elements ......................................................................................... 5 2.4 TRU Waste Sites............................................................................................... 5 3.0 WIPP WASTE ACCEPTANCE REQUIREMENTS AND CRITERIA ................... 6 3.1 Summary of WIPP Authorization Basis ........................................................... 6 3.1.1 DOE Operations and Safety Requirements for WIPP ................................. 7 3.1.2 NRC Transportation Safety Requirements for the TRUPACT II................ 7 3.1.3 NMED Hazardous Waste Facility Permit Requirements............................. 8 3.1.4 EPA Compliance Certification Decision Requirements .............................. 8 3.1.5 Land Withdrawal Act Requirements ........................................................... 9 3.2 Container Properties ....................................................................................... 10 3.2.1 Description................................................................................................. 10 3.2.2 Weight Limits and Center of Gravity ........................................................ 11 3.2.3 Assembly Configurations........................................................................... 13 3.2.4 Removable Surface Contamination ........................................................... 13 3.2.5 Identification/ Labeling............................................................................... 14 3.2.6 Dunnage ..................................................................................................... 15 3.2.7 Filter Vents................................................................................................. 16 3.3 Radiological Properties................................................................................... 16 3.3.1 Radionuclide Composition......................................................................... 17 3.3.2 239Pu Fissile Gram Equivalent ........................................................................ 18 3.3.3 TRU Alpha Activity Concentration........................................................... 20 3.3.4 239Pu Equivalent Activity................................................................................ 20 3.3.5 Radiation Dose Equivalent Rate ................................................................ 22 3.3.6 Decay Heat................................................................................................. 22 3.4 Physical Properties.......................................................................................... 23 3.4.1 Residual Liquids ........................................................................................ 23 3.4.2 Sealed Containers....................................................................................... 24 3.5 Chemical Properties........................................................................................ 24 3.5.1 Pyrophoric Materials.................................................................................. 24 3.5.2 Hazardous Waste ....................................................................................... 25 3.5.3 Chemical Compatibility............................................................................. 26  v  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste v 3.5.4 Explosives, Corrosives, and Compressed Gases........................................ 26 3.5.5 Headspace Gas Concentrations.................................................................. 27 3.5.6 Polychlorinated Biphenyl Concentration................................................... 27 3.6 Data Package Contents ................................................................................... 28 3.6.1 Characterization and Certification Data..................................................... 28 3.6.2 Shipping Data............................................................................................. 28 4.0 QUALITY ASSURANCE REQUIREMENTS ....................................................... 30 4.1 Waste Characterization QA Requirements..................................................... 30 4.2 Waste Certification QA Requirements ........................................................... 30 4.3 Waste Transportation QA Requirements........................................................ 31 4.4 Quality Assurance Program............................................................................ 31 4.4.1 AMWTP TRU Program Organization ....................................................... 33 4.4.2 AMWTP QA Program Description ........................................................... 37 4.4.3 Implementation of the CBFO QA Program............................................... 38 4.4.4 Graded Approach....................................................................................... 39 4.5 Personnel Qualification And Training............................................................ 39 4.5.1 Qualification .............................................................................................. 39 4.5.2 Training...................................................................................................... 39 4.6 Quality Improvement...................................................................................... 40 4.6.1 Conditions Adverse To Quality ................................................................. 40 4.6.2 Controlling Conditions Adverse To Quality.............................................. 41 4.6.3 Nonconforming Items ................................................................................ 41 4.6.4 Corrective Action and Planning Follow up ............................................... 43 4.6.5 Improvement Analysis............................................................................... 43 4.7 Documents and Records ................................................................................. 44 4.7.1 Document Control...................................................................................... 44 4.7.2 Document Preparation, Review, Approval and Issuance........................... 45 4.7.3 Document Distribution and Use................................................................. 46 4.7.4 Records ...................................................................................................... 46 4.8 Performance Requirements............................................................................. 47 4.9 Design Control................................................................................................ 48 4.10 Procurement ............................................................................................... 48 4.10.1 Procurement Document Control ................................................................ 48 4.10.2 Control of Purchased Items and Services .................................................. 48 4.10.3 Control of Subcontractors .......................................................................... 49 4.11 Inspection and Testing ............................................................................... 49 4.12 Assessment Requirements ......................................................................... 51 4.12.1 Management Assessments ......................................................................... 51 4.12.2 Independent Assessments .......................................................................... 51  vi  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste vi 4.12.3 Surveillances.............................................................................................. 52 4.12.4 CBFO Audits ............................................................................................. 52 4.12.5 Reports to Management ............................................................................. 52 4.13 Sample Control Requirements ................................................................... 53 4.14 Scientific Investigation Requirements ....................................................... 53 4.15 Software Requirements.............................................................................. 54 5.0 REFERENCES......................................................................................................... 55 APPENDIX A................................................................................................................. A 1 A. 1 Introduction................................................................................................. A 2 A. 2 Radionuclide Isotopic Ratios ...................................................................... A 3 A. 2.1 Methods for Confirmation of Isotopic Ratio AK.................................... A 3 A. 2.2 Acceptable Knowledge ( AK) Documentation ........................................ A 5 A. 2.2.1 Required Elements .................................................................................. A 5 A. 2.2.2 Supplemental Acceptable Knowledge Information ................................ A 6 A. 2.2.3 Discrepancy Resolution .......................................................................... A 7 A. 3 Data Quality Objectives.............................................................................. A 7 A. 4 Quality Control ......................................................................................... A 10 A. 4.1 General Requirements........................................................................... A 11 A. 4.2 NDA QC Requirements ........................................................................ A 11 A. 4.3 Radiochemistry QC Requirements ....................................................... A 13 A. 5 Data Management ..................................................................................... A 13 A. 5.1 Data Review and Validation ................................................................. A 14 A. 5.2 Data Reporting...................................................................................... A 14 A. 5.3 Data and Records Retention.................................................................. A 15 A. 6 Quality Characteristics Assessment.......................................................... A 15 A. 6.1 Data Accuracy....................................................................................... A 16 A. 6.2 Data Precision ....................................................................................... A 16 A. 6.3 Data Representativeness ....................................................................... A 16 A. 6.4 Data Completeness................................................................................ A 16 A. 6.5 Data Comparability............................................................................... A 17 Appendix A References ...................................................................................... A 18 APPENDIX B.................................................................................................................. B 1 B. 1 Appendix B References ............................................................................... B 3 APPENDIX C.................................................................................................................. C 1 APPENDIX D ....................................................................................................... D 1  vii  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste vii LIST OF ACRONYMS AND ABBREVIATIONS AEA Atomic Energy Act ACMM Analytical Chemistry Methods Manual AK acceptable knowledge ALD Analytical Laboratories Department AMWTF Advanced Mixed Waste Treatment Facility AMWTP Advanced Mixed Waste Treatment Project ASTM American Society for Testing and Materials ANSI American National Standards Institute CAR Corrective Action Report CBFO Carlsbad Field Office CCA Compliance Certification Application CFR Code of Federal Regulations CH contact handled CH TRU contact handled TRU waste CH WAC contact handled waste acceptance criteria Ci curie CPR cellulose, plastic, and rubber DAS drum assay system DDA differential die away DCR document change request DOE U. S. Department of Energy DOT U. S. Department of Transportation DR Deficiency Report DSDD detailed software design description DQO data quality objective EDF Engineering Design File EPA U. S. Environmental Protection Agency FGE fissile gram equivalent FRC Federal Records Center HSGS headspace gas sampling ID Idaho INEL Idaho National Engineering Laboratory INEEL Idaho National Engineering and Environmental Laboratory INST Instruction LCS laboratory control sample LLD lower limit of detection LWA Land Withdrawal Act MP Management Procedure  viii  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste viii MS matrix spike MSD matrix spike duplicate nCi/ g nanocuries per gram NCR nonconformance report NDA nondestructive assay NIST National Institute of Standards and Technology NMED New Mexico Environment Department NMMA nuclear material management area NRC U. S. Nuclear Regulatory Commission OPCTCD overpack payload container transportation certification document PATCD payload assembly transportation certification document PCTCD payload container transportation certification document PCB polychlorinated biphenyl PDAS In plant Drum Assay System PDP performance demonstration program PE Ci plutonium 239 equivalent curies QA quality assurance QAO quality assurance objective QAP Quality Assurance Plan QAPD Quality Assurance Program Document QAPjP quality assurance project plan QC quality control RC radiochemistry RCRA Resource Conservation and Recovery Act RDAS retrieval drum assay system RH remote handled ( waste) RIDS records inventory and disposition schedule % R percent recovery RPD relative percent difference RSD relative standard deviation RT Radiological Technician RTR real time radiography SAR Safety Analysis Report SATR Site Acceptance Test Reports SNM special nuclear material SPM Site Project Manager SPO Site Project Office SQAO Site Quality Assurance Officer SWB standard waste box TCO Transportation Certification Official  ix  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste ix TDOP ten drum overpack TMU total measurement uncertainty TRAMPAC TRUPACT II Authorized Methods for Payload Control TRU transuranic TRUCON TRUPACT II Content Codes TRUPACT II Transuranic Package Transporter Model II TSDF Treatment, Storage, and Disposal Facility VE Visual Examination VOC volatile organic compound WAC Waste Acceptance Criteria WAP Waste Analysis Plan WCL waste component limits WCO Waste Certification Official WIPP Waste Isolation Pilot Plant WSPF Waste Stream Profile Form WTS Waste Tracking System WWIS WIPP Waste Information System  1  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 1 1.0 INTRODUCTION The purpose of this document is to summarize the methods and procedures used by the Idaho National Engineering and Environmental Laboratory ( INEEL) Advanced Mixed Waste Treatment Project ( AMWTP) to certify defense generated waste as compliant to the waste acceptance criteria applicable to the transportation, storage, and disposal of contact handled transuranic ( CH TRU) waste at the Waste Isolation Pilot Plant ( WIPP). These criteria serve as the U. S. Department of Energy's ( DOE) primary directive for ensuring that CH TRU waste is managed and disposed of in a manner that protects human health and safety and the environment.

The authorization basis of WIPP for the disposal of CH TRU waste includes the U. S. Department of Energy National Security and Military Applications of Nuclear Energy Authorization Act of 1980 ( reference 20) and the WIPP Land Withdrawal Act ( LWA; reference 21). Included in this document are the requirements and associated criteria imposed by these acts and the Resource Conservation and Recovery Act ( RCRA, reference 22), as amended, on the TRU waste destined for disposal at WIPP.

The AMWTP must certify CH TRU waste payload containers to the contact handled waste acceptance criteria ( CH WAC) identified in this document. As shown in figure 1.0, the flow down of applicable requirements to the CH WAC is traceable to several higher tier documents, including the WIPP operational safety requirements derived from the WIPP CH Safety Analysis Report ( SAR; reference 14), the transportation requirements for CH TRU wastes derived from the Transuranic Package Transporter Model II ( TRUPACT II) Certificate of Compliance ( reference 43), the WIPP LWA ( reference 21), the WIPP Hazardous Waste Facility Permit ( reference 42), and the U. S. Environmental Protection Agency ( EPA) Compliance Certification Decision ( reference 27). The solid arrows shown in figure 1.0 represent the flow down of all applicable payload container based requirements. The two dotted arrows shown in figure 1.0 represent the flow down of summary level requirements only; i. e., the sites must reference the regulatory source documents from the U. S. Nuclear Regulatory Commission ( NRC) and the New Mexico Environment Department ( NMED) for a comprehensive and detailed listing of the requirements.

