Radiation Dose Rate Less Than or Equal to the limits specified in Subsection <IP_ADDRESS>, Table 4.4 2 of this Certification Plan   The limit applies only to the outermost payload container. If an SWB overpack will be overpacked in a TDOP, the limit for radiation dose rate applies only to the TDOP.   Filter Identification If a payload container will be overpacked, the limit applies to only the outermost payload container. The number of filters will be documented depending on container type. For fixed configurations ( e. g., pipe overpacks), the filter information shall be documented for both the payload containers ( e. g., inner pipe component and outer drum).

Overpacked Container Measured Parameters   Overpacked Container ID Number   List the site specific identification number for each of the overpacked payload containers.   Measured Weight and Measurement Error   The measured weight and measurement error ( one standard deviation) for each overpacked payload container or the entire overpack configuration shall be recorded and is limited to the outermost container configuration. The measured weight and measurement error may be obtained from PCTCD( s) or HNF 2600, REV 15 Page 181 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN OPCTCD for each overpacked payload container. The measured weight of the individual overpacked payload containers is not required if the entire overpack configuration will be weighed. If the weight of each individual overpacked payload container is recorded, enter the weight and measurement error ( one standard deviation) of the empty overpack payload container on the last row. Calculate the total weight as the sum of each of the individual weights ( including the weight of the empty overpack container), and record this value in the appropriate box. Calculate the root mean square ( RMS) 1 error for the overpack configuration as the square root of the sum of the squares of the individually listed errors, and record this value in the appropriate box. If the entire overpack configuration is weighed, record the total weight of the overpack configuration and the measurement error ( one standard deviation) in the appropriate boxes ( in this case, the measurement error is the same as the RMS [ calculated as RSS] error).   Measured Decay Heat and Measurement Error   The measured decay heat value and measurement error ( one standard deviation) for each overpacked analytical category payload container shall be recorded. The measured decay heat value and measurement error may be obtained from the PCTCD( s) or OPCTCD for each overpacked payload container. For analytical category payload containers, the decay heat value plus the measurement error for each payload container shall be compared individually to the governing decay heat limit for the overpacked configuration.   Decay heat Limit   For analytical category payload containers, the maximum allowable decay heat limit per overpacked payload container for the applicable payload shipping category shall be recorded from the PCTCD( s) or OPCTCD. The decay heat limits are recorded for use in determining the governing decay heat limit.   Measured Fissile Mass ( FGE) and Measurement Error   The measured fissile mass and two times the measurement error ( two standard deviations) for each payload container shall be recorded as obtained from the PCTCD( s) or OPCTCD for each overpacked payload container. The subtotal fissile mass plus the total RMS ( calculated as RSS) error ( RMS [ calculated as RSS] of twice each individual measurement error) or the entire overpack configuration shall be compared to the maximum allowable fissile mass limit for the outermost payload container of the overpack configuration ( i. e., 325 FGE per SWB or per TDOP).   Hydrogen/ Flammable Gas Generation Rate   The hydrogen/ flammable gas generation rate for each overpacked test category payload container shall be recorded. The hydrogen/ flammable gas generation rate limit for each payload container ( analytical or test category) shall be recorded for later use in completing the PATCD. For test category payload containers, the hydrogen/ flammable gas generation rate for each payload container shall be compared individually to the governing hydrogen/ flammable gas generation rate limit.   Hydrogen/ Flammable Gas Generation Rate Limit   For test category and analytical category payload containers, the hydrogen/ flammable gas generation rate limit per 1 Use of the term " root mean square" or " RMS" is calculated as " root sum of squares" or " RSS." Whenever a WIPP or TRU document, form, or software references RMS, this shall be interpreted to mean RSS. HNF 2600, REV 15 Page 182 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN overpacked payload container for the applicable payload shipping category shall be recorded from the PCTCD( s). The hydrogen/ flammable gas generation rate limits are recorded for use in deterring the governing limit.   Flammability Index ( FI) If mixing shipping categories within an overpack, calculate the FI for each overpack container as directed in Appendix 2.4 of the CH TRU Payload Appendices after selecting the overpacking containers comprising the payload assembly. Calculation is typically performed by a verified/ validated software package. FI is only applicable to overpacking payload containers of different shipping categories. For overpacked payload containers belonging to the same shipping category, indicate the FI is not applicable.

Approved for Transport the TCO records and signs and dates the PCTCD or OPCTCD certifying that the requirements for the transportation parameters are met. If the requirements are not met, the payload container is rejected ( nonconformance disposition) and not qualified for shipment.

Payload containers that do not comply with parameter limits are not qualified for shipment. These containers are segregated and corrective action is taken to resolve the noncompliant condition. The TCO completes the verification and certification of parameters in accordance with WMP 400, Section 2.1.5.

Refer to Appendix A, column " CH WAC and Certification Plan Section," rows 3.3.4 and 3.6.2, which contain the titles of applicable procedures that implement the requirements of this subsection.

4.7.2 Certification of Individual Payload Containers for Transport in the TRUPACT II ( Test Payload Shipping Category)

<IP_ADDRESS> Requirements In accordance with the CH TRAMPAC, Section 6.2, payload containers assigned to the test category must meet additional criteria for certification. The generating and storage sites shall qualify an individual payload container for transport in a TRUPACT II under the test category by verifying the container meets the parameter requirements/ limits in this subsection and in section 6.2 of the CH TRAMPAC.

Complete the PCTCD or OPCTCD for the test payload shipping category as outlined in subsection <IP_ADDRESS> of this Certification Plan.

Additional requirements for the test payload shipping category include measurement or testing of 55 gallon drums. Drum testing of 55 gallon drums shall be documented in the TRUPACT II test category payload container data sheet ( appendices B 3 and B 4 of this Certification Plan). HNF 2600, REV 15 Page 183 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Compliance can be achieved by measurement or drum testing. Methods must be consistent with the CH TRAMPAC in the following sections:

  Unified flammable gas test procedure ( UFGTP)   Section 5.2.5 of CH TRAMPAC 1. Measurement of UFGTP requirements are described in Section <IP_ADDRESS> of the CH TRAMPAC.

2. Testing of UFGTP requirements is described in Section <IP_ADDRESS> of the CH TRAMPAC.

3. Data sheets for documenting test results are identified in Appendixes B 3 and B 4 of this Certification Plan.

  Determination of flammable gas/ VOC concentrations  Appendix 3.10 of the CH TRU Payload Appendices.

1. Compliance with calculations of drum mathematical models and methodology are described in Appendix 3.10 of the CH TRU Payload Appendices.

2. Compliance with flammability assessment methodology program ( FAMP) is described in Appendix 3.10 of the CH TRU Payload Appendices.

<IP_ADDRESS> Compliance and Verification With the exception of waste type IV ( solidified organics), which currently is test category waste by definition, the Hanford site will repackage test category waste into an acceptable configuration to qualify as analytical category waste or conduct appropriate drum measurements or testing as specified in Section 6.2 of the CH TRAMPAC. Section 5.2.5 of the CH TRAMPAC will be implemented under the gas generation QAPP and HNF 2599 for gas generation testing. Appendix 3.10 of the CH TRU Payload Appendices will be implemented via e TRAMAPC in WWIS. WWIS entries will be in accordance with WMP 400, Section 7.1.5. For type IV waste or test category waste that cannot be repackaged, the Hanford site will segregate and store this waste until testing and/ or repackaging can be performed.

All test category parameter requirements will be documented in accordance with Section 6.2 of the CH TRAMPAC. Where applicable, overpacked containers parameter/ requirements limits will be documented on the OPCTCD in accordance with Section 6.2 of the CH TRAMPAC. The TCO completes the verification and certification of the CH TRAMPAC requirements in accordance with WMP 400, Section 2.1.5.

Refer to Appendix A, column " CH WAC and Certification Plan Section," rows 3.3.7 and 3.5.2, which contain the titles of applicable procedures that implement the requirements of this subsection. HNF 2600, REV 15 Page 184 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 4.7.3 Assembly of a TRUPACT II Payload <IP_ADDRESS> Requirements In accordance with the Section 6.2.2 of the CH TRAMPAC, certified payload containers shall be assembled into acceptable TRUPACT II payloads. Total TRUPACT II package limits must be met by ensuring the TRUPACT II SAR restrictions and requirements are met, and by evaluating the data from the individual PCTCDs or OPCTCDs, as applicable.

All parameters shall be met and documented on the PATCD consistent with subsection <IP_ADDRESS> of this Certification Plan.

Weight of pallets, reinforcing plates, slip sheets, guide tubes, banding material, etc., shall be measured for total weight ( or 265 lbs) and recorded on the PATCD as required.

<IP_ADDRESS> Compliance and Verification The TCO generates a PATCD from WWIS upon verifying the applicable transportation parameters are met, consistent with WMP 400, Section 2.1.5. The parameters listed below correspond with data fields on the PATCD, consistent with WMP 400, Section 2.1.5. When assembling payloads with mixed shipping categories, each payload container must meet all parameters provided in WWIS ( e. g., edit/ limit checks must be satisfied before a payload container is shippable). The WWIS entries must be done in accordance with WMP 400, Section 7.1.5. The parameters listed below correspond with data fields on the PATCD as identified in WMP 400, Section 2.1.5, and shall be completed as follows.

  Shipment No.: The shipment number assigned by TCO.   TRUPACT II OCA Body/ Lid Nos.: The identification numbers on the TRUPACT II OCA body and lid.   Payload Shipping Category: The governing shipping category of the payload shall be recorded only if all containers belong to the same or equivalent shipping category. Mixing shipping categories is also allowed in a TRUPACT II or CH TRAMPAC, but must be consistent with WWIS( e. g., all edit/ limit checks are satisfied).   Category Decay Heat Limit: If all containers belong to the same or equivalent shipping category, the maximum allowable decay heat per payload container for the governing payload shipping category shall be recorded from the PCTCD and OPCTCD. Mixing of shipping categories and payloads of any authorized contents, including credit for dunnage, is allowable provided all parameters in provided in WWIS are met ( e. g., all edit/ limit checks are satisfied).   Transportation Packaging: The type of packaging used ( TRUPACT II) shall be recorded. The payload configuration shall consist of any approved type of payload container ( verified by visual inspection).   Hydrogen/ Flammable Gases Rate Limit: If all containers belong to the same or equivalent shipping category, the maximum allowable hydrogen/ flammable gas generation rate per payload container for the governing payload shipping category shall be recorded from PCTCD( s). Mixing of shipping categories is also allowed in the HNF 2600, REV 15 Page 185 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TRUPACT II or CH TRAMPAC, but must be consistent with WWIS ( e. g., all edit/ limit checks are satisfied).   Type of Payload: The payload configuration shall consist of an approved type of payload container. If the payload type is " Standard Pipe Overpack" each seven pack in the payload must be comprised of only 6 inch standard pipe overpacks or 12 inch standard pipe overpacks.   Date ICV Closed: Identifies the date the inner containment vessel is closed and that information is recorded.   Payload Composition: Identifies the following container parameters:

1. Payload container identification number ( or " DUNNAGE" or " EMPTY")

2. Weight and measurement error 3. Decay heat and measurement error of one standard deviation 4. FGE and two times the measurement error ( two standard deviations or one times RMS [ calculated as RSS] error if values are taken from an OPCTCD)

5. Measured hydrogen flammable gas generation rate 6. Calculated flammability index for mixed shipping categories in accordance with WWIS.

Weights, decay heats, and FGEs of individual containers are summed for both top and bottom layers of the assembly, and the total error for each parameter is calculated as indicated on the PATCD.

Payload Totals   The total weight of pallets, reinforcing plates, slip sheets, guide tubes, banding material, etc., ( or 265 pounds) shall be measured and recorded.   Total Weight ( Plus RMS [ calculated as RSS] Error) of Payload and Package Indicates that the total weight of the payload and package does not exceed limits established in the CH TRAMPAC. The total error can be determined by weighing the entire payload assembly.   Bottom Layer ( Plus RMS [ calculated as RSS] Error) > Top Layer ( Plus RMS [ calculated as RSS] Error) The total weight of the bottom layer of seven drums, seven pipe overpacks, SWB, or five drums in a TDOP must be verified to be greater than or equal to the top layer. This is only applicable to TRUPACT IIs.   Total Weight ( Plus RMS [ calculated as RSS] Error) < 7,265 lbs. The total weight plus error must be verified to be less than or equal to 7,265 pounds.   Total Decay Heat ( Plus RMS [ calculated as RSS] Error) of all Containers Indicates that the total decay heat plus error for all containers comprising the shipment does not exceed allowable limits. HNF 2600, REV 15 Page 186 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN   Total 239Pu FGE ( Plus RMS [ calculated as RSS] Error) of all Containers Indicates that the calculated total fissile quantity plus two times the error for all containers comprising the shipment does not exceed allowable limits.   Dose Rates Indicates that dose rate measurements do not exceed allowable limits.

