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  A USQ EVALUATION IS REQUIRED TO CHANGE THIS PROCEDURE

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TABLE OF CONTENTS

#  {#section .TOC-1 .unnumbered}

## 4. WASTE ACCEPTANCE CRITERIA FOR CONTACT-HANDLED TRANSURANIC WASTE [3](#waste-acceptance-criteria-for-contact-handled-transuranic-waste)4.1 Scope [3](#scope) {#waste-acceptance-criteria-for-contact-handled-transuranic-waste-34.1-scope-3 .TOC-2}

### 4.1.1 Controlling Regulations [3](#controlling-regulations) {#controlling-regulations-3 .TOC-3}

### 4.1.2 Waste Type Covered by This Criteria [4](#waste-type-covered-by-this-criteria) {#waste-type-covered-by-this-criteria-4 .TOC-3}

### 4.1.3 Waste Type Not Covered by This Criteria [5](#waste-type-not-covered-by-this-criteria) {#waste-type-not-covered-by-this-criteria-5 .TOC-3}

## 4.2 Generator Waste Certification [6](#generator-waste-certification) {#generator-waste-certification-6 .TOC-2}

### 4.2.1 Liability for Waste Generation/Characterization [6](#liability-for-waste-generationcharacterization) {#liability-for-waste-generationcharacterization-6 .TOC-3}

### 4.2.2 Assessment [7](#assessment) {#assessment-7 .TOC-3}

### 4.2.3 Characterization [7](#characterization) {#characterization-7 .TOC-3}

### 4.2.4 Training [8](#training) {#training-8 .TOC-3}

### 4.2.5 Sampling and Verification [9](#sampling-and-verification) {#sampling-and-verification-9 .TOC-3}

### 4.2.6 Inventory Control [9](#inventory-control) {#inventory-control-9 .TOC-3}

### 4.2.7 Active Pursuit of Minimization [10](#active-pursuit-of-minimization) {#active-pursuit-of-minimization-10 .TOC-3}

### 4.2.8 Management of Satellite Accumulation [10](#management-of-satellite-accumulation) {#management-of-satellite-accumulation-10 .TOC-3}

## 4.3 New Generator Application [11](#new-generator-application) {#new-generator-application-11 .TOC-2}

### 4.3.1 Management Responsibility [11](#management-responsibility) {#management-responsibility-11 .TOC-3}

### 4.3.2 Description of Waste [12](#description-of-waste) {#description-of-waste-12 .TOC-3}

### 4.3.3 Generation Rate [13](#generation-rate) {#generation-rate-13 .TOC-3}

### 4.3.4 Identify Potential Conditions for Change [13](#identify-potential-conditions-for-change) {#identify-potential-conditions-for-change-13 .TOC-3}

### 4.3.5 Renewal Requirements [13](#renewal-requirements) {#renewal-requirements-13 .TOC-3}

### 4.3.6 Application Renewal and Approval Process [14](#application-renewal-and-approval-process) {#application-renewal-and-approval-process-14 .TOC-3}