The Certification Plan for INEEL Contact Handled Transuranic Waste, also referred to as the Certification Plan, does not address requirements or shippability of waste in DOE Type B casks or the subject of waste characterization relating to a determination of whether the waste is hazardous; rather, the AMWTP refers to the Waste Analysis Plan ( WAP) contained in the WIPP Hazardous Waste Facility Permit for details of the sampling and analysis protocols to be used in determining compliance with the required physical and chemical properties of the waste. Requirements and associated criteria pertaining to a determination of the radiological properties of the waste, however, are addressed in appendix A of this document. The collective information obtained from waste characterization records and acceptable knowledge ( AK) serves as the basis for sites to certify that their CH TRU waste satisfies the WIPP CHWAC  2  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 2 Section 2.0 of this document identifies the responsible organizations and associated activities for ensuring that the CH TRU waste is managed in a manner that protects human health and safety and the environment.

Section 3.0 identifies the authorization basis of the requirements and lists the associated waste acceptance criteria and compliance methods relating to the physical, chemical, and radiological attributes of the waste as well as the properties of the applicable containers themselves.

Section 4.0 summarizes the AMWTP Quality Assurance ( QA) requirements relating to waste characterization, certification, and transportation that meet all applicable requirements of the Carlsbad Field Office ( CBFO) Quality Assurance Program Document ( QAPD; reference 7). Characterization of CH TRU waste must be in accordance with the performance requirements of the WIPP WAP and is implemented in the AMWTP Quality Assurance Project Plan ( QAPjP). Certification of payload containers for shipment in the TRUPACT II shall be performed under a CBFO approved QA program that provides confidence for both the shipper and the receiver that the TRUPACT II Authorized Methods for Payload Control ( TRAMPAC; reference 45) requirements have been met.

The appendices provide supplemental information relating to radioassay ( appendix A) and radiotoxic inhalation hazard analyses ( appendix B). A glossary is provided in appendix C. Appendix D addresses the visual examination requirements and compliance criteria for payload containers.

The CH WAC is a controlled document. The most current version of the CH WAC ( including any Interim Changes) is available for downloading from the CBFO Web Page at http:// www. wipp. ws/ library/ wac/ ch wacrev0. pdf. This Internet link is provided for informational purposes only and may change.  3  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 3 NRC TRUPACT II CERTIFICATE OF COMPLIANCE1 NMED WIPP HAZARDOUS WASTE FACILITY PERMIT1 DOE/ CBFO WIPP CH SAFETY ANALYSIS REPORT ( FEIS, SEIS I, SEIS II) EPA WIPP COMPLIANCE CERTIFICATION DECISION CONGRESS WIPP LAND WITHDRAWAL ACT WIPP CH TRU WASTE ACCEPTANCE CRITERIA SITE TRAMPAC2 SITE QUALITY ASSURANCE PROJECT PLAN2 SITE WASTE CERTIFICATION PLAN2 SITE DATA INPUT ( REQUIREMENTS)

( CRITERIA)

Figure 1.0 Regulatory Basis of CH TRU Waste Acceptance Criteria Note 1: The TRAMPAC and the WIPP Hazardous Waste Facility Permit provide detailed requirements. The CH WAC only provides an overview of these requirements.

Note 2: All work performed by the site for the CBFO must be performed under an approved QA program.  4  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 4 2.0 RESPONSIBILITIES This section identifies the responsibilities of organizations that develop and approve the WIPP CH WAC and of those that oversee the implementation of the requirements defined herein. The responsibilities of the AMWTP to which these requirements apply are also identified in this section.

2.1 DOE Headquarters The Assistant Secretary for Environmental Management ( EM 1) provides policy and guidance for DOE environmental management sites, facilities, and operations.

2.2 DOE Carlsbad Field Office The CBFO is responsible for the day to day management and direction of strategic planning and related activities associated with the characterization, certification, transportation, and disposal of defense TRU waste. The CBFO holds the applicable permits, certifications, and records of decision necessary for the operation and closure of the WIPP facility.

The CBFO assists the sites in resolving issues about the management of TRU waste as requested. The CBFO provides policy and oversight direction for TRU waste program activities related to site certification of waste for disposal at WIPP. The CBFO is also responsible for the following:

  Ensuring that the sites prepare implementation documentation and programs to meet the requirements and criteria in the CH WAC   Overseeing activities associated with the  characterization and certification of CH TRU waste  proper use of approved transportation packaging  receipt, management, and disposal of CH TRU waste in WIPP   Providing a fleet of NRC approved Type B transportation packages for shipment of CH TRU waste from the sites to WIPP   Ensuring that CH TRU waste accepted for management and disposal at WIPP complies with the WIPP Hazardous Waste Facility Permit, applicable laws, and regulations as described in this CHWAC  5  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 5   Reviewing and approving proposed revisions to the CH WAC to ensure that environmental impacts associated with any revision are bounded by existing WIPP National Environmental Policy Act documentation including the Final Environmental Impact Statement ( reference 10), Final Supplemental Environmental Impact Statement I ( reference 11), and the Final Supplemental Environmental Impact Statement II ( reference 12)

  Reviewing and approving the site's waste certification plan, TRAMPAC, QA plan, and QAPjP   Performing site certification audits and surveillances   Granting transportation and waste certification authority to sites 2.3 DOE Field Elements Each DOE Field Element is responsible for overseeing the management of the site TRU waste program in compliance with established CBFO requirements, policies, and guidelines, and for providing liaison between the CBFO and the management and operating contractors.

2.4 TRU Waste Sites The AMWTP is responsible for developing and implementing site specific TRU waste program documents ( plans) that address applicable requirements and criteria pertaining to packaging, characterization, certification, and shipping of defense TRU waste to WIPP for disposal. Methods of compliance with each requirement and associated criterion to be implemented is described or specifically referenced and include procedural and administrative controls consistent with the CBFO QAPD. The AMWTP will certify that each CH TRU waste payload container meets the waste acceptance criteria contained in section 3. The AMWTP QA requirements relating to waste characterization, certification, and transportation are contained in section 4.0. The following AMWTP site specific TRU waste program documents will be submitted to CBFO for review and approval prior to implementation:

  MP TRUW 8.1, Certification Plan for INEEL Contact Handled Transuranic Waste   MP TRUW 8.2, Quality Assurance Project Plan ( QAPjP)

  MP TRUW 8.3, TRUPACT II Authorized Methods for Payload Control ( TRAMPAC)

The AMWTP TRU Program organization, project level positions, and their primary responsibilities are described in Section 4.4.1 of this document.  6  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 6 3.0 WIPP WASTE ACCEPTANCE REQUIREMENTS AND CRITERIA The requirements and associated criteria for acceptance of defense TRU waste at WIPP for disposal are identified in the CH WAC. The acceptance criteria of the CH WAC describe the controlling ( i. e., the most restrictive) requirements to be used by the AMWTP in preparing their waste for transportation to and disposal at the WIPP. In some instances the acceptance criteria and regulatory requirements are synonymous. The CH WAC requirements are derived from several source documents: the WIPP Safety Analysis Report ( reference 14), the TRUPACT II Certificate of Compliance ( reference 43), the WIPP LWA ( reference 21), the WIPP Hazardous Waste Facility Permit ( reference 42), and the Compliance Certification Decision ( reference 27). Definitions of terms used in the CH WAC are included in Appendix C.

3.1 Summary of WIPP Authorization Basis The purpose of section 3.0 is to present the requirements and associated criteria that must be met for CHTRU waste to be transported to, managed at, and disposed of in the WIPP. The requirements and associated criteria are organized under five major headings: Container Properties, Radiological Properties, Physical Properties, Chemical Properties, and Data Package Contents. Only CH TRU waste from a properly characterized and approved waste stream may be certified as meeting the requirements and associated criteria contained in this CH WAC. Any waste payload container from a waste stream that has not been preceded by an appropriate certified Waste Stream Profile Form ( WSPF) is not acceptable for disposal at WIPP ( reference 42, module II, section II. C. 3. k).

Site specific plans and procedures shall contain details of the processes, controls, techniques, tests, and other actions to be applied to each TRU payload container, waste stream, and shipment. Methods of compliance with each requirement shall be described and the specific procedure cited. These methods of compliance shall include procedural controls, administrative controls, and waste generation process controls. The QA requirements applicable to waste characterization, certification, and transportation are addressed in various sections of this CH WAC and are briefly summarized in section 4.0. The data resulting from the implementation of the plans and procedures will form the basis for verifying that CHTRU waste to be sent to WIPP is certified to meet the CH WAC by the responsible site certifying official( s).  7  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 7 Sites shall transmit required characterization, certification, and shipping data to WIPP using the WIPP Waste Information System ( WWIS). The WWIS is an electronic database equipped with edit/ limit checks to ensure that the data representing the waste payload containers are in compliance with this CHWAC The WWIS also incorporates the automated TRUPACT II Authorized Methods for Payload Control ( e TRAMPAC) software, which is used to evaluate containers and assemblies of CH TRU waste for compliance with each of the TRAMPAC requirements. Before shipping TRU waste payload containers from a WIPP accepted waste stream, the site shall transmit the required waste characterization, certification, and shipping data via WWIS to WIPP. Sites may periodically be requested to transmit payload container radiography reports or other data to WIPP. WIPP will not accept any waste shipments for disposal if the waste payload container information has not been correctly submitted and approved for shipment by the WWIS Data Administrator. The WWIS User's Manual ( reference 9) provides the information needed by TRU waste sites to perform tasks associated with transmittal of the payload container's characterization, certification, and shipment information to WIPP.

Sites will be notified of revisions to external regulatory requirements by CBFO. Revisions of requirements in referenced documents not controlled by the DOE ( but by, for example, the EPA, NRC, or NMED) shall have precedence over the values specified here if they are more restrictive. These changes will be incorporated in future revisions of the CH WAC.

3.1.1 DOE Operations and Safety Requirements for WIPP The WIPP SAR ( reference 14) addresses CH TRU waste handling and emplacement operations. The waste accepted for emplacement in the WIPP must conform to the SAR and the associated technical safety requirements ( reference 15). The SAR documents the safety analyses that develop and evaluate the adequacy of the WIPP safety bases necessary to ensure the safety of workers, the public, and the environment from the hazards posed by WIPP waste receiving, handling, and emplacement operations. The SAR establishes and evaluates the adequacy of the safety bases in response to plant normal and abnormal operations and postulated accident conditions.

3.1.2 NRC Transportation Safety Requirements for the TRUPACT II Acceptable methods for payload compliance are defined in the TRUPACT II Certificate of Compliance and implemented by the TRAMPAC ( reference 45). For shipments to WIPP, each site must prepare a site specific TRAMPAC describing how it will ensure compliance with each payload parameter. This technical plan shall contain sufficient detail to allow reviewers to adequately understand and evaluate the compliance methodology for each payload parameter.

Sites shall have a packaging QA program that defines the QA activities that apply to the use of NRCapproved transportation packaging equivalent to Title 10 of the Code of Federal Regulations ( 10 CFR) Part 71, Subpart H. ( reference 29)  8  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 8 3.1.3 NMED Hazardous Waste Facility Permit Requirements TRU waste is classified as TRU mixed waste if it contains hazardous constituents regulated under the New Mexico Hazardous Waste Act. Only TRU mixed waste and TRU waste that have been characterized in accordance with the WIPP WAP and that meet the treatment, storage, and disposal facility ( TSDF) waste acceptance criteria as presented in permit conditions II. C. 3. a through II. C. 3. k of the WIPP Hazardous Waste Facility Permit will be accepted at the WIPP facility for disposal in the permitted underground hazardous waste disposal unit.

Prior to disposal, each participating site shall develop and implement a QAPjP that addresses all the applicable requirements specified in the WIPP WAP. In accordance with attachment B5 of the WIPP WAP, the QAPjP will include the qualitative or quantitative criteria for making a hazardous waste determination. All site QAPjPs will be reviewed and approved by the CBFO.