Payload Certification Parameters   Decay Heat Plus Error of Each Analytical Category Payload Container Less Than or Equal to Governing Decay Heat Limit: For payload containers with the same of equivalent payload shipping category shipped under a governing payload shipping category, all analytical category payload containers shall meet the governing decay heat limit.   Hydrogen/ Flammable Gas Generation Rate of Each Test Category Payload Container Less Than or Equal to Governing Hydrogen/ Flammable Gas Generation Rate Limit: For payload containers with the same or equivalent payload shipping category shipped under a governing hydrogen/ flammable gas generation rate, all payload containers shall meet the governing hydrogen/ flammable gas generation rate limit.   Flammability Index of Each Payload Container Greater Than Zero and Less Than or Equal to 50,000 ( Section 6.2.4 of the CH TRAMPAC): For shipments with dunnage or multiple shipping categories, record the FI for each container, calculated as described in Section 6.2.4 of the CH TRAMPAC and Appendix 2.4 of the CH TRU Payload Appendices. The FI for each container must be a non negative number less than or equal to 50,000 for the payload to be eligible for shipment.   Payload Total Gas Release Rate Less Than or Equal to Limit Calculated in Accordance With Section 6.2.5 ( Section 6.2.5 of the CH TRAMPAC): Payload total gas release rate limits apply only to payloads containing one or more Waste Type IV payload containers that exceed the payload container total gas release rate limit specified in Table 5.2 11 of Section 5.2 of the CH TRAMPAC. The site Transportation Certification Official shall verify that the determined payload total gas release rate is less than or equal to the appropriate payload total gas release rate limit pursuant to the methodology defined in Section 6.2.5 of the CH TRAMPAC.   Bottom Weight Greater Than or Equal to Top Weight: The subtotal weight plus subtotal RMS ( calculated as RSS) weight error of the bottom layer of seven 55 gallon drums, seven pipe overpacks, one SWB, five 55 gallon drums in a TDOP, or three 85 gallon drums in a TDOP shall be greater than or equal to that of the top layer.   Total Weight Plus RMS ( calculated as RSS) Error   to 7,265 pounds.: The total measured payload weight plus the weight of the pallets, reinforcing plates, etc., plus the total RMS ( calculated as RSS) weight error shall be less than or equal to 7,265 pounds.   Decay heat Plus RMS ( calculated as RSS) Error Less Than or Equal to 40 Watts: The total measured decay heat value plus the total RMS ( calculated as RSS) decay heat error shall be less than or equal to the design limit for the packaging. The design limit for the TRUPACT II is 40 watts.   Fissile Mass ( 239Pu FGE) Plus RMS ( calculated as RSS) Error Less Than or Equal to Payload Limit: The total measured fissile mass ( 239Pu FGE) plus the total RMS ( calculated as RSS) fissile mass error shall be less than or equal to the maximum HNF 2600, REV 15 Page 187 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN allowable fissile mass limit established for the payload configuration. If the payload is composed of only pipe overpacks ( standard, S100, or S200), the total 239Pu FGE limit is 2,800 grams per TRUPACT II. The total 239Pu FGE limit for all other payloads is 325 grams per TRUPACT II.   Total Activity plus Error for S100 Pipe Overpack Payloads Less Than or Equal to 406 Curies ( Section 3.3): The total activity for a payload assembly made up of S100 pipe overpacks plus the error ( i. e., one standard deviation) shall be less than or equal to 406 Ci. There is no activity limit for other payloads.

The TCO completes the PATCD, except for dose rate information, and provides the PATCD to loading personnel. Loading personnel load the TRUPACT II in accordance WRP1 OP 0521. The TCO signs and dates the PATCD upon verifying the TRUPACT II transportation requirements, including dose rate information, are met, the TRUPACT II vessel is loaded, and the payload is certified for transport. This is done in accordance with WMP 400, Section 2.1.5.

Refer to Appendix A, column " CH WAC and Certification Plan Section," rows 3.2.1 and 3.6.2, which contain the titles of applicable procedures that implement the requirements of this subsection.

4.7.4 Mixing of Shipping Categories <IP_ADDRESS> Requirements Appendix 2.4 of the CH TRU Payload Appendices describes the logic for mixing shipping categories for compliance with flammable ( gas/ VOC) concentration limits, including the determination of the FI.

Mixing of shipping categories is allowed for direct loaded and overpacked payload configurations by ensuring that each payload container or overpacked container does not contain a flammable mixture of gases. Mixing of shipping categories is allowed only within authorized payload configurations comprised of a single payload container type as listed in Section 3.2.1 of the CH TRAMPAC. ( Note: Standard pipe overpacks may be assembled in a TRUPACT II payload with 55 gallon drums. Standard pipe overpacks in this payload assembly are considered 55 gallon drums and are subject to the requirements of Sections 4.4.1 and 4.7.1.) Each payload container or overpacked container is assessed through the calculation of the FI for the container, which accounts for the properties of each of the other containers in the assembly or overpacked configuration, which may include dunnage containers.

A payload is qualified for shipment only if the FI of each payload container or overpacked container is a non negative number less than or equal to 50,000. If one or more containers fail( s) the FI requirement, the payload or overpacked configuration shall be reconfigured until all containers satisfy this requirement. Otherwise, containers not meeting the FI requirement shall be placed in the test category or rejected from transport and subject to mitigation or repackaging. The FI determination can be performed either manually or by the use of a verified/ validated software package. HNF 2600, REV 15 Page 188 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN <IP_ADDRESS> Compliance and Verification For test category payload containers and/ or mixed shipping category payload containers that comprise a payload, WWIS will be used to determine payload shipability. If WWIS edit/ limit checks are satisfied, a payload assembly can be approved for shipment provided all other payload container requirements/ parameters are met as well. WWIS entries will be done in accordance with WMP 400, Section 7.1.5.

5.0 QUALITY ASSURANCE PLAN Each site must develop and implement QA plans for TRU waste characterization, certification, and packaging. QA plans are submitted to CBFO for approval before TRU wastes are characterized, certified, and transported to WIPP. Analytical laboratories analyzing waste for characterization are required to have an established QA program. No waste may be certified unless it is a product of a waste stream evaluated and approved by CFBO. The TRUPACT II is not used without CBFO granting authority.

The QAPD establishes QA program requirements for all programs, projects, and activities sponsored by permittee. The QA plan associated with the certification plan must apply QAPD requirements. The QA requirements for compliance with TRUPACT II loading and usage are derived from 10 CFR 71, Subpart H, " Packaging and Transportation of Radioactive Materials"; 49 CFR 173, " Shippers   General Requirements for Shipments and Packagings"; TRUPACT II Certificate of Compliance; DOE O 460.1 and 460.2; and the permittee TRUPACT II CH Packaging Program Guidance, Packaging Operations, and Packaging Maintenance Manual manuals. The QA plan for packaging must address DOT and NRC requirements applicable to the use, maintenance, and control of packages used to transport TRU waste to WIPP, including the criteria addressed in 10 CFR 71, Subpart H; 10 CFR 72, " Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High Level Radioactive Waste," Subpart G, " Quality Assurance"; and 10 CFR 50, " Domestic Licensing of Production and Utilization Facilities," Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."

This QA plan implements the combined QA requirements for certification, transportation, and packaging established in the documents identified above. HNF 2599 implements the QA/ QC activities and requirements specified in the WAP. All analytical labs analyzing WIPP waste characterization samples shall have an established and documented QA/ QC program. Activities included in the scope of this QA plan are those related to certifying that waste containers and payload assemblies meet the criteria and requirements specified in the CH WAC, CHTRAMPAC TRUPACT II Certificate of Compliance, operation and maintenance of transport containers, waste transportation services, and the criteria specific to the packaging and transportation of radioactive materials. This QA plan ensures that all activities that are governed by the CFRs, applicable certificates of compliance, or other regulatory requirements are conducted in accordance with written, approved procedures or instructions that incorporate the applicable regulatory requirements. Activities that are important to safety are performed with specified equipment under suitable conditions, and prerequisites are satisfied before inspection, testing, or operation. This QA plan takes precedence over any other Hanford site QA plans HNF 2600, REV 15 Page 189 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN related to characterization and certification of TRU wastes destined for WIPP, and transportation and packaging applicable to the TRUPACT II. This plan does not apply to the procurement, inspection, or testing of payload containers except as those activities apply to verification that the payload containers meet the requirements of the TRUPACT II Certificate of Compliance.

Any payload container with unresolved discrepancies ( e. g., CARs, NCRs) associated with hazardous waste characterization will not be shipped to WIPP until the discrepancies are resolved consistent with applicable site specific procedures ( e. g., WMP 400, Section 1.3.2 or 1.3.3).

The organization of this QA plan is based on the QAPD elements outlined below. Table 5 1 provides a cross reference of identical or related QA requirement elements from 10 CFR 830.120 and 10 CFR 71.

  Organization and QA Program 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. HNF 2600, REV 15 Page 190 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table 5.0 1. Cross Reference of Quality Assurance Requirements* QAPD and QA Plan Section Equivalent Section in 10 CFR 830.120 Equivalent Section in 10 CFR Part 71, Subpart H 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 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 Work Processes Design Identification and Control of Materials, Parts, and Components Software Requirements Not applicable Not applicable * The TRU Project applies a graded approach for managing items and activities associated with certifying waste for shipment to WIPP as defined in WMP 400, Section 1.1.2, " TRU Graded Approach."

  Personnel Qualification and Training identifies the Hanford site 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 project documents and records. HNF 2600, REV 15 Page 191 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN   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.   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.

5.1 ORGANIZATION AND QA PROGRAM This QA program applies to items and activities affecting project quality. Effective implementation of this QA program is dependent on the efforts at all levels of the program participants. The organizational structures and the responsibility assignments of program participants shall be such that those organizations that have been assigned responsibility for performing the work are responsible for achieving and maintaining quality. Management is responsible for defining quality, developing appropriate plans to attain quality, and supporting the workers in pursuit of quality. The QA organization is responsible for verifying the achievement of quality in the implementation of this QA program. Organizational responsibilities are shown in figure 2 1. Organizational and individual responsibilities for TRU waste characterization, assessment, waste transportation, nuclear safety, environmental protection, and management and operation of the TRU Project are addressed in section 2.0 of this Certification Plan.

In addition, such personnel or organizations shall ( 1) have direct access to responsible management at a level where appropriate action can be effected, and ( 2) report to a management level such that required authority and organizational freedom are provided, including sufficient independence from cost and schedule consideration.

The organizational structure and responsibility assignments shall be such that:

  Quality is achieved and maintained by those who have been assigned responsibility for performing work, and   Quality achievement is verified by personnel or organizations that are not directly responsible for performing the work. HNF 2600, REV 15 Page 192 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Additional organization and QA program requirements include the following:

1. The individual( s) or organization( s) responsible for establishing and executing a QA program may delegate any or all of the work to others but shall retain responsibility therefore.

2. Responsibility for the control of further processing, delivery, installation, or operation of nonconforming items shall be designated in writing.

3. When more than one organization is involved in the execution of activities covered by this Certification Plan, the responsibility and authority of each organization shall be clearly established and documented.

4. The external interfaces between organizations and the internal interfaces between organizational units, and changes thereto, shall be documented.

5. Interface responsibilities shall be defined and documented.

All personnel involved with TRU waste 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. Disputes related to QA program requirements will be resolved by the SQAO and cognizant project personnel.

TRU project management at all levels have established communication channels that provide timely and wide dissemination of information related to the TRU Project quality performance which includes:

  QA program status   Lessons learned   Quality improvement   Results of trend analysis.

The program interfaces are described and defined in section 2.0 of this certification plan.

Figure 1 1 ( see section 1.0 of this Certification Plan) illustrates the hierarchy and interrelationships of QA documents governing the QA program. Quality management documents are audited and/ or assessed to ensure they meet project requirements.

The TRU Project QA organization 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 QA organization will ensure unsatisfactory conditions are controlled until proper corrective actions have been completed.

Project personnel plan certification activities and document the planning process. Planning documentation is subject to review by facility managers and subject matter experts ( SME) s. Project planning documentation consists of this certification plan, HNF 2599, implementing procedures, training plans, and facility and certification process designs. These documents HNF 2600, REV 15 Page 193 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN establish performance criteria and methods to measure performance relevant to the project. All project personnel are accountable for ensuring quality within their assigned areas of responsibility. However, the SQAO is responsible for determining the effectiveness of this QA plan, which is accomplished through internal reporting procedures, audits, and assessments ( see subsection 5.3 of this Certification Plan).

5.2 PERSONNEL QUALIFICATION AND TRAINING Personnel performing work in support of the project receive QA indoctrination and are qualified and trained to ensure that suitable proficiency is achieved and maintained in the performance of their assigned tasks. Records documenting qualifications and completed training programs are maintained and controlled as described in subsections 5.4 and 5.5 of this Certification Plan.