### 4.3.7 Conditions for Cancellation [14](#conditions-for-cancellation) {#conditions-for-cancellation-14 .TOC-3}

### 4.3.8 Restrictions or Procurement [14](#restrictions-or-procurement) {#restrictions-or-procurement-14 .TOC-3}

## 4.4 Waste Transfer [15](#waste-transfer) {#waste-transfer-15 .TOC-2}

### 4.4.1 Notification [15](#notification) {#notification-15 .TOC-3}

### 4.4.2 Manifest [15](#manifest) {#manifest-15 .TOC-3}

### 4.4.3 Storage [15](#storage) {#storage-15 .TOC-3}

### 4.4.4 Response Time [15](#response-time) {#response-time-15 .TOC-3}

### 4.4.5 Containers [16](#containers) {#containers-16 .TOC-3}

### 4.4.6 Marking and Identification [16](#marking-and-identification) {#marking-and-identification-16 .TOC-3}

### 4.4.7 Packaging [17](#packaging) {#packaging-17 .TOC-3}

### 4.4.8 Conditions of Non-Acceptance [17](#conditions-of-non-acceptance) {#conditions-of-non-acceptance-17 .TOC-3}

## 4.5 Waste Acceptance Criteria [18](#waste-acceptance-criteria) {#waste-acceptance-criteria-18 .TOC-2}

### 4.5.1 Quantities and Concentrations [18](#quantities-and-concentrations) {#quantities-and-concentrations-18 .TOC-3}

### 4.5.2 Criticality [18](#criticality) {#criticality-18 .TOC-3}

### 4.5.3 Classification [19](#classification) {#classification-19 .TOC-3}

### 4.5.4 Thermal Power [19](#thermal-power) {#thermal-power-19 .TOC-3}

### 4.5.5 TRU Mixed Wastes [19](#tru-mixed-wastes) {#tru-mixed-wastes-19 .TOC-3}

### 4.5.6 Pyrophoric Materials [20](#pyrophoric-materials) {#pyrophoric-materials-20 .TOC-3}

### 4.5.7 Free Liquids [20](#free-liquids) {#free-liquids-20 .TOC-3}

### 4.5.8 Explosive and Compressed Gases [20](#explosive-and-compressed-gases) {#explosive-and-compressed-gases-20 .TOC-3}

### 4.5.9 Immobilization [20](#immobilization) {#immobilization-20 .TOC-3}

### 4.5.10 Gas Generation [21](#gas-generation) {#gas-generation-21 .TOC-3}

### 4.5.11 Waste Containers [21](#waste-containers) {#waste-containers-21 .TOC-3}

### 4.5.12 Specific Activity [22](#specific-activity) {#specific-activity-22 .TOC-3}

### 4.5.13 Waste Package Weight [22](#waste-package-weight) {#waste-package-weight-22 .TOC-3}

### 4.5.14 Surface Dose Rate [23](#surface-dose-rate) {#surface-dose-rate-23 .TOC-3}

### 4.5.15 Removable Surface Contamination [23](#removable-surface-contamination) {#removable-surface-contamination-23 .TOC-3}

## 4.6 Responsibility [24](#responsibility) {#responsibility-24 .TOC-2}

### 4.6.1 Custodial [24](#custodial) {#custodial-24 .TOC-3}

### 4.6.2 Excess Generation [24](#excess-generation) {#excess-generation-24 .TOC-3}

### 4.6.3 Funding [24](#funding) {#funding-24 .TOC-3}

### 4.6.4 Issues Resolution [24](#issues-resolution) {#issues-resolution-24 .TOC-3}

## 4.7 Treatment, Storage, and Disposal (TSD) Requirements [25](#treatment-storage-and-disposal-tsd-requirements) {#treatment-storage-and-disposal-tsd-requirements-25 .TOC-2}

### 4.7.1 Compliant TSD Operations [25](#compliant-tsd-operations) {#compliant-tsd-operations-25 .TOC-3}

### 4.7.2 Commitment for Disposal [25](#commitment-for-disposal) {#commitment-for-disposal-25 .TOC-3}

### 4.7.3 Technical Support [25](#technical-support) {#technical-support-25 .TOC-3}

### 4.7.4 Transportation (Onsite and Offsite) [25](#transportation-onsite-and-offsite) {#transportation-onsite-and-offsite-25 .TOC-3}

### 4.7.5 Assurance for Capability/Capacity [26](#assurance-for-capabilitycapacity) {#assurance-for-capabilitycapacity-26 .TOC-3}

### 4.7.6 Oversight of Generators Activity [26](#oversight-of-generators-activity) {#oversight-of-generators-activity-26 .TOC-3}

###  {#section-1 .TOC-3 .unnumbered}

# 4. WASTE ACCEPTANCE CRITERIA FOR CONTACT-HANDLED TRANSURANIC WASTE 

## 4.1 Scope

This section provides guidelines to transuranic generators on the
identification, characterization, packaging, and waste acceptance of
contact-handled transuranic waste (CH-TRU). Mound\'s Radioactive Waste
Management Group uses this waste acceptance criteria prior to handling
and storing CH-TRU waste. In addition, this section provides information
to ease operations when submitting reports to regulators, agencies, and
burial sites.