3.1.4 EPA Compliance Certification Decision Requirements Title 40 CFR § 194.24( c) states that the DOE shall specify the limiting values for waste components to be emplaced in the repository ( reference 33). Appendix WCL ( Waste Component Limits) of the Compliance Certification Application ( CCA; reference 8) identifies the repository limits for several waste components including free water, metals, and cellulose, plastic, and rubber ( CPR). Although the CCA does not specifiy limiting values for the activities and masses of specific radionuclides. Table 4 6 of the CCA identifies the listed values for a number of radionuclides that are considered in the Performance Assessment. To demonstrate that the cumulative total activities of the specified radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) are consistent with the levels used for the Performance Assessment and the compliance certification decision, reporting, and tracking of the specified radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) is necessary, as required by Table 4 10 of the CCA. TRU waste payload containers shall contain more than 100 nanocuries per gram of waste ( nCi/ g) of alpha emitting TRU isotopes with half lives greater than 20 years, as specified in section 3.3.3 of the CH WAC.

The repository limit for free water is a maximum of 1684 m3 and is met by the residual liquid criterion specified in section 3.4.1 of the CH WAC.

The limits for metals are a minimum of 2 X 107 kg for ferrous metals and 2 X 103 kg for nonferrous metals. These limits will be met in the total repository inventory by the metals that constitute the payload containers alone; thus, WIPP tracks the number and type of payload containers emplaced in the repository as reported in the WWIS by the sites ( see section 3.2.1).  9  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 9 The repository limit for CPR is a maximum of 2 X 107 kg. Sites are required to estimate the CPR weights and report these estimates in the WWIS on a payload container basis as required by section 3.6.1. Waste generators must quantify and report the activities and masses of specific radionuclides for the purpose of tracking the total radionuclide inventory of the repository as specified in section 3.3.1 of the CH WAC. The presence or absence of these specific radionuclides is determined from AK, radioassay, or both in accordance with appendix A of the CH WAC. The results of this determination are reported in the WWIS on a payload container basis.

3.1.5 Land Withdrawal Act Requirements The term " WIPP" means the Waste Isolation Pilot Plant project authorized under section 213 of the Department of Energy National Security and Military Applications of Nuclear Energy Authorization Act of 1980 ( Pub. L. 96 164; 93 Stat. 1259 1265) to demonstrate the safe disposal of radioactive waste materials generated by atomic energy defense activities ( reference 20, section 2[ 19]). Hence, by law, WIPP can accept only radioactive waste generated by atomic energy defense activities of the United States ( reference 21, section 2[ 19]).

The DOE and its predecessor agencies were engaged in a broad range of activities that fall under the heading of atomic energy defense activities. A TRU waste is eligible for disposal at WIPP if it has been generated in whole or in part by one or more of the following functions ( references 23 and 24):

  Naval reactors development   Weapons activities, including defense inertial confinement fusion   Verification and control technology   Defense nuclear materials productions   Defense nuclear waste and materials by products management   Defense nuclear materials security and safeguards and security investigations   Defense research and development Using AK, DOE sites must determine that each waste stream to be disposed of at WIPP is " defense" TRU waste.

High level radioactive waste or spent nuclear fuel shall not be transported, emplaced, nor disposed of at WIPP ( reference 20, section 12). Also, no transuranic waste may be transported by or for the DOE to or from WIPP, except in packages ( 1) the design of which has been certified by the NRC, and ( 2) that have been determined by the NRC to satisfy its quality assurance requirements ( reference 21, section 16).  10  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 10 3.2 Container Properties 3.2.1 Description Acceptance Criterion. Each payload container shall be assigned to a payload shipping category. ( reference 45, section 5.1) Authorized payload containers include:

  55 gallon drums ( either direct loaded or containing a pipe component)

  Standard waste boxes ( SWBs, either direct loaded, or containing up to four direct loaded 55 gallon drums, or containing one bin)

  Ten drum overpacks ( TDOPs, either containing up to ten direct loaded 55 gallon drums, six 85 gallon drum overpacks, or one SWB)

Payload containers shall meet U. S. Department of Transportation ( DOT) Specification 7A, Type A, packaging requirements ( reference 15, section 5.9.12; reference 42, attachment M1, section M1 1b). Payload containers must be made of steel and be in good and unimpaired condition prior to shipment from the generator/ storage sites. To demonstrate compliance with the requirement that payload containers be in good and unimpaired condition, the exterior of all payload containers shall undergo 100% visual examination ( VE) prior to loading into a TRUPACT II. The results of this visual examination shall be documented using the payload container integrity checklist contained in appendix D. A payload container in good and unimpaired condition 1) does not have significant rusting, 2) is of sound structural integrity, and, 3) does not leak. Significant rusting is a readily observable loss of metal due to oxidation ( e. g., flaking, bubbling, or pitting) that causes degradation of the payload container's structural integrity. Rusting that causes discoloration of the payload container surface or consists of minor flaking is not considered significant. A payload container is not of sound structural integrity if it has breaches or significant denting/ deformation. Breaching is defined as a penetration in the payload container that exposes the internals of the container. Significant denting/ deformation is defined as damage to the payload container that results in creasing, cracking, or gouging of the metal, or damage that affects payload container closure. Dents or deformations that do not result in creasing, cracking, or gouging or affect payload container closure are not considered significant. Generator sites will report to the WWIS the number and types of payload containers planned for shipment to the WIPP ( reference 8, appendix WCL).

Compliance: Each payload container is assigned a shipping category and is verified in the WTS or WIPP Waste Information System ( WWIS). Authorized payload containers are controlled and verified in accordance with work instruction, INST OI 21, TRUPACT II Payload Assembly. Payload container visual inspections detailed in Appendix D are performed and documented per work instruction, INST OI 21, TRUPACT II Payload Assembly. Payload containers that do not meet the container integrity visual examination are overpacked prior to shipment. The numbers and types of payload containers planned for shipment to WIPP are reported the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.  11  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 11 3.2.2 Weight Limits and Center of Gravity Acceptance Criterion. Each payload container, payload assembly, and loaded TRUPACT II shall comply with the weight limits shown in table 3.2.2. Weight calculations for the payload assembly must include the measurement error. The total weight of the top seven 55 gallon drums or SWB of the payload assembly shall be less than or equal to the total weight of the bottom seven 55 gallon drums or SWB, respectively. The total weight of the top five 55 gallon drums or three 85 gallon drum overpacks in a TDOP shall be less than or equal to the total weight of the bottom five 55 gallon drums or three 85 gallon drum overpacks, respectively. Calibrations of the scales used to make these weight determinations shall be in accordance with the National Institute of Standards and Technology ( NIST) Handbook 44, Specifications, Tolerances, and Other Technical Requirements for Weighing and Measuring Devices, or an equivalent standard. ( reference 45, section 2.3; reference 41)

Table 3.2.2 Weight Limits Container Maximum Gross Weight ( lbs) 55 gallon drum < 1,000 55 gallon drum containing a six inch diameter standard pipe component ( i. e., a standard pipe overpack) < 328 55 gallon drum containing a twelve inch diameter standard pipe component ( i. e., a standard pipe overpack) < 547 55 gallon drum containing an S100 pipe component ( i. e., an S100 pipe overpack) < 650 55 gallon drum containing an S200 pipe component ( i. e., an S200 pipe overpack) < 547 SWB < 4,000 TDOP < 6,700 Payload assembly of fourteen 55 gallon drums < 7,265 Payload assembly of two SWBs < 7,265 TRUPACT II < 19,250 Truck ( tractor/ trailer) < 80,000  12  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 12 Compliance: Each drum is weighed on a calibrated scale at one of the drum assay systems ( DAS) in accordance with work instruction, INST OI 14, Drum Assay Operations The payload container weight is evaluated by the WTS or WWIS for compliance with the requirement listed in Table 3.2.2. This evaluation compares the payload container weight including its associated measurement error ( expressed in terms of one standard deviation). Calibrations of the scales are done in accordance with the NIST Handbook 44, Specifications, Tolerances, and Other Technical Requirements for Weighing and Measuring Devices, or an equivalent standard. The weight is reported to the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.

Additional weight limits may be implemented based on restrictions identified by procurement specifications and testing. These restrictions will also be addressed in the applicable work instructions as they are identified.

The WTS or WWIS evaluates the TRUPACT II payload assembly for compliance with the weight requirements using the location and weight of the individual payload containers. The total weight of the top seven 55 gallon drums or SWB of the payload assembly is less than or equal to the total weight of the bottom seven 55 gallon drums or SWB, respectively. The total weight of the top five 55 gallon drums or three 85 gallon drum overpacks in a TDOP is be less than or equal to the total weight of the bottom five 55 gallon drums or three 85 gallon drum overpacks, respectively. Evaluations of the TRUPACT II and truck weights for compliance with the requirements listed in Table 3.2.2 are performed using the calculated payload assembly weights, reported TRUPACT II weights, and the reported truck weight. Work Instructions, INST OI 20, TRUPACT II Operations, and INST OI 21, TRUPACT II Payload Assembly, ensure compliance.  13  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 13 3.2.3 Assembly Configurations Acceptance Criterion. Payload container assembly configurations authorized for shipment in the TRUPACT II shall be in accordance with table 3.2.3.

Table 3.2.3 Payload Container Assembly Configurations Number of Payload Containers in Assembly Payload Container Configuration 14 55 gallon drums 14 55 gallon drums, each containing one standard pipe component 14 55 gallon drums, each containing one S100 pipe component 14 55 gallon drums, each containing one S200 pipe component 2 SWBs 2 SWBs, each containing one bin 2 SWBs, each containing up to four 55 gallon drums 1 TDOP containing up to 10 55 gallon drums 1 TDOP containing up to six 85 gallon drums ( each 85 gallon drum containing one 55 gallon drum) 1 TDOP containing one SWB 1 TDOP containing one bin within an SWB 1 TDOP containing up to four 55 gallon drums within an SWB Although 85 gallon drum overpacks are acceptable at WIPP, they are not authorized for transport in a TRUPACT II as individual payload containers.

Compliance: Work instruction, INST OI 21, TRUPACT II Payload Assembly, controls the maximum number of containers per TRUPACT II and the authorized packaging configurations.

3.2.4 Removable Surface Contamination Acceptance Criterion. Removable surface contamination on CH TRU waste payload containers, payload assemblies, and packaging shall not exceed 20 dpm/ 100 cm2 alpha and 200 dpm/ 100 cm2 beta gamma ( reference 15, section 5.9.12; reference 42, attachment M1, section M1 1d[ 2]; reference 37; and reference 31). The fixing of surface contamination to meet these criteria is not allowed by WIPP in accordance with best management practices for ensuring worker radiation dose as low as reasonable achievable.  14  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 14 Compliance: A radiological technician ( RT) surveys each container which is documented per the work instruction, INST OI 21, TRUPACT II Payload Assembly. Containers that exceed allowable surface contamination levels are decontaminated and/ or overpacked. Surveys on the loaded TRUPACT II are performed in accordance with work instructions, INST 0I 20, TRUPACT II Operations. Results are reported to the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.

3.2.5 Identification/ Labeling Acceptance Criterion. Each payload container shall be labeled with a unique container identification number using bar code labels permanently attached in conspicuous locations. The payload container identification number shall be in medium to low density Code 39 bar code symbology as required by American National Standards Institute ( ANSI) standard ANSI/ AIM BC1 1995 ( reference 40) in characters at least one inch high and alphanumeric characters at least one half inch high. In the case of 55 gallon drums, the bar code identification labels shall be placed at three locations approximately 120 degrees apart so that at least one label is clearly visible when the drums are assembled into a seven pack ( i. e., a label must be visible after slip sheets and wrapping are applied). In the case of SWBs, bar code labels are required on the flat sides of the SWB ( reference 4). For TDOPs, a minimum of one bar code is required.