5.2.1 Qualification Facility managers, the SPM, and the Training manager determine qualification standards for each job category relevant to the project and ensure that qualifications of project personnel, including minimum education and experience, have been verified. Project personnel maintain minimum qualifications in accordance with WMP 400, Section 1.2.1, " TRU Training and Qualification Plan." The SPM assists facility managers in determining which positions relevant to the project require minimum qualifications. The period of effectiveness for qualification associated with special processes and operations that require special skills and the requalification criteria are specified or referenced in WMP 400, Section 1.2.1. Facility managers ensure auditable records documenting personnel qualifications are maintained as described in WMP 400, Section 1.5.1. Records of qualified personnel, their areas of qualification, and qualification periods ( as appropriate) are retained in the TRU project records files.

5.2.2 Training The SPM and facility managers ensure that all project personnel receive indoctrination and training on the scope, purpose, and objectives of the project and the specific QAOs of the tasks being performed. Facility personnel performing activities affecting quality are trained according to facility training plans to ensure they achieve and maintain proficiency. Personnel receive initial and continuing training requisite with their activities and level of responsibility, as described in WMP 400, Section 1.2.1.

Training is designed, developed, conducted, and evaluated in accordance with Hanford site requirements described in WMP 400, Section 1.2.1. 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. Facility managers ( or designees) analyze job positions and determine task responsibilities for project personnel to ensure education, experience, and training is commensurate with minimum requirements specified. Facility managers are responsible for ensuring that auditable records documenting the required training and qualifications are maintained in accordance with WMP 400, Section 1.2.1. HNF 2600, REV 15 Page 194 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 5.3 QUALITY IMPROVEMENT Project personnel continually evaluate and improve project activities. The SQAO ensures that quality improvement in the project is achieved by identifying and controlling conditions adverse to quality, analyzing trends, reporting and tracking nonconformances, and implementing corrective actions. These quality improvement activities detect and prevent unacceptable quality problems and thereby increase accuracy and reliability and reduce variability.

A condition adverse to quality is an all inclusive term used in reference to failures; malfunctions; deficiencies; and nonconforming items, materials, parts, or components, and processes. Project personnel ensure that nonconforming items, materials, parts, or components, waste containers, etc., are adequately identified and segregated from acceptable items and materials to preclude their inadvertent use. The SQAO, the SPM, facility managers, and FQAOs have the authority to stop certification, packaging, and transportation activities and/ or refuse to accept work products or services ( e. g., procured items, documentation, packaging, and waste shipments) that do not conform to project requirements. All Hanford site employees have the responsibility to stop work that poses a clear and imminent danger to the safety and health of employees, subcontractors, visitors, or the environment. Project personnel report conditions adverse to quality to FQAOs and/ or the SQAO, who ensure that the condition adverse to quality is investigated and that corrective action is taken as described in this section.

All violations of the WIPP Hazardous Waste Facility Permit must be managed as a significant condition adverse to quality. Project personnel notify permittee of all conditions adverse to quality affecting waste to be shipped to WIPP and forward all CARs related to violations of the WIPP Hazardous Waste Facility Permit to permittee for tracking.

Deficiencies are uncontrolled and unapproved deviations from an approved plan, procedure, or expected result. Deficiencies specific to the project also include documentation or management practices that do not meet the requirements related to waste certification, packaging, and transportation, which are identified in the WAP, CH TRAMPAC, CH WAC, QAPD, DOE orders, and applicable federal and state regulations. Project personnel are responsible for identifying any condition that affects the project's compliance with these requirements. Assessments may often identify systems, processes, products, or services that do not meet performance criteria established in planning documents. When deficiencies are found, project personnel take prompt action to rectify the situation.

Any individual who identifies a condition adverse to quality initiates an NCR or CAR in accordance with WMP 400, Section 1.3.2 or 1.3.3. If the safety or quality of the certification process could be compromised by continued use of a nonconforming item, the item is taken out of service and tagged or otherwise identified to prevent reuse or acceptance until the nonconformance is corrected. The facility manager of the facility where the nonconformance is identified ensures that an NCR is initiated and that corrective action is taken to resolve the nonconformance. WMP 400, Section 1.3.1, guides the corrective action process.

NCRs and CARs are forwarded to the SQAO. The SQAO is responsible for validating and tracking project related deficiencies to ensure that corrective action is implemented and that the HNF 2600, REV 15 Page 195 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN corrective action resolves the nonconformance. Project personnel notify permittee within five calendar days of identification of any nonadministrative nonconformance related to applicable requirements specified in the WIPP Hazardous Waste Facility Permit WAP, which are first identified at the SPM's signature release level. Project personnel submit the NCR to permittee within 30 calendar days of identification of the deficiency. WMP 400, Section 1.3.1, guides the corrective action process. The SQAO ensures dissemination of information that may prevent problems or help improve parallel processes in other waste generator or project activities and reevaluates system performance after corrective actions have been implemented. The facility manager provides the resources necessary to accomplish corrective actions.

The SQAO, facility managers, and FQAOs are jointly responsible for identifying the following:

  Trends in nonconformances   Root causes of nonconformances   Specific, measurable corrective actions to resolve current problems and prevent recurrence   Personnel responsible for implementing corrective actions   Schedules for completing corrective actions.

5.4 DOCUMENTS Documents that specify quality requirements or establish activities affecting quality are controlled to ensure that accurate and current documents are used. Document control ensures that documents have gone through the designated review and approval process and are distributed to the appropriate personnel.

Project personnel prepare and control documents supporting the quality of the project in compliance with WMP 400, Section 1.4.1. Document control coordinators ensure documents are developed as prescribed by current procedures; reviewed for adequacy, correctness, and completeness; approved; revised; and distributed to the appropriate personnel. Documents developed specifically for the project are distributed through a document control process. These documents include:

  Certification plan   HNF 2599   QAPD procedures matrix   Plans and procedures implementing the TRU waste characterization, certification, packaging, and transportation requirements.

5.5 RECORDS A QA record is an authenticated record that furnishes evidence of the quality of items and/ or activities. The minimum lifetime and nonpermanent QA project records are identified in HNF 2599. QA records are controlled and maintained to certify compliance with requirements and to reflect completed work. QA records are indexed, classified, controlled, and maintained by records management personnel as described in WMP 400, Section 1.5.1. HNF 2600, REV 15 Page 196 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 5.6 WORK PROCESSES The work processes and items supporting and affecting project quality are controlled through plans and procedures identified in this certification plan, HNF 2599, and the QAPD procedures matrix. Procedures and plans are developed, reviewed, approved, revised, and distributed in accordance with WMP 400, Section 1.4.1; WMP 400, Section 2.1.2, " TRU Operating Procedure Preparation and Approval"; WMP 400, Section 2.1.3, " TRU Administrative Procedure Preparation and Approval"; and WMP 400, Section 2.1.6, " TRU Analytical Procedure Process." Project technical and QA personnel comply with the applicable technical standards and administrative controls described in procedures, which are reviewed and approved by the SPM ( or designee), the SQAO ( or designee), and cognizant facility manager in accordance with WMP 400, Section 2.1.2, Section 2.1.3, and Section 2.1.6, as appropriate. Facility managers ensure personnel perform work following established procedures.

The procedures identified in this certification plan and HNF 2599 provide the following information:

  Organizational and individual responsibilities   Training and qualification requirements   Technical, regulatory, and QA requirements   Step by step instructions for the process ( prepared by an SME of the cognizant organization)   Equipment specifications   Methods and criteria for ensuring and verifying the acceptability of equipment and materials used in the process ( e. g., calibration)   Prerequisites, precautions, process parameters, and other limiting conditions   Products of the process   Quantitative and/ or qualitative criteria for determining that prescribed process activities have been performed satisfactorily   Records generated by the process   Package and design control of equipment and materials.

The SPM and facility managers ensure that project activities are controlled and conducted in accordance with WMP 400, Section 2.1.1, " TRU Process Control," and facility specific procedures that describe and control work processes applicable to TRU waste characterization, certification, packaging, or transportation. The TRU Project does not perform design activities that impact EPA Disposal certification. Inspection and testing is addressed in subsection 5.8.

Each individual performing the work is responsible for ensuring that:

  Work processes are controlled and comply with established criteria, and   Reports describing work activity results are correct and free of grammatical and spelling errors.

Facility managers are responsible for ensuring that workers have the correct procedures, materials, and training to perform quality work. All instructions and procedures are maintained HNF 2600, REV 15 Page 197 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN current with a documented and controlled method of revision ( see subsection 5.4). Instructions, procedures, and drawings are readily available to project personnel at locations requiring their use.

Fabrication, installation, and inspection processes that have an effect upon the quality of items or services important to safety shall be controlled by process procedures. Special processes controlled under this QA plan are nondestructive testing ( NDA, NDE, and VE), helium leak testing, and limited maintenance of the TRUPACT II and associated components. These processes are controlled by the following written procedures:

  WMP 400, Section 1.2.2, " Qualification of NDE, NDA, Visual Examination, Transportation, and Inspection and Test Personnel"   WMP 400, Section 2.4.4, " TRU Control of Measuring, Testing, and Data Collection Equipment"   WRP1 OP 0521, " Receive and Load TRUPACT II Containers"   WRP1 OP 0522, " Assemble and Stretch Wrap TRUPACT II Payload"   WRP1 OP 0524, " Helium Leak Test of the TRUPACT II Shipping Container"   WRP1 OP 0729, " Visual Examination"   WRP1 OP 0905, Imaging Passive/ Active Neutron Assay Operation"   WRP1 OP 0906, " Gamma Energy Assay Operations"   WRP1 OP 0907, " Gamma Energy Assay Operations Using NDA2000"   WRP1 OP 0908, " Operation of the Drum Nondestructive Examination System"   WRP1 OP 1225, " Radiological Support of TRUPACT II Shipping and Receiving"   ZA 948 392, " NDA Using NDA 2000"   ZA 948 393, " NDA Using the Room 172 ANTECH Calorimeters"

5.7 PROCUREMENT All Hanford site TRU Project facilities implement procedures to ensure procurement of items and services important to safety and quality meet requirements and perform as intended. Procurement controls are also applicable to equipment and services that directly affect testing, sampling, and analytical data quality. Project personnel adhere to procurement and recordkeeping practices established in written procedures. The procurement criteria are implemented according to WMP 400, Section 2.3.1, " TRU Procurement Planning," and the procedures specified in the following subsections.

5.7.1 Procurement Document Control The SPM and facility managers ensure project personnel control procurement documents in accordance with WMP 400, Section 2.3.2, " TRU Procurement Document Control." Procurement documents supporting waste management and packaging and transportation activities must include required specifications and acceptance criteria. Procurement documents are reviewed by appropriate organizations and engineering disciplines to ensure they contain adequate scope of work, technical requirements, supplier QA program requirements, and provisions for acceptance. The procurement document control system is also defined in WMP 400, Section 2.3.2. HNF 2600, REV 15 Page 198 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 5.7.2 Control of Purchased Items and Services The SPM and facility managers ensure project personnel control items and services purchased ( including supplier evaluations and inspections) in accordance with WMP 400, Section 2.3.3, " TRU Control of Purchased Items and Services," and WMP 400, Section 2.4.1, " TRU Inspection Control." Documentary evidence that items, material, and equipment conform to the procurement specifications is provided before installation or use of the item, material, and equipment and is retained in accordance with WMP 400, Section 2.3.2. Potential suppliers of goods and services to the TRU Project will have their own QA program or will comply with applicable TRU Project requirements.

Measures are established in WMP 400, Section 2.1.4, " TRU Handling and Storage," and WMP 400, Section 2.4.1, to ensure that materials, parts, and components used for repair work for maintenance purposes or packaging and transportation purposes are adequately identified to preclude the use of incorrect or defective items. Also, where replacement of limited life items is specified, measures are established to preclude use of items whose shelf life or time in operation has expired ( see subsection 5.8 of this Certification Plan).

5.7.3 Control of Subcontractors Subsection 5.7.2 of this Certification Plan also applies to subcontractors who perform work that directly affects the quality of characterization and certification data. WMP 400, Section 2.3.3, describes how project personnel control subcontractor services. Subcontractors may support TRU Project activities under a " staff augmentation" role or for procurement of products and services. TRU Project staff augmentation subcontractors operate under the umbrella of the TRU Project QA program and are subject to all applicable requirements for TRU Project related functions they perform. All subcontractors who support the TRU Project will be informed of the need to perform operations in compliance with TRU Project requirements. Subcontractors are required to establish procurement controls and a QA program to ensure that purchased materials, equipment, and services conform to the TRU Project procurement and QA program documents. The controls must include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products on delivery. Subcontractors are subject to periodic assessments and audits at intervals consistent with the importance, complexity, and quantity of the product or services provided to ensure compliance with procurement requirements. Subcontractor personnel must meet applicable project training and qualification requirements. Subcontractors shall submit copies of all project related, qualityaffecting documents to the SPM.