### 4.1.1 Controlling Regulations

-   DOE 1540.1, \"Material Transportation and Traffic Management\"

-   DOE 1540.2, \"Hazardous Material Packaging for Transportation\"

-   DOE 5480.3, \"Safety Requirements for the Packaging and
    Transportation of Hazardous Materials, Hazardous Substances, and
    Hazardous Waste\"

-   DOE 5700.6C, \"Quality Assurance\"

-   DOE 5820.2A, \"Radioactive Waste Management\"

-   MD-10246, On-Site Transportation of Hazardous Materials

-   MD-70205, TRU Waste Management

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-   TRAMPAC, \"TRUPACT-II Authorized Methods for Payload Control\"

-   TRUCON Document TRUPACT-II Contact Codes

-   TRUPACT-II SARP, \"Safety Analysis Report for the TRUPACT-II
    Shipping\"

-   WIPP/DOE-069, \"Waste Acceptance Criteria for Waste Isolation Pilot
    Plant\"

-   WIPP/DOE 89-025, \"Waste Characterization Program Plan for WIPP
    Experimental Waste\"

-   WIPP/DOE-114, \"TRU Waste Certification Compliance Requirements for
    Acceptance of Newly Generated Contact-Handled Wastes to Be Shipped
    to the Waste Isolation Pilot Plant\"

-   WIPP/DOE-120, \"Quality Assurance\"

-   WIPP/DOE-157, \"Data Package Format for Certified Transuranic Waste
    for the Waste Isolation Pilot Plant\"

-   WIPP WAP, \"Waste Isolation Pilot Plant Waste Analysis Plan\"

-   10 CFR, \"Nuclear Regulatory Commission\"

-   40 CFR, \"Resource Conservation and Recovery Act,\" Parts 261-268

-   49 CFR, \"Transportation,\" Parts 100-177

### 4.1.2 Waste Type Covered by This Criteria

-   Contact-handled Transuranic Waste

-   Transuranic Mixed Waste

### 4.1.3 Waste Type Not Covered by This Criteria

-   Classified Waste

-   High-Level Waste (not generated at Mound)

-   Low-Level Radioactive Waste

-   Mixed Radioactive Waste

-   Non-Radioactive Waste

## 4.2 Generator Waste Certification

### 4.2.1 Liability for Waste Generation/Characterization

4.2.1.1 The TRU (Transuranic) generator must complete and sign a TRU
Waste Input Form, ML-7042B, (Figure A-11) for each package of waste
generated. This form requires a unique package identification number,
package assembly ID number, date of waste package certification, waste
acceptance criteria (WAC) exception number (if applicable), waste
generation site, date of package closure, maximum-surface dose rate in
mrem/h and specific neutron dose rate if \>20 mrem/h, weight (kg),
container type, physical description of waste form, assay information,
radionuclide information, radioactive mixed waste identity and quantity,
weight and volume of organics, measured or calculated thermal power, and
shipment number.

4.2.1.2 The waste must be packaged in accordance with the criteria set
forth in WIPP/DOE-069, \"Waste Acceptance Criteria for Waste Isolation
Pilot Plant.\" Additionally, Health Physics personnel must monitor the
exterior of the sealed package for contamination, to include alpha,
beta, and tritium, and take external radiation readings at contact and
at one meter for both gamma and neutron radiation. These readings and
the serial numbers of the instruments used are then recorded on Form
7042B, and the form is signed by the Health Physics monitor.

### 4.2.2 Assessment

The waste generator is required to establish each of his or her waste
streams. These streams may be from separate processes or may be a
combination of like waste within a given area. The generator must
provide rationale for each waste stream and specify the method of
control that ensures waste streams cannot be mixed. For waste streams
that cannot be sampled because of high radioactivity or impracticality,
the generator shall provide a detailed description of the waste and its
generation process. In addition, the generator\'s waste analysis plan
shall include a rationale for excluding the waste from sampling.
Information about the nature of the waste will then be based on
documented generator knowledge supported by a full characterization of
the waste stream in question as specified in the Quality Assurance
Project Program Plan (QAPPP) to be developed by Waste Management.