Payload containers shall be marked " Caution Radioactive Material" using a yellow and magenta label as specified in 10 CFR Part 835 ( reference 31). Those payload containers whose contents are also RCRA regulated ( mixed TRU) shall be additionally marked " Hazardous Waste" as specified in 40 CFR § 262.32 ( reference 34).

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

  Unique container identification number   " EMPTY" or " DUNNAGE If a seven pack of only dunnage 55 gallon drums or a dunnage SWB is used in the TRUPACT II, the container( s) shall be labeled only " EMPTY" or " DUNNAGE." The unique container identification number label is not required for a seven pack of dunnage, 55 gallon drums, or a dunnage SWB. ( reference 45, section 2.4.1)

Compliance: Payload containers certified for shipment by the AMWTP, are labeled in medium to low density Code 39 bar code symbology as required by American National Standards Institute ( ANSI) standard ANSI/ AIM BC1 1995 ( reference 40) in characters at least one inch high and alphanumeric characters at least one half inch high in the following format: BNXXXXXXXXXXX, where BN represents BNFL, Inc. AMWTP and XXXXXXXXXXX represents a sequential number generated by the WTS. The WTS also verifies that the identification number is unique and that a duplicate container identification number does not exist. Empty containers used as dunnage are labeled " EMPTY" or " DUNNAGE".  15  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 15 Payload containers are marked " Caution Radioactive Material" using a yellow and magenta label as specified in 10 CFR Part 835 ( reference 31). Those payload containers whose contents are also RCRA regulated ( mixed TRU) are additionally marked " Hazardous Waste".

55 gallon drums are labeled as they are retrieved from storage in accordance with Work Instruction, INST OI 09, Retrieval Enclosure Waste Container Extraction, or Work Instruction, INST OI 11, Waste Container Handling.

Work instruction, INST OI 21, TRUPACT II Payload Assembly, prepares the labels used when containers are placed into a TDOP or SWB and ensure that labels attached to all payload containers are correct prior to shipment.

3.2.6 Dunnage Acceptance Criterion. A shipper shall use empty 55 gallon drums or a SWB as dunnage to complete a payload configuration if too few payload containers are available that meet transportation requirements. The dunnage container( s) must meet the specifications of appendix 2.1 of the TRAMPAC with the exception that dunnage containers shall have open vent ports ( i. e., not filtered or plugged). ( reference 45, section 2.2.1)

To maximize the efficiency of disposal operations at the WIPP, the use of dunnage drums should be minimized. In the event the use of dunnage drums cannot be avoided, the preferred practice for maximizing the efficiency of waste handling and the utilization of disposal room capacity is to ship them in assemblies ( i. e., a seven pack assembly of 55 gallon drums). The use of dunnage drums is reviewed and approved concurrently with the review and approval of shipment assemblies by the WWIS Data Administrator on a case by case basis.

Compliance: Work Instruction, INST OI 21, TRUPACT II Payload Assembly, verifies that empty 55 gal drums or SWBs used, as dunnage to complete payload configurations are labeled " Empty" or " Dunnage". Dunnage containers are inspected in accordance with Work Instruction, INST OI 21, TRUPACT II Payload Assembly, to demonstrate compliance with the U. S. Department of Transportation ( DOT) Specification 7A, Type A, packaging requirements( reference 15, section 5.9.12; reference 42, attachment M1, section M1 1b) that payload containers be in good and unimpaired condition, the exterior of all payload containers are inspected prior to loading into a TRUPACT II. Payload containers are also inspected to ensure that containers have open vent ports ( i. e., not filtered or plugged). These containers are reported in the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.  16  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 16 3.2.7 Filter Vents Acceptance Criterion. Payload containers that have been stored in an unvented condition ( i. e., no filter and/ or unpunctured liner) shall be aspirated for a specific length of time as described in the TRAMPAC to ensure equilibration of any gases that may have accumulated in the closed payload container. ( reference 45, section 5.3.1 and appendix 5.9)

Each payload container shall have one or more filter vents that meet the specifications of appendix 2.5 of the TRAMPAC ( reference 15, section 5.9.12; reference 45, section 2.5.1). The model number of each filter vent or combination of filter vents installed on a payload container shall be reported to the WWIS. A listing of available CBFO filter vent models is provided on the CBFO Web Page ( http:// www. wipp. ws/ transport. htm). This Internet link is provided for informational purposes only and may change.

Compliance: QA procedures provide protocol for procuring and inspecting filters to ensure compliance with appendix 2.5 of the TRAMPAC specifications for filter vents, which are performed in accordance with management procedure, MP PCMT 15.3, Purchase Order/ Subcontract Preparation and Control and MP Q& SI 5.7, Quality Inspections.

Payload containers that have been stored in an unvented condition ( i. e., no filter and/ or unpunctured) liner are vented and aspirated in accordance with work instruction, INST OI 13, Drum Vent/ Headspace Gas Sample Operations.

Work instruction, INST OI 21, TRUPACT II Payload Assembly, verifies that each payload container contains the minimum number of filters as specified in Appendix 2.5 of the TRAMPAC. The model number of each filter or combination of filters installed in a payload container is recorded and stored in the WTS and reported to the WWIS in accordance with MP TRUW 8.16, WWIS Data Transfer.

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

The first group includes the activities and masses of the ten WIPP tracked radionuclides ( i. e., 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) and the TRU alpha activity concentration ( i. e., > 100 nCi/ g of alpha emitting TRU isotopes with half lives greater than 20 years) of the waste. This set of radiological properties is regulated by the EPA in accordance with 40 CFR Parts 191 and 194 ( references 32 and 33). Estimates of their activities and masses shall be derived from a system of controls certified by CBFO that includes AK, computations, measurements, sampling, etc. ( reference 8, appendix WCL). Appendix A provides the methods and requirements by which to characterize the radiological composition of the CH TRU waste utilizing radioassay techniques.  17  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 17 The second group includes the remaining radionuclides contributing to the fissile gram equivalent ( FGE), the plutonium 239 equivalent curies ( PE Ci), and the decay heat of the payload container. This set of radiological data is regulated both by the NRC as specified in the TRAMPAC ( reference 45) and the CBFO as required by the WIPP Technical Safety Requirements ( reference 15). PE Ci quantities shall be calculated for each payload container in accordance with appendix B. Any TRAMPAC compliant method may be used to quantify the remaining radiological properties at the discretion of the shipping facility. Appendix A provides recommended radioassay methods by which to characterize the remaining radiological properties. However, the resulting data ( e. g., AK from Safeguards and Security data), the source/ method from which the data was generated, and the basis for the reliability of the data shall be submitted to and approved by CBFO prior to use.

3.3.1 Radionuclide Composition Acceptance Criterion. The activities and masses of 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs shall be established on a payload container basis for purposes of tracking their contributions to the total WIPP radionuclide inventory ( reference 8, appendix WCL). The estimated activities and masses, including their associated total measurement uncertainties ( TMU) expressed in terms of one standard deviation, for these ten radionuclides shall be reported to the WWIS on a payload container basis. For any of these ten radionuclides whose presence can be substantiated from AK, direct measurement, computations, or a combination thereof, and whose measured data are determined to be below the lower limit of detection ( LLD) for that radionuclide, the site shall report the character string "< LLD" to the WWIS for the activity and mass of that radionuclide; otherwise a value of zero shall be reported. See appendix A, section A. 3, for information pertaining to the development and application of LLD.

In addition, all radionuclides other than the ten WIPP tracked radionuclides ( i. e., 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) that contribute to 95% of the radioactive hazard for the payload container shall be reported on the TRUPACT II bill of lading or manifest in accordance with 49 CFR § 172.203 and 49 CFR § 173.433 ( reference 35, reference 36). The activities and masses of these other radioisotopes shall also be reported to the WWIS along with their associated TMU, expressed in terms of one standard deviation for each waste container ( reference 8).  18  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 18 Compliance: The quantity of radionuclides in each payload container along with the associated TMU values ( expressed in terms of one standard deviation) is determined using the nondestructive assay ( NDA) method described in appendix A and is performed in accordance with work instruction, INST OI 14, Drum Assay Operations. Each radionuclide quantity and its associated TMU are transferred from the DAS to the WTS. The method used to perform the calculations for the radionuclides and associated TMU values are documented in the Canberra Industries, Genie 2000 Spectroscopy System Customization Tools, ICN 9230847F4, NDA 2000 Technical Reference Manual, ICN 9231595C, and Total Measurement Uncertainty for the AMWTP Integrated Waste Assay Systems, CI IDA NDA 0055. For the ten radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 235U, 90Sr, and 137Cs) whose presence can be substantiated from AK, direct measurement, computations, or a combination thereof, and whose measured data are determined to be below the lower limit of detection ( LLD) for that radionuclide, WTS reports the character string "< LLD" to the WWIS for the activity and mass of that radionuclide, otherwise a value of zero is reported.

In addition to the ten WIPP tracked radionuclides, 235U is also quantified, if present above its LLD, in order to calculate the 239Pu Fissile Gram Equivalent ( FGE) for compliance with the TRUPACT II requirements ( see section 3.3.2). All radionuclides other than the ten WIPP tracked radionuclides that contribute to 95% of the radioactive hazard for each container are also stored in the WTS.

The quantity of each radionuclide comprising 95% of the radioactive hazard whose value is above the LLD and its associated TMU expressed in terms of one standard deviation are reported to the WWIS for each payload container and on the TRUPACT II bill of lading or manifest for each shipment.

3.3.2 239Pu Fissile Gram Equivalent Acceptance Criterion. For each payload container and loaded TRUPACT II, the sum of 239Pu FGE plus two times its associated TMU, expressed in terms of one standard deviation, shall comply with the limits in table 3.3.2 ( reference 15, sections 5.9.11 and 5.9.12; reference 45, section 3.1.1). The values calculated for 239Pu FGE and its associated TMU ( expressed in terms of one standard deviation) shall be reported to the WWIS for each payload container.  19  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 19 Table 3.3.2 239Pu FGE Limits Container Type 239Pu FGE Limit 55 gallon drum ( including all pipe overpacks) < 200 SWB < 325 TDOP < 325 TRUPACT II ( containing either 14 55 gallon drums, 2 SWBs, or 1 TDOP) < 325 TRUPACT II ( containing either 14 standard, 14 S100, or 14 S200 pipe overpacks) < 2800 Compliance: The 239Pu FGE quantities in each drum container along with the associated TMU values ( expressed in terms of one standard deviation) is calculated for each container using the radionuclide values determined by the DAS described in appendix A and the associated 239Pu FGE values tabulated in the American National Standards Institute/ American Nuclear Society ( ANSI/ ANS) Standard 8.15 1981, " Nuclear Criticality control of Special Actinide Elements". The method that is used to perform the calculations for the 239Pu FGE and its associated TMU is documented in the Canberra Industries, Genie 2000 Spectroscopy System Customization Tools, ICN 9230847F4, NDA 2000 Technical Reference Manual, ICN 9231595C, and Total Measurement Uncertainty for the AMWTP Integrated Waste Assay Systems, CI IDA NDA 0055. The calculated 239Pu along with its associated TMU are transferred from the DAS in accordance with work instruction INST OI 14, Drum Assay Operations, and is stored in the WTS. The WTS evaluates each payload container and loaded TRUPACT II for compliance with the limits in table 3.3.2. The values calculated for 239Pu FGE and its associated TMU ( expressed in terms of one standard deviation) are reported to the WWIS for each payload container in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.  20  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 20 3.3.3 TRU Alpha Activity Concentration Acceptance Criterion. TRU waste payload containers shall contain more than 100 nCi/ g of alphaemitting TRU isotopes with half lives greater than 20 years. Without taking into consideration the TMU, the TRU alpha activity concentration for a payload container is determined by dividing the TRU alpha activity of the waste by the weight of the waste. The weight of the waste is the weight of the material placed into the payload container ( i. e., the net weight of the container). The weight of the waste is typically determined by subtracting the tare weight of the payload container ( including the weight of the rigid liner and any shielding external from the waste, if applicable) from the gross weight of the payload container. In the event waste containers ( e. g., 55 gallon drums) that have been radioassayed are overpacked in a payload container ( e. g., in an SWB), sites shall sum the individual TRU alpha activity values of the individual waste containers and divide by the sum of the individual net waste weights ( i. e., less container, shielding, and liner weights as appropriate) to determine the activity per gram for the payload container. Loading a 55 gallon pipe overpack with cans is considered direct loading  not overpacking for the purposes of calculating the weight of the container. The TRU alpha activity concentration shall be reported to the WWIS; however, there are no reporting requirements for its associated TMU. ( reference 21, section 2[ 18]; reference 8, chapter 4)