5.8 INSPECTION AND TESTING Equipment is tested, inspected, and maintained in accordance with WMP 400, Section 2.4.1; WMP 400, Section 2.4.2, " TRU Test Control"; and WMP 400, Section 2.4.4, " TRU Control of Measuring, Testing, and Data Collection Equipment." Status tagging based on inspections and/ or tests done in accordance with WMP 400, Section 2.4.5, " TRU Identification and Control of Items." Project personnel identify and control items ( e. g., items with limited shelf or HNF 2600, REV 15 Page 199 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN operating lives, materials, equipment, samples) and ensure that only correct and accepted items are used according to WMP 400, Section 2.4.1. These procedures and documents address planning, parameters for evaluation, techniques to be used, qualification of inspection and test personnel, hold points, documentation, acceptance criteria, and organizational responsibilities.

Project personnel routinely test and inspect items and processes and control, calibrate, and maintain equipment to ensure proper operation and data quality. Procedures identified above implement an inspection program that establishes criteria for inspection of activities affecting quality by or for the organization performing the activity, and to verify conformance with the requirements for accomplishing the activity. The verification is performed in accordance with written procedures, instructions, or drawings. Personnel performing the inspections are independent from the individuals performing the activity being inspected. Equipment modifications, repairs, and replacement are inspected in accordance with the original design and inspection requirements unless an approved alternative exists. The inspection program also provides for identification and documentation of deficiencies discovered during the inspection. Measures are established to indicate, by the use of markings, tags, stamps, labels, routing cards, or other suitable means, the status of inspections and tests performed. These measures provide for the identification of items that have satisfactorily passed required inspections and tests, where necessary, to preclude inadvertent bypassing of the inspections and tests.

Measuring and test equipment with the necessary range and accuracy is provided to qualified personnel for the inspection, test, and acceptance of material, parts, components, and systems. Equipment accuracy is ensured by periodic calibration that is traceable to national standards or a documented equivalent basis for calibration.

The test control program is established for items and services important to safety. No testing requiring a test control program relative to waste payload containers or the TRUPACT II will be performed under this program. All TRUPACT II repair parts that may be replaced by the operator are supplied by the permittee or a designated contractor and are tested, inspected, accepted, and tagged in accordance with the permittee DOE/ WIPP 02 3183 and DOE/ WIPP 02 3184 manuals before delivery to the user. Leak testing is a special process discussed in subsection 5.6.

Specific measures to control packaging, shipping, storage, preservation, handling of components, material, and packaging to prevent damage, loss, deterioration, or substitution are established in the following procedures:

  WRP1 OP 0521   WRP1 OP 0522   WRP1 OP 0524   WMP 400, Sections 2.1.5, 7.1.5, 7.1.7, and 7.1.8. HNF 2600, REV 15 Page 200 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN These procedures address the following requirements:

  Transport cask handling and operation shall conform to written handling and operating procedures for each licensed.   Before shipment of a transport cask, conditions of the NRC's certificate of compliance ( e. g., specifications, tests, inspections) shall be satisfied. Required shipping papers shall be prepared and shall accompany the shipment.   Established safety restrictions concerning handling, storage, and shipping shall be included in the handling and operating procedures for transport casks.

5.9 ASSESSMENT REQUIREMENTS The Hanford site participates in an assessments program to ensure that the project is in compliance with applicable requirements. Management assessments are conducted by Hanford site project management and independent assessments by site personnel independent of the project. Permittee and external regulatory agencies also conduct assessments of the TRU Project. The SQAO tracks deficiencies identified during assessments; identifies corrective actions to resolve deficiencies according to WMP 400, Sections 1.3.1, 1.3.2, and 1.3.3; and ensures the resolutions are reported to the SPM, RL, and permittee as described in subsection 5.3 of this Certification Plan.

5.9.1 Management Assessments Project managers periodically assess the performance of their organization to determine the effectiveness of QA program provisions that enable the organization to comply with requirements of the WAP, QAPD, CH WAC, and CH TRAMPAC, and applicable procedures and documents. Managers evaluate QA program effectiveness by focusing on the identification and resolution of both systemic and management issues and problems, and identifying strengths and weaknesses to facilitate actions to improve quality efficiency and cost effectiveness. The management assessment includes an introspective evaluation to determine whether the entire integrated management system effectively focuses on meeting strategic goals. Management assessments are conducted as described in WMP 400, Section 3.1.1, " TRU Management Assessment." Project managers are responsible for the conduct of these assessments and report at least annually on relevant findings.

5.9.2 Independent Assessments Documented independent assessments, also referred to as audits and surveillances, are used to measure item service and quality, process adequacy and effectiveness, and to promote improvement. Independent assessments are conducted in accordance with WMP 400, Section 3.2.1, " TRU Independent Assessments." Project personnel and facilities are subject to periodic independent assessments performed by teams assembled by the SQAO. The SQAO ensures that characterization facilities and analytical laboratories are assessed and determines whether the independent assessment is an audit or process surveillance ( see below). In addition, FQAOs may perform independent assessments ( audits or surveillances) of project activities at their facilities. Audit teams include one or more qualified auditors, one of whom must be a HNF 2600, REV 15 Page 201 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN certified lead auditor. Audit and surveillance personnel qualifications are addressed in WMP 400, Sections 1.2.1 and Section 1.2.3, " Certification of Audit Personnel," and are in accordance with the QAPD.

The independent assessment team is made up of a team leader appointed by the SQAO and team members and technical specialists selected by the team leader in conjunction with the SQAO. The team leader provides indoctrination and supervision of the team, organizes and directs the assessment, establishes the scope of the assessment, prepares a plan for conducting the assessment, and prepares and issues an assessment report to the management of the assessed organization and any affected organizations. The assessment team members and technical specialists prepare the assessment checklist, conduct the assessment, brief the management of the assessed organization on a daily basis, and prepare a draft report for presentation at the exit conference for the assessment. Assessments are performed in accordance with WMP 400, Sections 3.2.1 and 3.2.2.

5.9.3 Audits Facilities participating in the project are subject to permittee audits. A permittee audit of the project is conducted before waste is shipped to WIPP and annually thereafter. These audits are the responsibility of the permittee QA manager, who coordinates these audits through the SPM and SQAO.

The TRU Project also participates in an internal audits and surveillance program. The SQAO ensures that all conditions adverse to quality are resolved and that appropriate corrective actions are implemented in a timely manner. The SQAO develops a schedule, in association with project facility managers, which details follow up activities and final resolution of all corrective actions. The SQAO tracks corrective actions to completion and monitors the status of the corrective actions to ensure timely closure of deficient conditions.

5.9.4 Surveillances The surveillance program is conducted primarily to monitor work in progress and to follow up on corrective actions. Surveillance results are reported and monitored similar to other assessment activities. Surveillances are performed in accordance with WMP 400, Section 3.2.2, " TRU Surveillance Program." HNF 2600, REV 15 Page 202 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 5.9.5 Reports to Management The SQAO provides the QA interface between facilities and the SPM. The SQAO oversees the NCR/ CAR process for project related deficiencies and coordinates with facility managers to track nonconformances and verify corrective action completion according to WMP 400, Sections 1.3.2 and 1.3.3. Facility QA officers ( FQAOs) report the results of their independent assessments to the SQAO, and together they track assessment results and corrective actions. The SQAO reports these independent assessment results to the SPM in accordance with WMP 400, Section 3.1.2, " Quality Assurance Reports to Management." Also, the SQAO prepares and transmits a semiannual QA report to the SPM and the DOE. The semiannual QA report includes the following information, as appropriate:

  Any HNF 2599 changes   Identification of any significant QA/ QC problems, recommended solutions, and corrective actions   An assessment of QC data collected during the period, including the frequency of repeated analyses, reasons they were repeated, and corrective actions   Discussions of whether QAOs have been met and any resulting impact on decision making   Limitations on the use of measurement data   Status of PDP sample results   Results of audits, assessments, and surveillances conducted during the period.

5.9.6 Performance Demonstration Program ( PDP)

The Hanford Site TRU Project facilities participate in the PDP programs as summarized in DOE/ CAO 95 1076, Performance Demonstration Program Plan of Simulated Headspace Gasses, DOE/ CBFO 01 1005, Performance Demonstration Program Plan for Nondestructive Assay of Drummed Waste for the TRU Waste Characterization Program and DOE/ CBFO 01 1006 and Performance Demonstration Program Plan for Nondestructive Assay of Boxed Waste for the TRU Waste Characterization Program. PDP samples are processed according to the facility procedures applicable to the specific testing or analytical characterization activity being assessed.

5.10 SAMPLE CONTROL REQUIREMENTS Project personnel use procedures to ensure proper documentation and tracking of sample possession from the time of collection/ identification, through handling, preservation, shipment, transfer, analysis, storage, and final disposition. Sample control procedures used by project personnel are described in LO 090 450, " TRU Project Chain of Custody, Storage, Acceptance, and Disposal." Project personnel ship samples in compliance with DOT regulations and project QA requirements.

5.11 SCIENTIFIC INVESTIGATION REQUIREMENTS The plans and procedures developed and implemented to support the project define, control, verify, and document data collection activities related to TRU waste management. HNF 2600, REV 15 Page 203 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 5.12 SOFTWARE REQUIREMENTS Computer software and hardware/ software configurations used in project activities are developed, documented, verified, validated, and tested before use in compliance with requirements contained in the QAPD, HNF 2599, and NQA 2a, Subpart 2.7, " Quality Assurance Requirements of Computer Software for Nuclear Facility Applications." WMP 400, Section 6.1.1, describes the processes for computer software development, validation, and verification.

6.0 REFERENCES 10 CFR Part 71, " Packaging and Transportation of Radioactive Material," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

10 CFR Part 830, " Nuclear Safety Management," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

10 CFR Part 835, " Occupational Radiation Protection," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

40 CFR Part 191, " Environmental Radiation Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High Level and Transuranic Radioactive Wastes," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

40 CFR Part 194, " Criteria for the Certification and Re Certification of the Waste Isolation Pilot Plant's Compliance with the 40 CFR Part 191 ` Disposal Regulations'," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

40 CFR Part 261, " Identification and Listing of Hazardous Waste," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

40 CFR Part 262, " Standards Applicable to Generators of Hazardous Wastes," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

40 CFR Part 264, " Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities," Code of Federal Regulations, Washington D. C., Office of the Federal Register National Archives and Records Administration.

40 CFR Part 268, " Land Disposal Restrictions," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration. HNF 2600, REV 15 Page 204 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 49 CFR Part 172, " Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training Requirements," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

49 CFR Part 173, " Shippers General Requirements for Shipments and Packagings," Code of Federal Regulations, Washington, D. C., Office of the Federal Register National Archives and Records Administration.

ANSI/ AIM BC1 1995, Uniform Symbology Specification   Code 39. American National Standards Institute, Inc., 1430 Broadway, New York, NY 10018.

ASME NQA 1, Quality Assurance Program Requirements for Nuclear Facilities, 1989 Edition, New York, New York, American Society of Mechanical Engineers.

ASME NQA 2a 1990, Part 2.7, Addenda to NQA 2, Quality Assurance Program Requirements of Computer Software for Nuclear Facility Applications, New York, New York, American Society of Mechanical Engineers.

ASTM C 1030 95, " Determination of Plutonium Isotopic Composition by Gamma Ray Spectrometry," American Society for Testing and Materials, Washington D. C.

DOE/ CAO 2056, 40 CFR 191, Compliance Certification Application, Carlsbad Field Office, Carlsbad, New Mexico, U. S. Department of Energy.

DOE RL 96 57, Test and Evaluation Document for the U. S. Department of Transportation Specification 7A, Type A Packaging, U. S. Department of Energy.

Carlsbad Field Office Interim Guidance on Ensuring that Waste Qualifies for Disposal at the Waste Isolation Pilot Plant, , Carlsbad Field Office, Carlsbad, New Mexico, U. S. Department of Energy.

DOE/ WIPP 01 3194, CH TRU Waste Content Codes ( CH TRUCON)

DOE/ WIPP 02 3183, Contact Handled Packaging Program Guidance DOE/ WIPP 02 3184, Contact Handled Packaging Operations Manual DOE/ WIPP 02 3185, Contact Handled Maintenance Manual DOE/ CBFO 94 1012, U. S. Department of Energy Carlsbad Field Office Quality Assurance Program Document, , Carlsbad Field Office, Carlsbad, New Mexico, U. S. Department of Energy.

DOE/ WIPP 02 3122, Contact Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant. HNF 2600, REV 15 Page 205 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN DOE O 435.1, 1999, Radioactive Waste Management, Washington, D. C., U. S. Department of Energy.

EPA 600/ 2 80 076, A Method for Determining the Compatibility of Hazardous Wastes, Washington D. C., U. S. Environmental Protection Agency.

SW 846, Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods, Third Edition, Final Update I and Final Update II and III, Office Solid Waste and Emergency Response, Washington, D. C., U. S. Environmental Protection Agency.

HNF 2599, Hanford Site Transuranic Waste Characterization Quality Assurance Project Plan.

HNF 2601, Hanford Site Transuranic Waste Project Quality Assurance Program Document Procedures Matrix.