### 4.2.3 Characterization

The waste generator is required to perform a chemical and physical
characterization of his or her TRU waste. The characterization along
with the generator\'s knowledge helps Waste Management prepare a Waste
Profile Plan (WPP) describing how applicable Resource Conservation and
Recovery Act (RCRA) requirements are met for each category of TRU waste
present at Mound. Waste Profile Plans include a detailed description of
the waste generation process and applicable inspection and verification
methods used to show compliance with requirements specified in the Waste
Isolation Pilot Plant (WIPP) RCRA Part A and Part B Permit Applications,
as well as the requirements of the no-migration determination published
by the Environmental Protection Agency (EPA).

Approval of WPP by the New Mexico Environment Department (NMED) and the
Waste Acceptance Criteria Certification Committee (WACCC) is required
before shipment to the WIPP. WACCC has the authority to grant or suspend
a TRU-waste generating site\'s authority to certify waste to the WAC.
WACCC judges the thoroughness of plans regarding TRU-waste
certification, use of the TRUPACT-II, and associated quality assurance
(QA). WACCC responsibilities include reviewing, auditing, surveying, and
resolving concerns about issues at all user sites that are ready to
certify and transport any TRU waste to the WIPP. WACCC is responsible
for developing and maintaining the WIPP WAC. WAC for Mound generators
parallels the WIPP acceptance criteria, WIPP/DOE-069.

### 4.2.4 Training

\* Note: The particular type of training and frequency of retraining is
specified in each department\'s training plan.

4.2.4.1 Training for workers is required in varying degrees depending
upon their assigned tasks. A worker in a radiation area where TRU is
generated, stored, handled, or processed requires a general orientation
that addresses waste minimization and controls for waste disposal, and
presents an overview of the waste management program.

4.2.4.2 In addition to the above, any worker who generates,
consolidates, or handles unpackaged waste is required to attend seminars
on hazardous materials recognition, WIPP acceptance criteria, and
procedural requirements.

4.2.4.3 A person signing on Form ML-7042B (see Figure A-11) for a
generator is required to have documented training in hazardous material
recognition and WIPP acceptance criteria, at TRUPACT-II user\'s school,
and in procedures for packaging and preparing documents for TRU packages
and for preparing documents using Form ML-7042B.

### 4.2.5 Sampling and Verification

4.2.5.1 Sampling by the waste generator requires an approved waste
sampling plan for hazardous constituents that is in accordance with the
following: EPA requirements; recognized industry methods and standards;
and procedures for radioactive constituents in DOE Order 5820.2A. The
sampling plan must be approved by WACCC and Mound\'s Waste Certification
Group before the waste is packaged.

4.2.5.2 Verification of sampling data for hazardous constituents is
performed by Mound\'s Analytical Group. Verification for radioactive
constituents is performed by Mound\'s Nuclear Material Measurement
Group.

4.2.5.3 Additionally, the In-Process inspectors in the Waste Compliance
Group follow established sampling plans to verify package contents, and
sign Form ML-7042B.

4.2.5.4 The verification ensures that the waste package and contents are
in compliance with WIPP WAC, 49 CFR, Mound\'s TRAMPAC, TRUPACT-II, the
list of chemical compounds for each contact code in TRUCON, and 40 CFR,
Parts 262.20 through 262.23. The In-Process inspectors will have the
same level of training as the persons signing the generator\'s
verification. In addition, each generator will be required to have an
initial assay performed to verify the dose rate and quantity of
transuranic contamination.

### 4.2.6 Inventory Control

4.2.6.1 All packages of TRU waste must have Form ML-7042B completed and
signed by the generator, Health Physics monitor, and the In-Process
inspector.

4.2.6.2 Each package must have a unique identification number and a
corresponding number assigned to Form ML-7042B before being accepted in
a Radioactive Waste Management staging area. The information on ML-7042B
is entered into the Waste Accountability, Shipping, and Packaging (WASP)
database.

4.2.6.3 Any movement of a waste package onsite after its addition into
the WASP database requires a Drum/Box Transfer tag, Form ML-1234,
(Figure A-3) filled out by Health Physics.