Compliance. The TRU alpha activity in each drum is determined from the alpha emitting TRU isotopes with half lives greater than 20 years. The TRU alpha activity is determined using the DAS in accordance with work instruction, INST OI 14, Drum Assay Operations. The TRU alpha activity concentration for each payload container is calculated by dividing the TRU alpha activity by the net weight of the container ( weight of the waste). The net weight of the container is determined by subtracting the tare weight of the container ( including the weight of the rigid liner and any shielding external to the waste, if applicable) from the gross weight of the container. The method used to determine the gross weight of the container is described in section 3.2.2. The TRU alpha activity concentration is transferred from the DAS and stored on the WTS. In the event a waste drum is overpacked in a payload container, the reported TRU alpha activity concentration for the overpacked payload container is determined by summing the TRU alpha activity values of the individual waste containers and dividing by sum of the net waste weights of the individual waste containers.

The WTS software evaluates each payload container for compliance with the TRU alpha activity concentration limit (> 100nCi/ g). The TRU alpha activity concentration and the associated TMU is reported to the WWIS for payload containers in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.

3.3.4 239Pu Equivalent Activity Acceptance Criterion. Plutonium 239 equivalent curie ( PE Ci) limits are shown in table 3.3.4. PE Ci quantities shall be calculated for each payload container ( see Appendix B) and reported to WIPP using the WWIS. There are no reporting requirements for the associated TMU. ( reference 15, section 5.9.12)  21  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 21 Table 3.3.4 PE Ci Limits Waste Container Packing Configuration 239Pu PE Ci Limit Direct load   all approved waste forms < 80 Direct load   solidified/ vitrified waste only < 1,800 Overpacked into a 85 gallon drum, SWB, or TDOP   all approved waste forms < 1,100 55 gallon drum in good condition Overpacked into a 85 gallon drum, SWB, or TDOP   solidified/ vitrified waste only < 1,800 Overpacked into a 85 gallon drum, SWB, or TDOP   all approved waste forms < 80,   130,   130 respectively 55 gallon drum in damaged condition Overpacked into a 85 gallon drum, SWB, or TDOP   solidified/ vitrified waste only < 1,800 55 gallon pipe component in good condition Direct load   all approved waste forms < 1,800 Overpacked into a TDOP   all approved waste forms < 1,100 85 gallon drum in good condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 Overpacked into a TDOP   all approved waste forms < 130 85 gallon drum in damaged condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 Direct load ( or a bin)   all approved waste forms < 130 Direct load ( or a bin)   solidified/ vitrified waste only < 1,800 Overpacked into a TDOP   all approved waste forms < 1,100 SWB in good condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800 Overpacked into a TDOP   all approved waste forms < 130 SWB in damaged condition Overpacked into a TDOP   solidified/ vitrified waste only < 1,800  22  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 22 Compliance: The plutonium equivalent curies ( PE Ci) for each drum are determined using the DAS in accordance with work instruction, INST OI 14, Drum Assay Operations. Appendix B describes the methodology for calculating the PE Ci value based on the radionuclide values determined by the DAS as described in appendix A. The PE Ci value for overpack containers is calculated by the WTS based on the combined drum data. PE Ci values are transferred from the DAS and stored in the WTS.

The WTS software evaluates each payload container for compliance with the PE Ci limits in table 3.3.4. The PE Ci value is reported to the WWIS for each payload container in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.

3.3.5 Radiation Dose Equivalent Rate Acceptance Criterion. The external radiation dose equivalent rate of individual payload containers shall be   < 200 mrem/ h at the surface. The external radiation dose equivalent rate of the TRUPACT II shall be <

  200 mrem/ h at the surface and < 10 mrem/ h at 2 m. Additional internal payload container shielding, beyond that identified in appendix 2.1 of the TRAMPAC as an integral component of the payload container, shall not be used to meet this criterion. Total dose equivalent rate and the neutron contribution to the total dose equivalent rate shall be reported for each payload container in the WWIS. ( reference 15, section 5.9.12; reference 42, module I, section I. D. 1; reference 45, section 3.2.1)

Compliance: Each container is survey by a Radiological Technician ( RT) and documented per work instructions, INST OI 20, TRUPACT II Operations, and INST OI 21, TRUPACT II Payload Assembly. The highest measured combined dose rate at the drum surface is entered in the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer. The TRUPACT II is also surveyed and the combined dose rate at the surface and 2 m from any side ( excluding the top and bottom) is recorded on the shipping documentation and reported in WWIS. Dose rates for beta gamma and neutron dose are reported separately.

3.3.6 Decay Heat Acceptance Criterion. The sum of the decay heat for each payload container plus its TMU shall be less than or equal to the limits of the assigned shipping category specified in table 5.5 1 of appendix 5.5 of the TRAMPAC. For those payload containers that exceed the decay heat limit, a determination of compliance with the unified flammable ( gas/ VOC) concentration limit as specified in the TRAMPAC allows the payload container to be shipped in the TRUPACT II package under test category ( see section 3.5.5). The values calculated for decay heat and its associated TMU ( expressed in terms of one standard deviation) shall be reported to the WWIS for each payload container. ( reference 45, section 5.2 and appendix 1.2 and 5.5).  23  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 23 Compliance: The decay heat is determined using the DAS in accordance with work instruction, INST OI 14, Drum Assay Operations. The total decay heat from the radioactive decay of the radioisotopes within an individual payload container, and the total decay heat from all payload containers in a TRUPACT II, is determined by calculations using isotopic inventory information for fissile and nonfissile TRU radionuclides and for any non TRU radionuclides present in the payload container. The values for total decay and its TMU are determined using the method described in appendix A. The sum of the calculated value of the decay heat and the total measurement uncertainty at one standard deviation is transferred from the DAS and stored in the WTS.

The WTS or WWIS performs an evaluation to determine if the payload container exceeds the analytical decay heat limit derived from the decay heat limit for shipping categories presented in Appendix 5.5 of the TRAMPAC. As defined in Table 5 2 of Section 5.0 of the TRAMPAC, payload containers of Waste Material Type II. 1 and Waste Type III that meet the criteria for the application of dose dependent G values ( watt* year> 0.012) are assigned a shipping category that uses a dose dependent G value. This assignment revises the four digit G value notation used in the numeric shipping category otherwise assigned to the payload container. For containers that exceed the decay heat limit, a determination of compliance with the unified flammable ( gas/ VOC) concentration limit specified in the TRAMPAC allows the payload container to be shipped under the test category requirements ( see section 3.5.5). The decay heat value and the associated TMU is reported to the WWIS per management procedure, MP TRUW 8.16, WWIS Data Transfer.

The evaluation of payload containers and programmed reassignment of shipping category will be evaluated by WWIS.

3.4 Physical Properties 3.4.1 Residual Liquids Acceptance Criterion. Liquid waste is prohibited at WIPP. Waste shall contain as little residual liquid as is reasonably achievable by pouring, pumping, and/ or aspirating. Internal containers shall also contain no more than 1 inch or 2.5 cm in the bottom of the internal containers. The total residual liquid in any payload container shall not exceed 1 percent by volume of that payload container. If visual examination methods are used in lieu of radiography, then the detection of any liquids in non transparent internal containers will be addressed by using the total volume of the internal container when determining the total volume of liquids within the payload container. ( reference 15, section 5.9.12; reference 42, module II, section II. C. 3. a; reference 42, attachment B, sections B 1c and B 3c; reference 45, section 2.6.1; reference 8, appendix WCL)  24  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 24 Compliance: Radiography ( INST OI 12, Real Time Radiography Operations) and VE ( INST OI 16, Drum Coring Operations, and INST OI 34, VE Operating Procedures and Data Reporting) are used to detect the presence of liquids in payload containers. Residual liquid in well drained bottles, cans or similar rigid containers is restricted to less than 1 in ( 2.5cm) of liquid per container as estimated during the examination process. When the sum of all liquids exceeds one percent of the payload container volume or liquids have been identified in rigid containers above specified limits, the container is segregated and sent to the AMWTF for future treatment. The WTS stores a description of the location of any liquid detected and an estimate of the volume.

When VE is used in lieu of radiography, the liquids identified will be removed and/ or absorbed at the AMWTF. An independent verification ( by a second operator) is performed and documented before closing the container.

3.4.2 Sealed Containers Acceptance Criterion. Payload containers shall be verified to be free of sealed containers greater than 4 liters. ( reference 42, attachment B1, section B1 1a)

Compliance: Radiography ( INST OI 12, Real Time Radiography Operations) and VE ( INST OI 16, Drum Coring, and INST OI 34, VE Operating Procedures and Data Reporting) are used to detect the presence of sealed containers greater than 4L. Radiography is used to nondestructively confirm the absence of prohibited items. Payload containers with sealed containers greater than 4L will be segregated and sent to the AMWTF.

When VE is used in lieu of radiography, the VE operators remove and/ or vent sealed containers. An independent verification ( by a second operator) is performed and documented before closing the container.

3.5 Chemical Properties 3.5.1 Pyrophoric Materials Acceptance Criterion. Pyrophoric radioactive materials shall be present only in small residual amounts (< 1 percent by weight) in payload containers and shall be generally dispersed in the waste. Radioactive pyrophorics in concentrations > 1 percent by weight and all nonradioactive pyrophorics shall be reacted ( or oxidized) and/ or otherwise rendered nonreactive prior to placement in the payload container. Nonradionuclide pyrophoric materials are not acceptable at WIPP. ( reference 15, section 5.9.12; reference 42, module II, section II. C. 3. b; reference 45, section 4.1.1)  25  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 25 Compliance: Nonradionuclide pyrophoric material is subject to the same controls as explosives ( e. g., procurement controls and safety assessments). In general, pyrophoric materials are not permitted in TRU process areas. Processes that require the use of pyrophoric materials require a safety analysis that is used to determine the applicable controls. Generator sites administrative, operational and QA procedures dictate the quantity of pyrophoric materials that enter processes, which are limited and controlled. Operating procedures require that pyrophoric materials be rendered chemically safe by processing before being placed in payload containers ( e. g., oxidation at high temperature in the presence of oxygen).

No pyrophoric materials or pyrophoric radionuclides exceeding one percent of the waste weight have been identified in any of the AK documentation, content code evaluations, or sampling programs.