Specifications, Tolerances, and Other Technical Requirements for Weighing and Measuring Devices, Handbook 44, Boulder, Colorado, U. S. Department of Commerce, National Institute of Standards and Technology.

Safety Analysis Report for the TRUPACT II Shipping Package, NRC Docket No. 71 9218, , Office of Regulatory Procedures, Washington, D. C., U. S. Nuclear Regulatory Commission.

Waste Isolation Pilot Plant Land Withdrawal Act, Public Law 102 579.

Waste Isolation Pilot Plant Hazardous Waste Facility Permit, NM4890139088 TSDF, Attachment B, including B1 through B6, Santa Fe, New Mexico, New Mexico Environment Department.

DOE/ WIPP 95 2065, Waste Isolation Pilot Plant Safety Analysis Report, Carlsbad, New Mexico, Westinghouse Electric Corporation.

Contact handled Transuranic Waste Authorized Methods for Payload Control ( CH TRAMPAC), Washington D. C., Office of Regulatory Procedures, U. S. Nuclear Regulatory Commission CH_ TRU Payload Appendices, Washington D. C., Office of Regulatory Procedures, U. S. Nuclear Regulatory Commission.

U. S. Nuclear Regulatory Commission. Certificate of Compliance. NRC Docket No. 71 9218, Washington, D. C. Office of Regulatory Procedures, U. S. Nuclear Regulatory Commission. ( http:// www. wipp. ws/ library/ t2sar/ cofc/ trucert. pdf) HNF 2600, REV 15 Page 206 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX A SUMMARY OF CH TRU WASTE ACCEPTANCE CRITERIA,

REQUIREMENTS, AND COMPLIANCE AND VERIFICATION DOCUMENTS AND PROCEDURES HNF 2600, REV 15 Page 207 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures Container Properties Criteria and Requirements 3.2.1 2.1, 2.9 ( 4.3.1) Payload Container description   DOT 7A Type A 55 gal. drums,

pipe overpacks, SWBs, and TDOPs ( including dunnage)

  Maximum number of containers and authorized packaging configurations shown in Table 3 2 TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5)

TRU Procurement Document Control ( WMP 400, Section 2.3.2)

TRU Control of Purchased Items and Services ( WMP 400, Section 2.3.3)

Transuranic Waste Sample and Waste Container Management Activities ( WMP 400, Section 7.1.7)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Receive and Load TRUPACT Containers ( WRP1 OP 0521)

3.2.2 2.3 ( 4.3.3) Weight limits and center of gravity     1000 lbs/ 55 gal. drum     certified weight. Limits for Type A equivalent drums     4000 lbs/ SWB     6,700 lbs/ TDOP     TRUPACT II configuration limits shown in Table 3 1 TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

3.2.3 2.1, 2.9 ( 4.3.3) Container assembly   Fourteen 55 gal. drums   14 POCs ( std., S100 & S200   2 SWBs ( including one bin)

  2 SWBs ( including four 55 gal.

drums)

  1 TDOP all configurations TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5)

3.2.4 NA Removable surface contamination     20 disintegrations per minute ( dpm)/ 100 cm2 alpha     200 dpm/ 100 cm2 beta/ gamma TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Radiological Support of TRUPACT II Shipping and Receiving ( WRP1 OP

1225)

3.2.5 2.4 ( 4.3.4) Container identification / labeling/

marking   Bar code with unique CIN and site identification   Empty   Dunnage TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) HNF 2600, REV 15 Page 208 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures 2.2 ( 4.3.2) Dunnage   Empty 55 gal. drums   Empty SWBs TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Receive and Load TRUPACT Containers ( WRP1 OP 0521)

Assemble and Stretch Wrap TRUPACT Payload ( WRP1 OP 0522)

3.2.7 2.5 ( 4.3.5) Filter vents   Payload containers vented with filters that meet WAP and TRAMPAC or CH TRAMPAC specifications CH WAC TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5)

TRU Control of Purchased Items and Services ( WMP 400, Section 2.3.3)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Headspace Gas Samples of TRU Waste Containers ( TRU OP 001)

Move Containers Throughout WRAP Facility ( WRP1 OP 0503)

Assemble and Stretch Wrap TRUPACT Payload ( WRP1 OP 0522)

Physical Properties Criteria and Requirements 2.6 ( 4.3.6) Liquids   < 1 in. ( 2.5 cm) in the bottom of any container   < 1 volume percent in any payload container 3.4.1 2.7 4.3.7 Sharp or Heavy Objects   Sharp or heavy objects shall be blocked or braced TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3)

Sampling Design and Data Analysis for RCRA Characterization and Visual Examination of Transuranic Waste ( WMP 400, Section 7.1.4)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

AK Documentation Management ( WMP 400, Section 7.1.9)

TRU Waste Visual Exam Technique ( WMP 400, Section 7.1.10)

TRU RWM Glovebox Automatic Mode Operations ( WRP1 OP 0722)

TRU Sorting Glovebox Operation ( WRP1 OP 0725)

TRU Loadout Glovebox Operation ( WRP1 OP 0726)

Operation of the Drum Nondestructive Examination System ( WRP1 OP

0908)

Pipe and Go Operations ( ZO 160 080)

Pu/ Al Alloys Operations ( ZO 160 081) ( Inactive)

Load Standard Waste Box ( SWB) Storage Containers With TRU Waste ( ZO 170 044)

Visual Examination Technique for PFP Debris Waste ( ZO 170 057)

3.4.2 2.8 ( 4.3.8) Sealed containers   Sealed containers > 4 L prohibited ( except for waste material Type II. 2 packaged in a metal container) TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3) HNF 2600, REV 15 Page 209 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures Sampling Design and Data Analysis for RCRA Characterization and Visual Examination of Transuranic Waste ( WMP 400, Section 7.1.4)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

AK Documentation Management ( WMP 400, Section 7.1.9)

TRU Waste Visual Exam Technique ( WMP 400, Section 7.1.10)

TRU RWM Glovebox Automatic Mode Operations ( WRP1 OP 0722)

TRU Sorting Glovebox Operation ( WRP1 OP 0725)

TRU Loadout Glovebox Operation ( WRP1 OP 0726)

Operation of the Drum Nondestructive Examination System ( WRP1 OP

0908)

Pipe and Go Operations ( ZO 160 080)

Pu/ Al Alloys Operations ( ZO 160 081) ( Inactive)

Load Standard Waste Box ( SWB) Storage Containers With TRU Waste ( ZO 170 044)

Visual Examination Technique for PFP Debris Waste ( ZO 170 057) HNF 2600, REV 15 Page 210 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures Radiological Properties Criteria and Requirements 3.3.1 3.1 ( 4.4.1) Radionuclide Composition /

Nuclear criticality   Assay measurements   Quantification of : 241Am, 238Pu,

239Pu, 240Pu, 242Pu, 233U, 234U,

238U, 90Sr, and 137Cs TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Operation of the SuperHENC Assay System ( TRU OP 002)

Calculation of Assay Results ( WMP 350, Section 2.2)

Data Management ( WMP 350, Section 2.3)

GEA Energy and Efficiency Setup and Baseline Establishment ( WMP 350,

Section 2.5)

WRAP NDA Measurement Control Program ( WMP 350, Section 2.8)

Performing Calibration Verifications and Confirmations for NDA at WRAP ( WMP 350, Section 2.9)

GEA Calibration Using NDA2000 ( WMP 350, Section 2.10)

Imaging Passive/ Active Neutron Assay Operation ( WRP1 OP 0905)

Gamma Energy Assay Operations ( WRP1 OP 0906)

Gamma Energy Assay Operations Using NDA2000 ( WRP1 OP 0907)

Data Management ( FSP PFP 5 8, Section 16.2)

QC Criteria for Residues Project NDA Instruments ( FSP PFP 5 8, Section 16.3) Calibration Confirmation for Residues Project NDA Instruments ( FSP PFP

5 8, Section 16.4)

Calculation of Assay Results ( ZA 400 302)

Energy and Efficiency Setup and Baseline Determination Using NDA 2000 ( ZA 400 303)

ANTECH Calorimeter Calibration ( ZA 400 304)

3.3.3 3.1 ( 4.4.1) Fissile material quantity ( 239Pu fissile gram equivalent [ FGE])     200 g/ 55 gal. drum ( including pipe overpacks)

    325 g/ SWB or TDOP     325 g/ TRUPACT II     2,800 g/ TRUPACT II ( 14 pipe overpacks) TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Operation of the SuperHENC Assay System ( TRU OP 002)

Calculation of Assay Results ( WMP 350, Section 2.2)

Data Management ( WMP 350, Section 2.3)

GEA Energy and Efficiency Setup and Baseline Establishment ( WMP 350,

Section 2.5)

WRAP NDA Measurement Control Program ( WMP 350, Section 2.8)

Performing Calibration Verifications and Confirmations for NDA at WRAP HNF 2600, REV 15 Page 211 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures ( WMP 350, Section 2.9)

GEA Calibration Using NDA2000 ( WMP 350, Section 2.10)

Imaging Passive/ Active Neutron Assay Operation ( WRP1 OP 0905)

Gamma Energy Assay Operations ( WRP1 OP 0906)

Gamma Energy Assay Operations Using NDA2000 ( WRP1 OP 0907)

Data Management ( FSP PFP 5 8, Section 16.2)

QC Criteria for Residues Project NDA Instruments ( FSP PFP 5 8, Section 16.3) Calibration Confirmation for Residues Project NDA Instruments ( FSP PFP

5 8, Section 16.4)

Calculation of Assay Results ( ZA 400 302)

Energy and Efficiency Setup and Baseline Determination Using NDA 2000 ( ZA 400 303)

ANTECH Calorimeter Calibration ( ZA 400 304)

NDA Using NDA 2000 ( ZA 948 392)

NDA Using the Room 172 ANTECH Calorimeters ( ZA 948 393)

Pipe N Go Operations ( ZO 160 080)

Pu/ Al Alloys Operations ( ZO 160 081) ( Inactive)

3.3.3 NA TRU alpha activity   > 100 nCi of alpha emitting TRU isotopes with half lives greater than 20 years per gram of waste matrix TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Operation of the SuperHENC Assay System ( TRU OP 002)

Calculation of Assay Results ( WMP 350, Section 2.2)

Data Management ( WMP 350, Section 2.3)

Imaging Passive/ Active Neutron Assay Operation ( WRP1 OP 0905)

Gamma Energy Assay Operations ( WRP1 OP 0906)

Gamma Energy Assay Operations Using NDA2000 ( WRP1 OP 0907)

Data Management ( FSP PFP 5 8, Section 16.2)

Calculation of Assay Results ( ZA 400 302)

Energy and Efficiency Setup and Baseline Determination Using NDA 2000 ( ZA 400 303)

ANTECH Calorimeter Calibration ( ZA 400 304)

NDA Using NDA 2000 ( ZA 948 392)

NDA Using the Room 172 ANTECH Calorimeters ( ZA 948 393) HNF 2600, REV 15 Page 212 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures 3.3.4 NA 239Pu equivalent activity ( 239Pu equivalentcuries [ PE Ci]) Untreated Waste     80 PE Ci/ 55 gal. Drum     130 PE Ci/ SWB     130 PE Ci/ drum overpacked in TDOP     1800 std. POC     1100 PE Ci/ 55 gal. drum overpacked in SWB or TDOP or 85 gal. drum Solidified/ Vitrified Waste     1800 PE Ci/ 55 gal. drum ( including a drum containing a pipe component) ( see PE Ci table in subsection <IP_ADDRESS> of this Certification Plan) TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Operation of the SuperHENC Assay System ( TRU OP 002)

Calculation of Assay Results ( WMP 350, Section 2.2)

Data Management ( WMP 350, Section 2.3)

Imaging Passive/ Active Neutron Assay Operation ( WRP1 OP 0905)

Gamma Energy Assay Operations ( WRP1 OP 0906)

Gamma Energy Assay Operations Using NDA2000 ( WRP1 OP 0907)

Data Management ( FSP PFP 5 8, Section 16.2)

Calculation of Assay Results ( ZA 400 302)

Energy and Efficiency Setup and Baseline Determination Using NDA 2000 ( ZA 400 303)

ANTECH Calorimeter Calibration ( ZA 400 304)

NDA Using NDA 2000 ( ZA 948 392)

NDA Using the Room 172 ANTECH Calorimeters ( ZA 948 393)

3.3.6 3.2 ( 4.4.2) Radiation dose rate     200 mrem/ hr ( at surface for payload containers and TRUPACT II)

    10 mrem/ hr at 2 meters ( TRUPACT II only) TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Repackaging Visual Examination and Sampling ( WMP

400, Section 7.1.3)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Receive and Load TRUPACT Containers ( WRP1 OP 0521)

Radiological Support of TRUPACT II Shipping and Receiving ( WRP1 OP

1225)

Chemical Properties Criteria and Requirements 3.5.1 4.1 ( 4.5.1) Pyrophoric materials   < 1 weight percent radionuclide pyrophorics   No nonradionuclide pyrophorics TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

3.5.2 NA Hazardous wastes   Characterization per HNF 2599 ( as defined in WAP)

  Limited to EPA hazardous waste numbers approved by WIPP WAP TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Characterization Data Quality Objectives Reconciliation and Reporting ( WMP 400, Section 7.1.1) HNF 2600, REV 15 Page 213 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3)

Sampling Design and Data Analysis for RCRA Characterization and Visual Examination of Transuranic Waste ( WMP 400, Section 7.1.4)

Transuranic Waste Transportation and Disposal Certification ( WMP 400,

Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

Data Management for Headspace Gas Sampling and Analytical Results ( WMP 400, Section 8.1.8)

ACE Program Implementation and Operation of Spreadsheet Interface ( WMP 310, Section 9.1)

Mercury Analysis by Cold Vapor Atomic Absorption ( LA 325 104)

Acid Digestion of Solid and Liquid Samples for Graphite Furnace Atomic Absorption Analysis ( GFAA) ( LA 505 100)

Metal Analysis by Graphite Furnace Atomic Absorption ( GFAA) using the Perkin Elmer 5100 PC ( LA 505 102)

Inductively Coupled Plasma ( ICP) Emission Spectrometric Method for the Applied Research Laboratories ( LA 505 151)

Acid Digestion/ Dilution of Aqueous Samples and Extracts ( LA 505 158)

Acid Digestion of Sediments, Sludges, and Soils for Inductively Coupled Plasma ( ICP) and Atomic Absorption ( AA) Analysis ( LA 505 159)

Inductively Coupled Plasma ( ICP) Emission Spectrometric Method for Jarrel Ash Type 61E ( LA 505 161)

Determination of Trace Elements and Radionuclides by Inductively Coupled Plasma Mass Spectrometry using TJA Poems ( LA 506 101)

Determination of Volatile Organic Compounds in TRU/ Mixed Waste Container Headspace ( LA 523 410)

Determination of Total Nonmethane Organic Compounds in TRU Waste Container Headspace ( LA 523 425)

Polychlorinated Biphenyls ( PCBs) by Volatile Sample Analysis by SSW 846 ( LA 523 455)

Semivolatile Sample Analysis by SW 846, Method 8270B1 ( LA 523 456)

3.5.3 4.3 ( 4.5.3) Chemical Composition Chemicals allowed within a given waste material type so a conservative bonding TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) HNF 2600, REV 15 Page 214 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures G value can be established Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

TRU Waste Visual Examination Technique ( WMP 400, Section 7.1.10)

4.4 ( 4.5.4) Chemical compatibility All chemicals must be allowable per the CH TRAMPAC TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

3.5.4 4.2 ( 4.5.2) Explosives,

corrosives,

and compressed gases   No explosives, compressed gases,

or pressurized containers   No ignitable, reactive, or corrosive wastes TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

TRU Waste Visual Examination Technique ( WMP 400, Section 7.1.10)

TRU RWM Glovebox Automatic Mode Operations ( WRP1 OP 0722)

TRU Sorting Glovebox Operation ( WRP1 OP 0725)

TRU Loadout Glovebox Operation ( WRP1 OP 0726)

TRU Waste Certification  Operation of the Drum NDE System ( WRP1 OP

0908)

Pipe and Go Operations ( ZO 160 080)

Pu/ Al Alloys Operations ( ZO 160 081) ( Inactive)

Load Standard Waste Box ( SWB) Storage Containers With TRU Waste ( ZO 170 044)

Visual Examination Technique for PFP Debris Waste ( Z0 170 057)

3.5.6 NA PCB concentration   < 50 ppm TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section HNF 2600, REV 15 Page 215 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures 7.1.9)

Gas Generation Properties Criteria and Requirements 3.3.7 5.0 ( 4.6.2) Decay heat Test category waste     Decay heat limit for the authorized shipping category     40 W per TRUPACT II TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Operation of the SuperHENC Assay System ( TRU OP 002)

Calculation of Assay Results ( WMP 350, Section 2.2)

Data Management ( WMP 350, Section 2.3)

Imaging Passive/ Active Neutron Assay Operation ( WRP1 OP 0905)

Gamma Energy Assay Operations ( WRP1 OP 0906)

Gamma Energy Assay Operations Using NDA2000 ( WRP1 OP 0907)

Data Management ( FSP PFP 5 8, Section 16.2)

Calculation of Assay Results ( ZA 400 302)

Energy and Efficiency Setup and Baseline Determination Using NDA 2000 ( ZA 400 303)

ANTECH Calorimeter Calibration ( ZA 400 304)

NDA Using NDA 2000 ( ZA 948 392)

NDA Using the Room 172 ANTECH Calorimeters ( ZA 948 393)

3.5.5 5.0 ( 4.6.2) Headspace gas VOC concentration   Every container or randomly selected containers from waste streams that meet the conditions for reduced headspace gas sampling will be headspace gas sampled per HNF 2599 as defined in the WAP     500 ppm VOC for analytical category     500 ppm VOC for test category   Hydrogen methane gas sampler per Appendix F. TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Sampling Design and Data Analysis for RCRA Characterization and Visual Examination of Transuranic Waste ( WMP 400, Section 7.1.4)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

Data Management for Headspace Gas Sampling and Analytical Results ( WMP 400, Section 8.1.8)

Headspace Gas Samples of TRU Waste Containers ( TRU OP 001)

Determination of Volatile Organic Compounds in TRU/ Mixed Waste Container Headspace ( LA 523 410)

Determination of permanent gases in TRU waste container headspace ( LA

523 426)

N/ A 5.3 Venting and     Times shown in CH TRUCON TRU Waste Transportation Certification and Logistics ( WMP 400, Section HNF 2600, REV 15 Page 216 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures ( 4.6.3) aspiration tables   Options for determining aspiration time based on date of drum closure 2.1.5) Sampling Design and Data Analysis for RCRA Characterization and Visual Examination of Transuranic Waste ( WMP 400, Section 7.1.4)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

N/ A 5.1 ( 4.6.1) Payload shipping category   Approved content codes listed in CH TRUCON tables   Assigned shipping category per WIPP CH TRU Payload Engineer   Derived shipping category decay heat limits for TRUPACT II TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Repackaging, Visual Examination, and Sampling ( WMP

400, Section 7.1.3)

Transuranic Waste Certification ( WMP 400, Section 7.1.8)

Acceptable Knowledge Documentation Management ( WMP 400, Section 7.1.9)

TRU Waste Visual Exam Technique ( WMP 400, Section 7.1.10)

Receive and Load TRUPACT Containers ( WRP1 OP 0521)

TRU RWM Glovebox Automatic Mode Operations ( WRP1 OP 0722)

TRU Sorting Glovebox Operation ( WRP1 OP 0725)

TRU Loadout Glovebox Operation ( WRP1 OP 0726)

Operation of the Drum Nondestructive Examination System ( WRP1 OP

0908)

Pipe and Go Operations ( ZO 160 080)

Pu/ Al Alloys Operations ( ZO 160 081) ( Inactive)

Load Standard Waste Box ( SWB) Storage Containers With TRU Waste ( ZO 170 044)

Visual Examination Technique for PFP Debris Waste ( ZO 170 057)

N/ A 3.3 4.4.3 Activity Limits   S100 POC maximum total activity TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Transuranic Waste Certification ( WMP 400, Section 7.1.8) HNF 2600, REV 15 Page 217 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CH WAC & Cert.

Plan Sect. CH TRAMPAC (& Cert. Plan Sect., if app) Criteria Requirements Compliance and Verification Procedures Data Packages Criteria and Requirements 3.6.2 6.0 ( 4.7) Shipping data   Payload Container Transportation Certification Document   Overpack PCTCD   Payload Assembly Transportation Certification Document ( analytical/ test)

  Bill of ladingb   Land disposal restriction notification a   UHWMa TRU Waste Transportation Certification and Logistics ( WMP 400, Section 2.1.5) Receive and Load TRUPACT Containers ( WRP1 OP 0521)

Radiological Support of TRUPACT II Shipping and Receiving ( WRP1 OP

1225) Determination of Permanent Gases in TRU Waste Container Headspace ( LA 523 426)

a Applies to mixed wastes only ( a one time notice per waste stream)

b A Uniform Hazardous Waste Manifest may be substituted HNF 2600, REV 15 Page 218 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX B 1 PAYLOAD CONTAINER TRANSPORTATION CERTIFICATION DOCUMENT: ANALYTICAL PAYLOAD SHIPPING CATEGORY HNF 2600, REV 15 Page 219 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TRUPACT II PAYLOAD CONTAINER TRANSPORTATION CERTIFICATION DOCUMENT ( PCTCD) ( Analytical Category) a IDENTIFICATION PARAMETERS Container/ Barcode ID# Certification Site Shipping Category Content Code Direct Load Configurations

55 Gallon Drum

85 Gallon Drum

SWB

TDOP Fixed Configurations

6 inch Standard Pipe Overpack

12 inch Standard Pipe Overpack

S100 Pipe Overpack

S200 Pipe Overpack

SWB with Bin ( Bin Overpack)

Overpacked Configurations

85 Gallon Drum with 55 Gallon Drum ( 85 Gallon Drum Overpack)

SWB with 55 Gallon Drum( s) ( SWB Overpack)

TDOP with 55 Gallon Drum( s)

TDOP with SWB Overpack

TDOP with 85 Gallon Drum Overpack( s)

TDOP with 85 Gallon Drum( s)

TDOP with SWB

TDOP with Bin Overpack CH TRAMPAC TRANSPORTATION PARAMETERS Parameter Initials Filter( s) Identification Residual liquids are < 1% of payload container volume Sharp/ heavy objects are blocked/ braced/ suitably packaged Nonradioactive pyrophorics are not present or have been reacted Radioactive pyrophorics are < 1% ( weight) Explosives are not present Corrosives are not present Pressurized containers and compressed gases are not present Sealed container > 4 liters are not present ( except for Waste Material Type II. 2) Rigid liner ( if present) is punctured/ vented Flammable VOCs are   500 ppm Surface radiation dose rate is < payload container limitb 1. 2.

3. 4.

5. 5.

7. 7.

9. 10.

MEASURED PARAMETERS Container Parameter Value Error Value + 1x Error Value + 2x Error Limit Weight ( lbs) Decay heat ( watts) Fissile mass ( FGE) Curie limits ( Ci) S200 Pipe overpacks only Payload container meets limits specified in Section 3.3 of THE CH TRAMPAC Yes/ No HNF 2600, REV 15 Page 220 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN UNVENTED WASTE PARAMETERS ONLY Aspiration Method

Option 1

Option 2a

Option 2b

Option 3 Aspiration period ( if applicable) days Option 1 Container closed time months Aspiration table no. ( if applicable) Options 2a, 2b, or 3 Headspace H2 concentration mol% Time container vented days I certify that the above container meets all the requirements for shipment as stated in the CH TRAMPAC. The container is approved for

payload assembly or

overpacking.

/ Transportation Certification Official ( print/ sign) Date aFollow instructions in Section <IP_ADDRESS>. bLimits are not applicable if container is to be overpacked. HNF 2600, REV 15 Page 221 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX B 2 OVERPACK PAYLOAD CONTAINER TRANSPORTATION CERTIFICATION DOCUMENT ( OPCTCD) HNF 2600, REV 15 Page 222 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN OVERPACK PAYLOAD CONTAINER TRANSPORTATION CERTIFICATION DOCUMENT ( OPCTCD) a IDENTIFICATION PARAMETERS Overpack Container ID# Overpack Container Bar Code # Governing Payload Shipping Category Numberb Governing Decay Heat Limitb Governing Hydrogen/ Flammable Gas Generation Rate Limitb Overpack Container Type

85 Gallon Drum

SWB

TDOP Overpacked Container Type( s)

55 Gallon Drum( s)

SWB

SWB Overpack

85 Gallon Drum Overpack( s)

85 Gallon Drum ( s)

Bin Overpack Weight Limitc ( lbs) Fissile Mass Limitc FGE Certification Site Content Code CH TRAMPAC TRANSPORTATION PARAMETERS Surface Radiation Dose Rate   payload container limitc Initials Filter Identification 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

OVERPACKED CONTAINER MEASURED PARAMETERS Overpacked Container ID Number Weight ( lbs) Error ( lbs) Decay Heat ( watts) Error ( watts) Decay Heat Limits ( watts) Fissile Mass ( FGE) 2x Error ( FGE) Hydrogen/ Flammable Gas Generation Rate ( mol/ s) Flammability Limitd   Weight and error of empty overpack payload container ( if applicable) Total ( A) Total RMS* Error Total + RMS* Error HNF 2600, REV 15 Page 223 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN CERTIFICATION OF COMPLIANCE Initials Total weight + weight error   limitc Total fissile mass + 2x fissile mass error   limitc Decay heat + decay heat error   decay heat limit of governing payload shipping category for each analytical category payload containerb Hydrogen/ flammable gas generation rate   hydrogen/ flammable gas generation rate limit of governing payload shipping category for each test category payload containerb Flammability Index ( FI) of each overpacked container meets the following criteria: 0   FI   50,000d * Calculated as RSS I certify that the above overpack container meets all the requirements for shipment as an overpack as stated in the CH TRAMPAC. The overpack is approved for

payload assembly or

overpacking.