3.5.2 Hazardous Waste Acceptance Criterion. Hazardous wastes not occurring as co contaminants with TRU wastes ( non mixed hazardous wastes) are not acceptable at WIPP. Each CH TRU mixed waste container shall be assigned one or more EPA hazardous waste codes as appropriate. Only EPA hazardous waste codes listed as allowable in the Hazardous Waste Facility Permit may be managed at WIPP. Wastes exhibiting the characteristic of ignitability, corrosivity, or reactivity ( EPA hazardous waste numbers of D001, D002, or D003) are not acceptable at WIPP. ( reference 42, module II, section II. C. 3. g) Hazardous waste codes are synonymous with hazardous waste numbers. ( reference 42, module II, sections II. C. 3. c and II. C. 4)

Compliance: AK documentation identifies physical and chemical properties of the waste that is confirmed by radiography ( INST OI 12, Real Time Radiography Operations), VE ( INST OI 16, Drum Coring Operations and INST OI 34, VE Operating Procedure and Data Reporting), headspace gas sampling ( INST OI 13, Drum Vent/ Headspace Gas Sampling), and homogeneous waste sampling and analysis ( INST OI 16, Drum Coring Operations, Analytical Chemistry Methods Manual ( ACMM) 2900, Determination of Trace Elements by ICP Atomic Emission Spectrometry, ACMM 7802, Determination of Mercury by Cold Vapor Fluorscence Spectrophotometry, ACMM 8909, Microwave Assisted Digestion of Homogeneous Solids and Soil/ Gravel, ACMM 9260, Volatile Organic Compounds by Gas Chromatography/ Mass Spectrometry ( GC/ MS), ACMM 9270, Semivolatile Organic Compounds by Gas Chromatography/ Mass Spectrometry, ACMM 9441, Determination of Nonhalogenated Volatile Organic Compounds by Gas Chromatography, and ACMM Method 9500, Sample Preparation for Semivolatile Organic Compounds and Polychlorinated Biphenyls) per the AMWTP QAPjP, provides the basis for EPA hazardous waste code assignment. Each Waste Stream Profile Form ( WSPF) documents the applicable hazardous waste codes for each payload container in that waste stream. EPA hazardous waste codes are reported in the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer.  26  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 26 3.5.3 Chemical Compatibility Acceptance Criterion. TRU waste containing incompatible materials or materials incompatible with payload container and packaging materials, shipping container materials, other wastes, repository backfill, or seal and panel closure materials are not acceptable for transport in the TRUPACT II and disposal at the WIPP. Chemical constituents shall conform to the lists of allowable materials in tables 4 1 through 4 8 of the TRAMPAC. Other chemicals or materials not identified in these tables are allowed provided that they meet the requirements for trace constituents as specified in section 4.3 of the TRAMPAC. ( reference 42, module II, section II. C. 3. d; reference 45, sections 4.3 and 4.4)

Compliance: Chemical compatibility studies of the waste and the packaging ensure that the chemical processes do not threaten the safe transport of the TRUPACT II. Only waste listed in the TRUPACT II Content Codes ( TRUCON), DOE/ WIPP 89 004, will be shipped in the TRUPACT II. Potential chemical incompatibilities were evaluated by the NRC for each content code, between one content code and another and between each content code and the TRUPACT II inner containment vessel ( ICV) and the oring seals. Waste generated by new processes, or an existing process that has changed, will be evaluated by the WIPP TRUPACT II Cognizant Engineer to ensure that compliance with the transportation requirements of the TRAMPAC can be demonstrated. New or revised TRUCON codes will not be shipped without written notification indicating approval by the WIPP TRUPACT II Cognizant Engineer. Waste compatibilities with backfill, seal, and panel closure materials are verified through the use of approved TRUCON codes.

All payload containers selected for shipment to WIPP are evaluated in accordance with management procedure , MP TRUW 8.5, TRU Waste Certification, and the e TRAMPAC software to ensure that waste that is shipped belongs to an approved TRUCON Content Code.

3.5.4 Explosives, Corrosives, and Compressed Gases Acceptance Criterion. Waste shall contain no explosives, corrosives, or compressed gases ( pressurized containers). ( reference 15, section 5.9.12; reference 42, module II, section II. C. 3. g; reference 45, section 4.2.1)

Compliance: Most generator sites did not allow explosives in the same facility as TRU waste. Waste generating processes were assessed for safety hazards such as potential explosive hazards and potential inadvertent production of explosive materials. Corrosive liquids were neutralized or absorbed by the generator sites before being shipped to the INEEL. Content code assessments have been performed to ensure liquids have been adequately neutralized.

AK documentation identifies physical and chemical properties of the waste that is confirmed by radiography ( INST OI 12, Real Time Radiography Operations), VE ( INST OI 16, Drum Coring Operations, and INST OI 34, VE Operating Procedure and Data Reporting),( for liquids, pressurized containers, and compressed gases), and continuing intrusive characterization per the AMWTP QAPjP confirm the absence of corrosives and explosives.  27  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 27 Payload containers that are suspected to contain explosives or compressed gases will be segregated and sent to the AMWTF for corrective action.

3.5.5 Headspace Gas Concentrations Acceptance Criterion. The headspace gas of payload containers shall be sampled and analyzed in accordance with an approved site specific QAPjP, as defined in the WIPP WAP, to determine volatile organic compound ( VOC) concentrations. ( reference 42, module II, section II. C. 3. I)

Flammable VOCs are restricted to < 500 ppm in the payload container headspace. For those payload containers that exceed the flammable VOC limit, a determination of compliance with the unified flammable ( gas/ VOC) concentration limit as described in the TRAMPAC allows the payload container to be shipped in the TRUPACT II under a test category. ( reference 45, section 5.2 and appendix 5.7) Test category payload containers shall be tested to quantify the hydrogen/ methane, VOC, and total gas generation rates ( as appropriate) for purposes of determining if all applicable limits are met. ( reference 45, section 5.2, appendix 1.2 and 5.7)

Compliance: All payload containers selected for shipment to WIPP will undergo headspace gas sampling in accordance with work instruction, INST OI 13, Drum Vent/ Headspace Gas Sampling, to determine volatile organic compound ( VOC) concentrations and demonstrate the total flammable VOC concentrations are < 500 ppm.

When payload containers exceed the analytical decay heat limit and the concentration of flammable VOCs exceeds 500 ppm, the container belongs to the test category. Full drum testing in accordance with work instruction, INST OI 18, Gas Generation Testing Operations, and/ or e TRAMPAC evaluation is performed to verify that all applicable limits are met.

3.5.6 Polychlorinated Biphenyl Concentration Acceptance Criterion. Waste shall contain no polychlorinated biphenyl ( PCB) concentrations equal to or greater than 50 parts per million ( ppm). ( reference 42, module II, section II. C. 3. f)

Compliance: AK documentation verified by homogeneous waste sampling and analysis ( for organic sludge forms suspected of containing PCBs) in accordance with work instruction, INST OI 16, Drum Coring , ACMM Method 9080, Determination of Polychorinated Biphenyls by Gas Chromatography, and ACMM Method 9500, Sample Preparation for Semivolatile Organic Compounds and Polychorinated Biphenyls, are used to confirm that payload containers contain less than 50 ppm PCBs.  28  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 28 Radiography ( INST OI 12, Real Time Radiography Operations) or VE ( INST OI 16, Drum Coring Operations or INST OI 34, VE Operating Procedure and Data Reporting) is used to confirm the absence of prohibited waste items. If there is any reason to suspect that an item ( i. e., ballasts, transformers) may contain PCBs, the item will be identified as such and the payload container segregated and sent to AMWTF until the correct disposition can be ascertained.

3.6 Data Package Contents 3.6.1 Characterization and Certification Data Acceptance Criterion. Sites shall prepare a WSPF for each waste stream. Each WSPF shall be approved by the CBFO prior to the first shipment of that waste stream. Characterization and certification information for each payload container shall be submitted to the WWIS and approved by the Data Administrator. Sites are required to estimate the CPR weights and report these estimates in the WWIS on a payload container basis. Any payload container from a waste stream that has not been preceded by an appropriate certified WSPF is not acceptable at WIPP. ( reference 42, attachment B, section B 4b[ 2])

Compliance: The SPM or designated alternate prepares and approves the WSPF and Data Summary Reports in accordance with management procedure, MP TRUW 8.14, Preparation of Waste Stream Profile Forms. A hard copy of the WSPF and Data Summary Report are then transmitted to WIPP for approval. This transmittal is coordinated with the initial characterization data transfer to the WWIS in accordance with management procedure, MP TRUW 8.16, WWIS Data Transfer, for the Data Administrator review and approval. Payload containers from a waste stream that does not have an approved WSPF, will not be certified and shipped.

3.6.2 Shipping Data Acceptance Criterion. Sites shall prepare either a bill of lading or a uniform hazardous waste manifest for CH TRU waste shipments as required by the transportation requirements. The land disposal restriction notification for CH TRU mixed waste shipments shall state that the waste is not prohibited from land disposal. For shipment in TRUPACT II, the following documents shall be prepared for containers and assemblies, as appropriate: payload container transportation certification document ( PCTCD); overpack payload container transportation certification document ( OPCTCD); and payload assembly transportation certification document ( PATCD). ( reference 42, attachment B, section B 4b( 2); reference 45, section 6, appendices 6.1 and 6.2)

Compliance: The Transportation Certification Official ( TCO) will review and sign, as appropriate, the PCTCD, OPCTCD, and PATCD generated by the WTS or WWIS. The TCO verifies that all requirements for the transportation parameters have been met and completion of the signature authorizes payload containers for shipment in the TRUPACT II in accordance with management procedure, MPTRUW 8.5, TRU Waste Certification.  29  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 29 The AMWTP will coordinate the preparation of either a bill of lading or a uniform hazardous waste manifest for each CH TRU waste shipment in accordance with management procedure, MP TRUW 8.12, Waste Receipt and Shipping Inspection. The land disposal restriction notification for CH TRU mixed waste shipments that the waste is prohibited from land disposal.  30  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 30 4.0 QUALITY ASSURANCE REQUIREMENTS Quality assurance is an integral part of TRU waste characterization, certification, transportation, and operation activities. This section defines the QA program requirements that assure TRU waste characterization, certification, and transportation activities are performed satisfactorily. The QA requirements applicable to WIPP are addressed in the QAPD ( reference 7).

The AMWTP is responsible for developing, documenting, and implementing a site specific QA plan that address the elements of the QAPD that govern TRU waste characterization, certification, and transportation activities. This section defines the QA program requirements for TRU waste characterization, certification, and transportation activities performed by the AMWTP. This Certification Plan will be submitted to the CBFO for approval before TRU wastes are characterized, certified, or shipped to WIPP. The CBFO and AMWTP will conduct audits and surveillances to ensure compliance with this plan. When the QAPD is revised, AMWTP QA plan, procedures, and activities will be evaluated for changes to requirements, and revisions will be initiated and implemented, as appropriate.

4.1 Waste Characterization QA Requirements The Quality Assurance Project Plan ( QAPjP), MP TRUW 8.2, documents the QA and quality control ( QC) activities applicable to TRU characterization. Analytical laboratories analyzing WIPP waste characterization samples for the AMWTP have established, documented QA/ QC programs.

Data quality objectives are qualitative and quantitative statements that specify WIPP program technical and quality objectives; they are determined through the data quality objective process ( reference 25). The data quality objectives for waste characterization activities relating to physical and chemical properties of the waste are contained in the WAP of the WIPP Hazardous Waste Facility Permit ( reference 42, attachment B3). The radioassay data quality objectives are given in appendix A of this document.

Payload containers with unresolved discrepancies associated with hazardous waste characterization will not be managed or disposed of at WIPP until discrepancies are resolved ( reference 42, attachment B4, section B4 4). Corrective action reports applicable to WIPP WAP requirements shall be resolved prior to waste shipment ( reference 42, attachment B6, section B6 4).

4.2 Waste Certification QA Requirements The Certification Plan for INEEL Contact Handled Transuranic Waste, MP TRUW 8.1, describes the QA and QC activities applicable to certification of TRU waste to the CH WAC that comply with the requirements of the QAPD ( reference 7).