/ Transportation Certification Official ( print/ sign) Date aFollow instructions in Section <IP_ADDRESS> of the CH TRAMPAC. bNot applicable if mixing shipping categories pursuant to Section 4.7.4. cLimits are not applicable if container is to be overpacked. dApplicable if mixing shipping categories pursuant to Section 4.7.4. FI is determined as part of payload assembly ( Section 6.2.2 of the CH TRAMPAC). HNF 2600, REV 15 Page 224 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX B 3 TRUPACT II TEST CATEGORY PAYLOAD CONTAINER DATA SHEET HNF 2600, REV 15 Page 225 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TRUPACT II TEST CATEGORY PAYLAOD CONTAINER DATA SHEET ( Example)

SECTION 1 Identification Parameters Container ID No. Container Bar Code No.

Shipping Category Content Code Container Type

55 gal. drum

SWB

TDOP

85 gal drum Filter Type Certification Site Test Category Classification Measurement ( Waste Types I, II, or III) 55 Gal. Drum Testing ( Complete Sections 2, 3, 4, and 6) ( Complete Sections 2, 3, 5, and 6)

Decay Heat > Analytical Limit

Decay Heat > Analytical Limit

Flammable VOC Concentration > 500 ppm

Fail Measurement

Waste Type IV SECTION 2 Methane Concentration Location of methane measurement Container headspace/ inside liner Date of methane measurement Measured methane concentration ( ppm)

Measured methane concentration   1,250 ppm YES/ NO HNF 2600, REV 15 Page 226 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN SECTION 3 Flammable VOC Concentration

No flammable VOCs present

Maximum concentration of flammable VOCs in payload container headspace   500 ppm ( from process knowledge)

Flammable VOC Headspace Measured Concentration ( ppm) Predicted Innermost Confinement Layer Concentration ( ppm) Acetone Benzene 1 Butanol Chlorobenzene Cyclohexane 1,1 Dichloroethane 1,2 Dichloroethane 1,1 Dichloroethene cis 1,2 Dichloroethene Ethyl benzene Ethyl ether Methanol Methyl ethyl ketone Methyl isobutyl ketone Toluene 1,2,4 Trimethylbenzene 1,3,5 Trimethylbenzene m Xylene o Xylene p Xylene Sum of flammable VOCs HNF 2600, REV 15 Page 227 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN SECTION 4 Measurement 1. Decay heat plus error ( W)

Wattage limit for TRUPACT II design pressure limit Decay heat plus error   wattage limit for TRUPACT II Design pressure limit YES/ NO 2. Calculated flammable gas generation rate ( FGGR) ( mol/ sec)

3a. Maximum allowable hydrogen gas generation rate of container or controlling shipping category ( mol/ sec)

Calculated FGGR   maximum allowable hydrogen gas generation rate of container or controlling shipping category YES/ NO 3b. Calculated innermost confinement layer flammable gas concentration ( vol %)

Mixture lower explosive limit ( MLEL) ( vol %)

Calculated innermost confinement layer flammable gas concentration plus sum of flammable VOCs ( innermost confinement layer concentration) ( vol %)

Calculated innermost confinement layer flammable gas plus flammable VOCs   MLEL YES/ NO HNF 2600, REV 15 Page 228 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN SECTION 5 55 Gallon Drum Testing 1. Decay heat plus error ( W)

2. Maximum decay heat per drum and per TRUPACT II ( W)

3a. May gas generation testing be performed at room temperature? YES/ NO 3b. Total measured gas release rate ( mol/ sec)

Maximum allowable total gas release rate ( mol/ sec)

Total measured gas release rate   maximum allowable gas release rate limit YES/ NO 4. Measured flammable gas generation rate ( FGGR) ( mol/ sec)

5a. Maximum allowable hydrogen gas generation rate ( mol/ sec)

Measured FGGR   maximum allowable hydrogen gas generation rate YES/ NO 5b. Calculated innermost confinement layer flammable gas concentration ( vol %)

Mixture lower explosive limit ( MLEL) ( vol %)

Calculated innermost confinement layer flammable gas concentration plus sum of flammable VOCs ( innermost confinement layer concentration) ( vol %)

Calculated innermost confinement layer flammable gas plus flammable VOCs   MLEL YES/ NO HNF 2600, REV 15 Page 229 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN SECTION 6 Measurement/ Testing Certification Does payload container meet test category criteria? YES/ NO / ( Print Name) ( Sign Name) ( Date) Transportation Certification Official HNF 2600, REV 15 Page 230 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX C PAYLOAD CONTAINER TRANSPORTATION CERTIFICATION DOCUMENT: TEST PAYLOAD SHIPPING CATEGORY HNF 2600, REV 15 Page 231 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TRUPACT II PAYLOAD CONTAINER TRANSPORTATION CERTIFICATION DOCUMENT ( PCTCD) ( Test Category) a IDENTIFICATION PARAMETERS Container ID # Container Barcode # Certification Site Container Designated for Controlled Shipment?

Yes

No Shipping Category Content Code Direct Load Configurations

55 Gallon Drum

85 Gallon Drum

100 Gallon Drum

SWB

TDOP Fixed Configurations

6 inch Standard Pipe Overpack

12 inch Standard Pipe Overpack

S100 Pipe Overpack

S200 Pipe Overpack

S300 Pipe Overpack

SWB with Bin ( Bin Overpack)

Overpacked Configurations

85 Gallon Drum with 55 Gallon Drum ( 85 Gallon Drum Overpack)

SWB with 55 Gallon Drum( s) ( SWB Overpack)

TDOP with 55 Gallon Drum( s)

TDOP with SWB Overpack

TDOP with 85 Gallon Drum Overpack( s)

TDOP with 85 Gallon Drum( s)

TDOP with SWB

TDOP with Bin Overpack CH TRAMPAC TRANSPORTATION PARAMETERS Parameter Initials Filter( s) Identification Residual liquids are < 1% of payload container volume Sharp/ heavy objects are blocked/ braced/ suitably packaged Nonradioactive pyrophorics are not present or have been reacted Radioactive pyrophorics are < 1% ( weight) Explosives are not present Corrosives are not present Pressurized containers and compressed gases are not present Sealed container > 4 liters are not present ( except for Waste Material Type II. 2) Rigid liner ( if present) is punctured/ vented Surface radiation dose rate is < payload container limitb 1. 2.

3. 4.

5. 6.

7. 8.

9. 10.

MEASURED PARAMETERS Container Parameter Value Error Value + 1x Error Value + 2x Error Limit Weight ( lbs) b Fissile mass ( FGE) b Curie limits ( Ci) S200 Pipe overpacks only Payload container meets limits specified in Section 3.3 of the CH TRAMPAC Yes/ No UNVENTED WASTE PARAMETERS Aspiration Method

Option 1

Option 2A

Option 2B

Option 3 Required Aspiration Period days Option 1 Container Closed Time months Option 2A, 2B, or 3 Headspace H2 Concentration mol% Time Container Vented days HNF 2600, REV 15 Page 232 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN TEST CRITERIA UFGTP requirements are met as documented in Section 5.2.5 of the CH TRAMPAC Yes/ No I certify that the above container meets all the requirements for shipment as stated in the CH TRAMPAC, current revision. The container is approved for

payload assembly or

overpacking.

/ ( Print Name) ( Sign Name) ( Date) Transportation Certification Official aFollow instructions in Section <IP_ADDRESS>. bLimits are not applicable if container is to be overpacked. HNF 2600, REV 15 Page 233 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX D PAYLOAD ASSEMBLY TRANSPORTATION CERTIFICATION DOCUMENT HNF 2600, REV 15 Page 234 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN PAYLOAD ASSEMBLY TRANSPORTATION CERTIFICATION DOCUMENT ( PATCD) a IDENTIFICATION PARAMETERS Shipment No. Packaging OCA Body/ Lid No. Payload Assembly Designated for Controlled Shipment? b

Yes

No Shipping Categoryc Decay Heat Limitc Hydrogen/ Flammable Gas Generation Rate Limitc Type of Payload

55 Gallon Drums

Standard Pipe Overpacks

S100 Pipe Overpacks

S200 Pipe Overpacks

S300 Pipe Overpacks

85 Gallon Drums

100 Gallon Drums

SWBs

TDOP Transportation Packaging:

TRUPACT II

HalfPACT Date ICV Closed Time ICV Closedd Certification Site BOTTOM PAYLOAD ASSEMBLY COMPOSITION Container ID Weight ( lbs) Error ( lbs) Decay Heat ( watts) Error ( watts) Fissile Mass ( FGE) 2 x Error ( FGE) Hydrogen/ Flammable Gas Generation Rate e, f, g Flammability Indexf, g Subtotal ( A) Subtotal RSS Error ( C) TOP PAYLOAD ASSEMBLY COMPOSITION ( TRUPACT II Only) Container ID Weight ( lbs) Error ( lbs) Decay Heat ( watts) Error ( watts) Fissile Mass ( FGE) 2 x Error ( FGE) Hydrogen/ Flammable Gas Generation Ratee, f, g Flammability Indexf, g Subtotal ( B) Subtotal RSS Error ( D) PAYLOAD TOTALS Weight of Pallets, Reinforcing Plats, Slip Sheets, Guide Tubes, Adjustable Slings, etc. ( E) Total ( A+ E[+ B ( TRUPACT II only)]) Weight lbs Total RSS Weight Error lbs Total ( A+ B) Decay Heat Watts Total RSS Decay heat Error watts Total ( A+ B) Fissile Mass FGE Total RSS Fissile Mass Error FGE Bottom Assembly Weight plus Subtotal RSS Error ( A+ C) ( TRUPACT II Only) lbs Top Assembly Weight plus Subtotal RSS Error ( B+ D) ( TRUPACT II Only) lbs Total Weight plus Total RSS Error lbs Total Fissile Mass plus Total RSS Error FGE Total Decay Heat plus Total RSS Error watts HNF 2600, REV 15 Page 235 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN PAYLOAD CERTIFICATION PARAMETERS Initials Decay Heat + Error of Each Analytical Category Payload Container   Governing Limitc Hydrogen/ Flammable Gas Generation Rate of Each Test Category Payload Container   Governing Limitc, e Flammability Index of Each Payload Container meet the following criteria: 0   FI   50,000f Payload Total Gas Release Rate   Limit Calculated in accordance with CH TRAMPAC, Section 6.2.5h Bottom Weight   Top Weight ( for TRUPACT II) Total Weight plus RSS Error   7265 lbs for TRUPACT II;   7600 lbs for HalfPACT Decay Heat plus RSS Error   40 Watts for TRUPACT II;   30 watts for HalfPACT Fissile Mass ( 239Pu FGE) plus RSS Error   FGE Total activity plus error for S100 or S300 pipe overpack payloads   406 curies I certify that the above payload assembly meets all the requirements for shipment as stated in the CH TRAMPAC, current revision. The payload assembly is approved for shipment.

/ ( Print Name) ( Sign Name) ( Date) Transportation Certification Official aFollow instructions in Section 6.2.2 of the CH TRAMPAC. bIf the payload is designated for controlled shipment, Table 6.2 5 must also be completed for the shipment of this payload as specified in Section 6.2.3 of the CH TRAMPAC. cNot applicable if mixing shipping categories pursuant to Section 4.7.4. dRequired only for payloads designated for Controlled Shipment ( 10 days) eRequired for payloads containing test category payload containers. fApplicable if mixing shipping categories pursuant to Section 4.7.4. gIf the payload assembly consists of overpacked configurations, indicate not applicable ( e. g., " NA   Mixing") and record the hydrogen/ flammable gas generation rate and FI values for each overpacked container on the appropriate OPCTCD. hApplicable if shipping pursuant to Section 6.2.5 of the CH TRAMPAC. HNF 2600, REV 15 Page 236 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN APPENDIX E NONDESTRUCTIVE ASSAY HNF 2600, REV 15 Page 237 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN E. 0 INTRODUCTION At the Hanford site, only nondestructive assay ( NDA) techniques are used in the radiological characterization and certification of TRU waste for shipment to WIPP. This appendix describes the Hanford TRU Project requirements to meet the requirements specified in the WIPP contacthandled waste acceptance criteria ( CH WAC) for NDA. Radiochemistry requirements are not addressed in this appendix.

Radiological characterization is used to:

  Identify and quantify the activity of the ten WIPP tracked isotopes ( i. e., 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr and 137Cs),   Identify and quantify the activity for other isotopes to ensure U. S. Department of Transportation ( DOT) and certificate of compliance ( C of C) requirements to identify and quantify the isotopes contributing to at least 95 percent of the total radiological hazard. Identification and quantification of 235U without regard to total package activity is necessary to meet DOT requirements for fissile gram equivalent ( FGE) determination,   Ensure applicable requirements for decay heat, 239Pu FGE, and 239Pu equivalent activity ( PE Ci) are met, and   Demonstrate that the waste being disposed of at WIPP meets the radiological definition of TRU waste.

Acceptable knowledge ( AK) may be used to supplement NDA for hard to detect radionuclides ( e. g., 90Sr and 234U), when poor counting statistics exist, etc. The requisite data on isotopic ratios and quantities will be derived from AK ( see subsection E. 1), NDA, or both, using CBFOapproved NDA.

The SPO must technically justify the AK, and each facility must technically justify that the NDA techniques, instruments, and procedures used:

  Are appropriate for the specific waste stream and waste content code descriptions being assayed,   Will result in unbiased values for the activity and mass of the WIPP radionuclide inventory, and   Are initiated, revised, reviewed, maintained, controlled in accordance with Hanford TRU Project procedures.

Controlled changes to radioassay ( NDA or radiochemistry) related plans or procedures shall be managed through the document control process described in the QAPD. The Site Project Manager and the Site QA Officer shall review all such changes and report to the CBFO those changes that could impact compliance with the criteria in this Certification Plan. The Site Project Manager shall ensure that site approved changes to radioassay related plans or procedures affecting either the performance criteria or data quality of certified systems/ processes are not used in the collection of waste certification data prior to CBFO's review and approval. Related testing, calibration, and training performed in accordance with these site approved changes, however, are not precluded from being conducted prior to CBFO's review and HNF 2600, REV 15 Page 238 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN approval. ( Memorandum from CBFO to Distribution, CBFO: NTP: RMK: VW: 02 2734: UFC5822, July 29, 2002.)

E. 1 RADIONUCLIDE ISOTOPIC RATIOS Direct measurement using WIPP certified NDA equipment of all containers in a waste stream has been selected as the methodology to perform radiological characterization of TRU waste at the Hanford site. It is recognized that certain nuclides ( e. g., 90Sr and 234U) cannot be quantified using NDA and that technical reasons may cause the NDA for certain waste to be invalid ( e. g., poor counting statistics). Under these circumstances, AK will be used to complete radiological characterization.

E. 1.1 Methods for Confirmation of Isotopic Ratio Acceptable Knowledge The Hanford site requires that all containers of TRU waste be assayed to perform radiological characterization of that waste. The batch data reports shall contain results of isotopic measurements. The SPO shall correlate the results of actual measurements to AK. Reference E22 shall describe the documentation and discrepancy resolution requirements for this correlation.

Because 234U and 90Sr cannot be detected using the NDA systems currently in use at the Hanford site, the means and methodology to quantify these isotopes from other measured isotopes shall be technically justified in the AK documentation described below. If measured isotopic results are not used, the use of AK must be either included with or referenced in NDA batch data reports. Examples of this quantification include using isotopic ratios to calculate 234U from the measured 235U ( and possibly 238U) and 90Sr from the measured 137Cs. When the activity of an isotope is scaled or correlated from the measured value of another isotope ( e. g., 90Sr calculated from measured 137Cs or 234U from 235U or 238U), the NDA batch data report shall contain sufficient information to independently perform or repeat that calculation.

The acceptance or rejection of identified isotopes or unidentified peaks is usually part of routine analytical procedures and is not normally subject to AK requirements. Examples of this include using confirmatory peaks or correlation to demonstrate the absence or presence of certain isotopes or elimination of a nuclide or peak based upon high counting error. Facility procedures shall specify the means to document such rejection, acceptance, or correlation.

If any of the ten WIPP tracked isotopes are determined not to be present in a waste stream on the basis of AK, this shall be technically justified in the AK.

E. 1.2 Acceptable Knowledge ( AK) Documentation E. 1.2.1 Required Elements The use of AK information concerning the radiological composition of a waste stream will be documented either in the AK summary report for the waste characterization of the waste stream or in another controlled document approved by the SPM. Should this information be contained in AK package( s) prepared to meet other general waste characterization requirements, it need not HNF 2600, REV 15 Page 239 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN be duplicated in other controlled documents that address the radiological properties of the waste stream. The following information shall be included as part of the written AK record, as described in WMP 400, Section 7.1.9:

  Map of the Hanford site with the areas and facilities involved in TRU mixed waste generation, treatment, and storage identified,   Facility mission description as related to radionuclide bearing materials and their management ( e. g., routine weapons production, fuel research and development, and experimental processes),   Description of the specific facility locations ( such as the area or building) and operations relative to the isotopic composition of the TRU wastes they generated ( e. g., plutonium recovery, weapons fabrication, pyrochemical operations, and waste incineration),   Waste identification or categorization schemes used at the facility relevant to the waste material's isotopic distribution ( e. g., the use of codes that correlate to a specific isotopic distribution), and a description of the isotopic composition of each waste stream,   Information regarding the waste's physical and chemical composition that could affect the isotopic distribution ( e. g., processes used to remove ingrown 241Am or alter its expected contribution based solely on radioactive decay kinetics),   Statement of all numerical adjustments applied to derive the material's isotopic distribution ( e. g., scaling factors, decay/ ingrowth corrections and secular equilibrium considerations),   Specification of the isotopic ratios for the ten WIPP tracked radionuclides ( 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs) and, if applicable, other radionuclides such that at least 95 percent of the total radiological hazard in a waste stream, waste stream subpopulation, and container basis is reported. Additionally, the isotopic ratios for radionuclides that are neither one of the ten WIPP tracked isotopes nor otherwise contribute to 95 percent of the total radiological hazard must be established and technically justified in the AK documentation if either of the below conditions are met:

1. The radionuclide contributes to FGE ( e. g., 237Np or 235U)

2. The radionuclide is used to scale one of the ten WIPP tracked isotopes.

The type and quantity of supporting documentation may vary by waste stream and shall be compiled in a written record that shall include a summary identifying all sources of information used to delineate the waste stream's isotopic distribution. The basis and rationale for the delineation shall be clearly summarized in an AK report and traceable to referenced documents. Assumptions made in this delineation shall be identified.

E. 1.2.2 Supplemental Acceptable Knowledge Information The SPO shall obtain supplemental AK information, dependent on availability. The amount and type of this information cannot be mandated, but the SPO shall collect information as appropriate to support documentation of the waste's isotopic distribution. This information will be used to compile the waste's AK written record, in accordance with WMP 400, Section 7.1.9. HNF 2600, REV 15 Page 240 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Supplemental AK documentation that may be used includes, but is not limited to, information from the following sources:

  Safeguards & Security, Materials Control & Accountability, and other nuclear materials control systems or programs and the data they generated,   Reports of nuclear safety or criticality, or accidents/ excursions involving the use of special nuclear material ( SNM) or nuclear material,   Waste packaging, waste disposal, building or nuclear material management area logs or inventory records, and available databases that provide information on SNM or nuclear materials,   Test plans, research project reports, or laboratory notebooks that describe the radionuclide content of materials used in experiments,   Information from facility personnel ( e. g., documented interviews), and   Historical analytical data relevant to the isotopic distribution of the waste stream.

E. 1.2.3 Discrepancy Resolution If there is a discrepancy between AK information related to isotopic ratios or composition, the SPO will evaluate the sources of the discrepancy to determine if the discrepant information is credible. Information that is not credible or information that is limited in its applicability to WIPP characterization will be identified as such, and the reasons for dismissing it will be justified in writing. Limitations concerning the information will be documented in the AK record and summarized in the AK report. If discrepancies result in a change to the original determinations, the AK summary will be updated. Discrepancy reporting and resolution shall be documented in accordance with reference E22.

Positive identification and quantification of any isotope previously identified in AK as not being present shall be treated as a discrepancy and documented in accordance with reference E22.

If a discrepancy cannot be resolved, the site will perform direct measurements for the impacted population of containers.

E. 2 DATA QUALITY OBJECTIVES The data quality objectives ( DQOs) for WIPP certifiable radiological characterization data are established in section 3.3 and summarized in section A. 3 of the CH WAC. They are summarized below in Table E 1 as they apply to individual payload containers. HNF 2600, REV 15 Page 241 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN Table E 1 Data Quality Objectives for NDA Requirement DQO Confidencea TRU   activity concentration > 100 nCi/ gb activity > LLD N/ A Fissile mass   FGE limit FGE + 2 TMU ( FGE)   FGE limit 97.5%

Decay Heat ( DH)   CH TRAMPAC limit DH + 1  TMU ( DH)   LCH TRAMPAC 84% aConfidence means the statistical level of confidence that the limit is exceeded or not exceeded depending on the requirements of the individual DQOs. The confidence is derived from the specified DQOs which assumes contributions to total measurement uncertainty ( TMU) are normally distributed. bTRU waste determinations shall be in accordance with the policy for management of TRU alpha activity concentration when overpacking waste containers.

There are no stipulated DQOs for PE Ci or individual isotope activities ( except as they impact the requirements listed above). However, at a minimum, NDA programs must be capable of identifying, measuring, and reporting the presence or absence of:

  The ten radionuclides identified in subsection 3.3.1 for tracking of the WIPP radionuclide inventory ( see subsection E. 1.1 above for discussion of hard to detect nuclides),   235U, in order to calculate FGE, as required in subsection 3.3.3 for compliance with transportation requirements,   Other radionuclides that contribute to at least 95 percent of total radiological hazard, as specified in subsection 3.3.1, for compliance with transportation requirements, and   Other radionuclides that contribute to FGE or decay heat ( e. g., 241Pu or 237Np if AK indicates the presence of such contributors) or any radionuclide used to scale one of the otherwise reportable radionuclides ( e. g., 235U for 234U).

In support of the above requirements, each facility must evaluate, document, and technically justify the following determinations.

1. Lower Limit of Detection: The lower limit of detection ( LLD) for each NDA system must be determined. Instruments performing TRU waste/ low level waste discrimination measurements must have an LLD of 100 nCi/ g or less. Facility specific environmental background and container specific interferences must be factored into LLD determinations. LLD is that level of radioactivity which, if present, yields a measured value greater than the critical level with a 95 percent probability, where the critical level is defined as that value which measurements of the background will exceed with 5 percent probability. Because LLD is a measurement based parameter, it is not feasible to calculate LLD for radionuclides that are not determined primarily by measurement ( e. g., 90Sr and 234U). In such cases, the facility shall derive the equivalent of an LLD ( i. e., a reporting threshold for a radionuclide( s), when it is technically justified). This value may be based on decay kinetics, scaling factors, or other scientifically based HNF 2600, REV 15 Page 242 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN relationships and must be adequately documented. For purposes of reporting radionuclide data in the WWIS, this value will be the equivalent of an LLD. References E3 and E4 provide information in developing the LLD. The method( s) for determining LLD shall be documented in a report to the SPO and approved by the SQAO.

2. Total Measurement Uncertainty ( TMU): The method used to calculate the TMU for the quantities in table E 1 must be documented and technically justified for each CBFO certified NDA system. It is permissible to combine reports for like or similar systems if the TMU is justified to be identical or if any differences are clearly identified and do not otherwise affect other portions of TMU. The likeness or similarity of the systems must be technically justified in the TMU report. Compliance with this requirement will be evaluated in reviews of the TMU documentation package for each assay system by CBFO. General guidance for determining the TMU is provided in references E5 and E6. TMU shall be properly justified and calculated and documented in a report to the SPO and approved by the SQAO.

3. Calibration. Each NDA system shall be calibrated before initial use. During calibration ( or recalibration), system correction factors shall be established and algorithms adjusted such that the value of % R ( percent recovery) is set equal to 100 percent ( i. e., the system is calibrated to 100% R). When calibrating NDA instruments, a calibration curve is usually fitted to a number of data points obtained with calibration sources.

The range of applicability of system calibrations must be specified in facility procedures. The matrix/ source surrogate waste combination( s) used for calibration shall be representative of the activity range( s) or gram loading( s), and relevant waste matrix characteristics ( e. g., densities, moderator content, container size) planned for measurement by the system.

Calibration and recalibration shall be documented in a report to the SPO and approved by the SQAO. Individual components or functions ( e. g., separate detectors or reference peak) may require individual calibration. Calibration of supporting systems ( e. g., gamma system used solely for isotopic measurements to support calorimetry or neutron measurements) may be limited to applicable portions of the calibration for that instrument ( e. g., just energy).

Calibration( s) shall be performed in accordance with consensus standards ( see NDA quality control [ QC] requirements below) when such standards exist. For calorimetry, calibration shall be performed in accordance with reference E17. If consensus standards are not used, full documentation of the calibration technique must be provided to and approved by CBFO before performing WIPP related assays. HNF 2600, REV 15 Page 243 of 281 5/ 11/ 2005 HANFORD SITE TRANSURANIC WASTE CERTIFICATION PLAN 4. Calibration Standards ( and Sources): Sources used for calibration and calibration confirmation shall meet the requirements listed below. Sources used for instrument performance measurements are not subject to these requirements but shall be well characterized.