The TRU Waste Program Procedures Matrix for the DOE CBFO QAPD, MP TRUW 04 IM, identifies applicable documents for each organization or project that implement each applicable requirement of the QAPD. The matrix pertains to all AMWTP waste characterization, certification, and transportation activities. This matrix will be updated as implementation procedures are revised.  31  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 31 4.3 Waste Transportation QA Requirements Quality assurance requirements for the transportation of TRU waste involve two elements: compliance with TRUPACT II payload control requirements and compliance with TRUPACT II usage requirements. The QA requirements for payload control compliance derived from the certificate of compliance for the TRUPACT II issued by the NRC ( reference 43). The certificate of compliance references the TRAMPAC ( reference 45). The QA requirements for compliance with TRUPACT II usage requirements are derived from 10 CFR Part 71, 49 CFR, Part 173 ( references 28 and 36), the TRUPACT II certificate of compliance ( reference 43), DOE Orders 460.1 and 460.2 ( references 5 and 6), and the CH Packaging Program Guidance ( reference 17).

The TRUPACT II Authorized Methods for Payload Control ( TRAMPAC), MP TRUW 8.3, describes the QA and QC activities applicable to the specific parameters of the transportation packaging methods for payload control and the Certification Plan for INEEL Contact Handled Transuranic Waste, MP TRUW 8.1, describes the QA and QC activities applicable to the usage of the TRUPACT II. These documents control the used of the NRC certified packaging ( TRUPACT II) and comply with the CH Packaging Program Guidance ( reference 17).

4.4 Quality Assurance Program The AMWTP Quality Assurance Program ( QAP) is based on the QAPD ( reference 7) elements outlined below. Table 4.0.1 provides a cross reference of identical or related QA requirement elements from 10 CFR 830 Subpart A ( reference 30) and 10 CFR 71 ( reference 29).

  Organization and QA Program ( QAP) documents the organizational structure, primary interfaces, functional responsibilities, levels of authority, and lines of communication for activities affecting quality, and identifies the activities and items to which the QA program applies.

  Personnel Qualification and Training identifies the AMWTP qualification and training programs and plans established to ensure personnel are provided training to perform their assignments and maintain job proficiency.

  Quality Improvement describes the processes to detect and prevent conditions adverse to quality, pursue continuous quality improvement, and control and correct nonconforming items.

  Documents and Records describes the processes for preparation, review, approval, issue, use, revision, and control of the AMWTP documents and records.

  Work Processes identifies the processes by which work conditions, equipment, and special processes are controlled to ensure quality.

  Procurement identifies the technical and QA requirements for procured items and services.

  Inspection and Testing identifies the processes for inspection and testing.  32  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 32   Assessment Requirements describes the requirements for conducting management and independent assessments to measure management effectiveness, item quality, and process effectiveness and to promote improvement.

  Sample Control Requirements identifies the requirements for the control of waste samples, including identification, handling, storing, shipping, and archiving.

  Scientific Investigation Requirements describes the requirements for defining, controlling, verifying, and documenting scientific investigations.

  Software Requirements specifies the requirements for developing, procuring, maintaining, and using software.

Table 4.0.1. Quality assurance requirements cross reference table.

QAPD and Certification Plan Section Equivalent Section in 10 CFR 830. Subpart A, Nuclear Safety Management Equivalent Section in 10 CFR Part 71, Subpart H, Quality Assurance Organization and QA Program Program QA Organization QA Program Personnel Qualification and Training Personnel Training and Qualification QA Program Quality Improvement Quality Improvement Corrective Action Nonconforming Materials, Parts, or Components Documents Records Documents and Records Document Control QA Records Work Processes Work Processes Instructions, Procedures, and Drawings Identification and Control of Materials, Parts, and Components Control of Special Processes Procurement Procurement Procurement Document Control Control of Purchased Material, Equipment, and Services Inspection and Testing Work Process and Acceptance Testing Internal Inspection Test Control Control of Measuring and Test Equipment  33  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 33 QAPD and Certification Plan Section Equivalent Section in 10 CFR 830. Subpart A, Nuclear Safety Management Equivalent Section in 10 CFR Part 71, Subpart H, Quality Assurance Inspection, Test, and Operating Status Handling, Storage, and Shipping Assessment Requirements Management Assessment Independent Assessment Audits Sample Control Requirements Work Processes Not applicable Scientific Investigation Requirements Not applicable Not applicable Software Requirements Not applicable Not applicable 4.4.1 AMWTP TRU Program Organization The TRU Program organization is part of the overall AMWTP organization as defined in MP ADMN 1.19, AMWTP Organization Charts. This section describes the principal organizations involved, the project level positions, and their primary responsibilities. Data generation organizations also support the AMWTP. The central organizational structure is depicted in Figure 4.1.

AMWTP General Manager has overall responsibility for all aspects of the AMTWP, which includes permitting, designs to construction, commissioning, operations, waste certification, packaging, and transportation.

AMWTP Operations Manager is responsible for the safe, efficient production of acceptable waste packaged for disposal at WIPP. Provides commissioning and operations planning and strategies. Ensures planning and execution of the WIPP certification program. Reports to the AMWTP General Manager.

TRU Waste Program Manager is responsible for the planning, execution, implementation, and coordination of activities associated with the characterization, certification, packaging and transportation of waste for disposal in the WIPP, and ensures compliance with applicable requirements. Reports to the Operations Manager.

BNFL Inc. Corporate Quality Assurance Manager, is responsible for providing qualified quality professionals to the AMWTP. The Corporate QA Manager provides professional training and, where applicable, certified individuals to perform QA related activities.

AMWTP Quality Assurance Manager. ensures development of the QA program and provides QA oversight of work performed by BNFL Inc. and subcontractors in accordance with the plan requirements. Reports to the General Manager and independently to the BNFL Inc. Corporate QA Manager.  34  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 34 Site Project Manager ( SPM) has overall responsibility for ensuring that CH TRU is successfully characterized in accordance with the WIPP WAP. The SPM ( or designated alternates) responsibilities include:

  Ensuring that adequate technical and QA training is provided for personnel performing activities subject to the DOE/ CBFO QAPD.

  Reviewing and recommending approval of the QAPjP and subsequent revisions before it is submitted to CBFO for approval   Waste selection and tracking   Data validation/ verification   Data reconciliation with data quality objectives ( DQOs)

  Assignment of EPA Hazardous Waste Numbers   Preparing of the Waste Stream Characterization Package   QA/ QC reports to the CBFO   Characterization data transmittal to CBFO.

Site Quality Assurance Officer ( or designated alternate) reports to the AMWTP QA Manager and is responsible for developing, documenting, and monitoring the implementation of QA documentation specific to the characterization, certification, and transportation activities. These responsibilities include, but are not limited to:

  Reviewing the AMWTP QAPjP and subsequent revisions   Day to day guidance to the project staff on quality related matters   Scheduling and conducting QA assessments   Nonconformance tracking and corrective action verification   Data validation/ verification   Data QA documentation verification   Tracking and performing trend analysis of quality problems, and reporting quality problem areas   Preparing QA/ QC reports to Site Project Manager.  35  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 35   Maintaining liaison with participant QA organizations and other affected organizations     Ensuring preparation, review, and issuance of QA plans and procedures that implement the provisions of the DOE/ CAO QAPD The SQAO has the authority, access to work, and organizational freedom to identify quality problems, make recommendations for resolution, and verify implementation of corrective actions. In addition, the SQAO will ensure that unsatisfactory conditions are controlled until proper corrective actions have been completed.

To ensure the independence of this QA function, the SQAO is deployed from the AMWTP QA Manager with established lines of communication to the SPM.

Waste Certification Official ( WCO), or designated alternate, is responsible for documenting and certifying that all TRU waste payload containers prepared for shipment to the WIPP meet all WAC, and for transmitting the waste certification data to the WIPP. The WCO is responsible for final compilation and approval of CH TRU Waste Certification Statements. The same or different individuals may perform the functions of the WCO and the TCO.

Transportation Certification Official ( or designated alternate), is responsible for documenting and certifying the compliance of payload containers and assemblies with transportation requirements. The TCO approves by signature the transportation certification documents for every payload selected for transport. The same or different individuals may perform the functions of the WCO and the TCO.  36  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 36 DOE/ CBFO DOE ID Project Manager AMWTP General Manager AMWTP Operations Manager TRU Program Manager AMWTP Quality Assurance Manager BNFL Inc. Corporate QA Manager BNFL Inc. Manager ES& H/ QA Waste Certification Official Transportation Certification Official Site Project Manager Site Quality Assurance Officer Site Project Office Lines of Authority:

Lines of Communication:

Figure: 4.1 AMWTP TRU Program Organization Structure  37  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 37 4.4.2 AMWTP QA Program Description This QAP applies to items and activities affecting AMWTP quality. QA activities are integrated into the AMWTP through reviews, assessments, inspections, and approval and control of records and documents. The AMWTP has identified the SPM, SQAO, WCO, and TCO as being responsible for ensuring QA within the AMWTP TRU Program. All personnel involved with TRU waste characterization, certification, packaging, and transportation ensure the quality of their activities and products. If work is delegated, the individual making the delegation retains responsibility for the delegated work. The SQAO and the cognizant AMWTP personnel will resolve disputes related to QAP requirements.

AMWTP TRU Program personnel plan certification activities and document this process. Planning documentation is subject to review by TRU Program management and subject matter experts ( SMEs). Project planning documentation consists of the documents discussed in this section, implementing procedures, and training plans. These documents establish performance criteria and methods to measure performance relevant to the AMWTP. All Site Project Office ( SPO) personnel are accountable for ensuring quality within their assigned areas of responsibility; however, the SQAO is responsible for determining the effectiveness of this QAP, which is accomplished through internal reporting procedures, assessments, and surveillance's performed in accordance with MP M& IA 17.1, Management Assessments, MP M& IA 17.2, Independent Assessments, and MP M& IA 17.3, Surveillances, respectively.

AMWTP management at all levels has established communication channels that provide timely and wide dissemination of information related to performance, which includes:

  QA program status   Lessons learned   Quality improvement   Results of trend analysis  38  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 38 4.4.3 Implementation of the CBFO QA Program The provisions of the AMWTP QAP are implemented through the use of numerous program documents and procedures. The relationships between the various external requirements sources and AMWTP programmatic and implementing documents are depicted in Figure 4.2, AMWTP document hierarchy. Implementing procedures are listed within sub tier program plans, matrices, or other documents. Documents, which collectively define these activities, are presented below:

NRC TRUPACT II CERTIFICATE OF COMPLIANCE1 NMED WIPP HAZARDOUS WASTE FACILITY PERMIT1 DOE/ CBFO WIPP CH SAFETY ANALYSIS REPORT ( FEIS, SEIS I, SEIS II) EPA WIPP COMPLIANCE CERTIFICATION DECISION CONGRESS WIPP LAND WITHDRAWAL ACT WIPP CH TRU WASTE ACCEPTANCE CRITERIA AMWTP TRAMPAC2 MP TRUW 8.3 AMWTP QUALITY ASSURANCE PROJECT PLAN2 MP TRU 8.2 AMWTP CERTIFICATION PLAN2 MP TRU 8.1 AMWTP TRU WASTE PROGRAM PROCEDURES MATRIX FOR DOE CBFO QAPD MP TRUW 04 IM ( REQUIREMENTS)

( CRITERIA) WIPP QUALITY ASSURANCE PROGRAM DOCUMENT IMPLEMENTING PROCEDURES Figure 4.2 AMWTP TRU Program document hierarchy.  39  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 39 4.4.4 Graded Approach Implementation of the AMWTP QAP is based on the application of the graded approach. The levels of analysis, documentation, verification, and other controls are applied commensurate with an item's risk and importance. The AMWTP graded approach process is implemented in accordance with, Graded Approach, MP Q& SI 5.6. The AMWTP QA Manager is responsible for review and concurrence with quality level designations for the AMWTP Systems, Structures, and Components. MP Q& SI 5.6, Graded Approach, is submitted to the CBFO QA Manager for approval for use in the AMWTP.

4.5 Personnel Qualification And Training Personnel performing AMWTP TRU Program activities affecting quality receive QA indoctrination and are qualified and trained to ensure that suitable proficiency is achieved and maintained in the performance of their assigned tasks 4.5.1 Qualification The appropriate managers, with support of the training organization, determine job positions and qualification standards for each job category relevant to the AMWTP. Task responsibilities for personnel are analyzed to ensure education, experience, and training prerequisites is commensurate with minimum requirements specified in accordance with Job and Training Needs Analysis, MP RTQP 14.6 4.5.2 Training The appropriate managers ensure that all applicable AMWTP personnel receive indoctrination and training on the scope, purpose, and objectives of the TRU Program and the specific Quality Assurance Objectives ( QAOs) of the tasks being performed. Personnel performing activities affecting quality are trained according to their respective training plans to ensure they achieve and maintain proficiency prior to performing any tasks subject to these QAP requirements. Personnel receive initial and continuing training requisite with their activities and level of responsibility in accordance with MP RTQP 14.4, Personnel Qualification and Certification, and MP RTQP 14.20, Training Implementation Matrix. Training is designed, developed, conducted, and evaluated in accordance with MP RTQP 14.1, Preparation and Administration of Individual Training Plans.. Training programs may include classroom instruction, practical hands on experience, supervised on the job training, self paced individual study, and written, oral, or practical demonstration of worker competence. The period of effectiveness for qualification associated with special processes, operations that require special skills, and the requalification criteria are specified or referenced Personnel Qualification and Certification, MP RTQP 14.4 or supporting training program plans.  40  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 40 Nondestructive examination ( NDE) and Nondestructive assay ( NDA) is considered to be a characterization process, therefore, personnel performing NDE are qualified to a program based on the American Society of Nondestructive Testing ( ASNT) Recommended Practice No. SNT TC 1A and personnel performing NDA are qualified to ASTM C1490, Standard Guide for selection, training and qualification of NDA personnel. Personnel performing helium leak testing of the TRUPACT II are qualified in accordance with ASNT SNT TC 1A and its applicable supplements.

Training is subject to ongoing review to determine instruction and training program effectiveness and shall be upgraded whenever improvements or enhancements are identified in accordance with Preparation and Administration of Individual Training Plans, MP RTQP 14.1.

Personnel performing TRU Program activities affecting quality receive indoctrination in the following:

  General criteria, this QAP, and applicable codes, regulations, and standards   Specific criteria, including the QAPjP, Certification Plan, TRAMPAC, and the applicable implementing procedures.

Auditable records documenting the required training and qualifications are maintained as QA records and controlled in accordance with MP RTQP 14.19, Training Records Administration.

4.6 Quality Improvement AMWTP personnel continually evaluate and improve project activities. Personnel are responsible for identifying nonconforming items and processes that do not meet established requirements are identified, controlled, and corrected in accordance with MP Q& SI 5.4, Identification of Nonconforming Conditions and MP Q& SI 5.3, Corrective Action.

4.6.1 Conditions Adverse To Quality A condition adverse to quality is an all inclusive term used in reference to failures, malfunctions, deficiencies, and nonconforming items, materials, parts, components, data, and processes. Significant conditions adverse to quality are those that, if uncorrected, could have a serious effect on safety, operability, waste isolation, TRU waste site certification and shipment, regulatory compliance demonstration, or effective implementation of the QA program.

Conditions adverse to quality are classified according to their significance and the corrective action developed accordingly.

The SQAO ensures that quality in the TRU Program by identifying and reporting conditions adverse to quality, analyzing trends, reporting and tracking nonconformances, and implementing corrective actions in accordance with MP Q& SI 5.1, Investigations and Root Cause Analysis. These quality improvement activities detect and prevent unacceptable quality problems and thereby increasing accuracy and reliability, and reducing variability.  41  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 41 4.6.2 Controlling Conditions Adverse To Quality Conditions adverse to quality are investigated and documented, including the extent of the condition and the impact on completed work. As appropriate, corrective action plans are developed, documented and implemented as soon as practicable.

The SQAO notifies CBFO of all conditions adverse to quality affecting waste to be shipped to WIPP and forwards all reports upon issuance and again upon closure related to violations of the WAP ( reference 42, Attachment B) to CBFO for tracking. All deficiencies are evaluated for Price Anderson Amendments Act applicability and reporting and require verification of completion of assigned action items prior to closure.

All violations of the WAP must be managed as a significant condition adverse to quality. Significant conditions adverse to quality are reported and evaluated by the AMWTP QA Manager, other relevant regulatory compliance organizations ( e. g., environmental and safety), and the responsible management, to determine if a work suspension is necessary. If a work suspension is warranted, the SQAO, the AMWTP QA Manager, or the BNFL Inc. Corporate QA Manager verifies and documents the completion of applicable corrective actions prior to any management action releasing the work suspension. AMWTP work suspensions are processed in accordance with Identification of Nonconforming Conditions, MPQ SI 5.4.

The CBFO is notified of Corrective Action Reports that relate to violations of the WAP. Corrective Action Plans relating to these violations of the WAP and all DOE/ CBFO issued Corrective Action Reports ( CARs) address corrective action planning and follow up for significant conditions adverse to quality. Instructions governing these activities are detailed in procedures referenced in Identification of Nonconforming Conditions, MP Q& SI 5.4.

4.6.3 Nonconforming Items Management at all levels fosters a " no fault" attitude to encourage the identification of nonconforming items and processes. Nonconformances are uncontrolled and unapproved deviations from an approved plan or procedure. Nonconforming items are those that do not meet the AMWTP requirements, procurement document criteria, or approved work procedures. All AMWTP personnel are responsible for promptly reporting any nonconformance condition identified as adverse to quality to management.

The AMWTP identifies and documents nonconformances. The nonconformance process is controlled in accordance with Identification of Nonconforming Conditions, MP Q& SI 5.4. This procedure describes AMWTP specific nonconformance procedures and communication with WIPP concerning nonconformance tracking and resolution. It also describes the methods to identify, control, and dispose of nonconforming items ( nonconforming items are identified by marking, tagging, or segregating the items).

Identification of Nonconforming Conditions, MP Q& SI 5.4 is used for nonconformances identified during data generation level and project level data review. AMWTP nonconformance reports ( NCRs) are processed electronically and/ or tracked in hard copy.  42  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 42 An NCR is prepared for each nonconformance identified, including or referencing, as appropriate, results of laboratory analysis, QC tests, audit reports, internal memoranda, or letters. The NCR provides the following information:

  Identification of the individual( s) identifying or originating the nonconformance   Description of the nonconformance   Method( s) or suggestions for correcting the nonconformance ( corrective action)

  Schedule for completing the corrective action   An indication of the potential ramifications and overall usability of the data, if applicable   Any approval signatures specified in the site nonconformance procedures.

Identification of Nonconforming Conditions, MP Q& SI 5.4, also assigns responsibilities to AMWTP organizations and personnel to identify, report, control, evaluate the nonconformances, obtain and document a disposition, determine cause, track, and define corrective action for reported nonconforming items. The SQAO ( or designated alternate) oversees the AMWTP NCR process. The SPM and SQAO are notified when a nonconformance related to the AMWTP TRU Program is observed or detected. Operations, SPM and SQAO are responsible for evaluating nonconformances and taking appropriate corrective action.

Documentation of nonconformances is made available to the SPM. CBFO receives written notification of all non administrative nonconformances ( that is, a failure to meet a DQO specified by the WAP) or confirmatory analytical techniques specified in the WAP are inconsistent with AK documentation first identified during the SPM review level within five days of identification. These NCRs are also submitted to CBFO within 30 days of identification ( reference 42, Attachment B, Section B3 13).  43  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 43 4.6.4 Corrective Action and Planning Follow up Corrective actions are planned and prepared for all significant conditions adverse to quality and for any violation of the WAP. The quality systems established for corrective actions and reporting are described in MP Q& SI 5.3, Corrective Action. The AMWTP identifies and implements corrective actions before TRU waste is shipped to WIPP. Corrective Action Reports ( CARs) generated by CBFO are tracked in hard copy and processed per CBFO instructions. These corrective actions address considerations including:

  The extent and impact of the significant condition adverse to quality   Actions to resolve the initial problem   Root cause of the problem   Actions to be taken to preclude recurrence   Responsible personnel, responsibilities, and expected completion dates for the required actions.

A follow up of completion of proposed corrective actions occurs to verify timeliness and effectiveness of implementation.

4.6.5 Improvement Analysis Performance data are identified, collected, and routinely analyzed to identify opportunities to improve items, activities, and processes. Analysis of quality performance data serves to identify trends adverse to quality. These analyses shall consider information from external sources and not be limited to one type of work or to one organization. Reports of conditions adverse to quality are evaluated to identify adverse quality trends and identify root causes, with results reported to responsible management and to the applicable quality assurance organization. The SQAO is responsible to generate a TRU Programs trend analysis report semiannually in accordance with MP Q& SI 5.1, Investigations and Root Cause Analysis.  44  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 44 When conditions adverse to quality are identified on a recurring basis, actions are taken to evaluate those conditions in order to minimize their impact and to preclude recurrence. For recurring conditions adverse to quality, management shall, as appropriate:

  Determine the events leading to the occurrences   Develop an understanding of the technical and work activities associated with the conditions adverse to quality   Ascertain and identify any generic implications and impacts on completed work   Determine the extent to which similar quality problems, or precursors to the problem, have been recognized by the responsible organization   Determine the effectiveness of any corrective actions that were taken   Consider suspending work associated with the applicable activity   Suggest actions that can be taken by the responsible organization to preclude recurrence.

4.7 Documents and Records 4.7.1 Document Control Documents that specify quality requirements or establish activities affecting quality are controlled to ensure that accurate and current documents are used. Document Control personnel ensure that documents are approved, distributed, filed, and maintained in accordance with current procedures.

AMWTP personnel prepare and control documents supporting quality in accordance with management procedure, MP DOCS 18.4, Document Control. Document owners ensure that documents are developed as prescribed by current procedures, reviewed for adequacy, correctness, completeness, and are approved and revised, as needed. Document control personnel verify proper document approval and ensure the documents are distributed to the appropriate personnel.  45  AMWTP MANAGEMENT PROCEDURE User responsible to ensure correct revision is used MP TRUW 8.1, Revision 2 Issued: 06/ 11/ 03 Effective: 06/ 11/ 03 Certification Plan for INEEL Contact Handled Transuranic Waste 45 4.7.2 Document Preparation, Review, Approval and Issuance Instructions, procedures, and drawings are reviewed for adequacy, correctness, and completeness prior to approval and issuance. MP DOCS 18.1, Developing Written Work Instructions, addresses approved AMWTP policies and procedures for the initiation, preparation, review, and revision control of work instructions and MP DOCS 18.3, Developing Management Procedures, addresses approved AMWTP policies and procedures for the initiation, preparation, review, and revision control of management procedures for all quality related activities. Non routine/ temporary processes may be addressed by making temporary changes in procedures and plans. CBFO approves quality affecting changes prior to implementation.

Qualified and independent personnel review all quality documents for adequacy, correctness, and completeness prior to approval and issuance. MP DOCS 18.4, Document Control, identifies the individuals and/ or organizations responsible for the preparation, review, approval, and issuance of controlled documents.

  Documents are controlled during the review and approval phase, by the document owner, in accordance with approved procedures.

  The requesting organization identifies the applicable criteria for the review. These criteria consider technical adequacy, accuracy, completeness, and compliance with established requirements.

  Pertinent background information or data are made available by the organization requesting the review if the information is not readily available to the reviewer.

  Individuals other than the originator perform this review.