4.2.6.4 As a package is shipped, its unique identification number is
listed on Shipment Load, Form ML-7042K, which lists the shipment number,
date, and DOE/NRC-741 number. Entry of this data alerts the WASP system
to remove packages from inventory and to store all package and shipment
data on historical tapes.

4.2.6.5 Additionally, the WASP system prepares a manifest and other
documents needed for shipment. The information on each package and
shipment is transmitted by modem to the WIPP for loading into their
database. At Mound, all records are kept following guidelines in Systems
Manual 201, Records Management, Retention, and Disposal, and are stored
in Waste Certification files for that period.

### 4.2.7 Active Pursuit of Minimization

Simply stated, waste minimization is a method of pollution prevention
that focuses on reducing the generation and discharge of hazardous waste
at its source to avoid subsequent handling, treatment, and disposal.
Waste minimization is the responsibility of each waste generator. To
support their efforts, Mound has formed a committee of senior managers
from all departments chaired by a Science Fellow. This committee
conducts waste assessments to identify methods to reduce waste.

### 4.2.8 Management of Satellite Accumulation

TRU is not controlled by the less-than-90-day-storage requirement for
hazardous waste. However, before its transfer to Waste Management,
stored TRU waste is the responsibility of the waste generator. Good
housekeeping and safety should be observed in the accumulation areas.
Packages should be protected from weather to prevent rusting or damage.

## 4.3 New Generator Application

### 4.3.1 Management Responsibility

Quality oversight is within respective departments. The Waste
Certification Official is in the Waste Compliance Group of the
Environmental, Safety and Health Department.

4.3.1.1 Waste Generator

4.3.1.1.1 The TRU-waste generator must complete and sign the TRU-Waste
Input Form, ML-7042B, for each TRU package generated. (See Figure A-11.)

4.3.1.1.2 The TRU-waste generator must notify Radioactive Waste
Management of all new waste streams, as well as any changes in the
existing waste streams or process changes.

4.3.1.1.3 The TRU-waste generator is responsible for performing an
initial waste characterization based on knowledge of process and
materials.

4.3.1.1.4 The TRU-waste generator is responsible for inspecting waste
containers and overpacking or transferring the contents of damaged waste
containers in accordance with all applicable WIPP and Radioactive Waste
Management requirements.

4.3.1.1.5 The TRU-waste generator is responsible for marking and
labeling waste containers. Generators of TRU waste are also responsible
for replacing damaged labels on waste containers in accordance with all
WIPP and Radioactive Waste Management requirements.

4.3.1.1.6 The TRU-waste generator is responsible for ensuring that waste
handlers are appropriately trained and qualified to do their jobs in
accordance with all applicable WIPP and Radioactive Waste Management
requirements.

4.3.1.2 Quality Responsibility

The Performance Assurance Department is responsible for providing
oversight functions to both the generators and the Radioactive Waste
Management Group.

4.3.1.3 Waste Management Responsibility

4.3.1.3.1 The Radioactive Waste Management Group is responsible for the
Radioactive Waste Management Program at Mound and is the focal point for
contact with the WIPP for ultimate disposal of transuranic wastes.

4.3.1.3.2 The Radioactive Waste Management Group is responsible for
keeping waste generators up-to-date concerning regulatory and WIPP
regulations.

4.3.1.3.3 The Radioactive Waste Management Group is responsible for
maintaining operating records, waste profile sheets, analytical data,
waste characterization data, and shipping manifests for the operational
period of WIPP, in accordance with Systems Manual 201, Records
Management, Retention, and Disposal.

### 4.3.2 Description of Waste

The waste generator is required to provide a description of the waste
stream and the controls necessary to ensure that only the waste
described is present in the waste stream. Information obtained in the
sampling, verification, and waste characterizations can be used for the
description. The description should also define the process or areas of
generation and the waste stream number.

### 4.3.3 Generation Rate

The generator must provide a forecast of estimated TRU volumes, waste
type, and number and type of packages. The forecast shall be prepared
for a three-fiscal-year period with the first fiscal year divided into
four three-month increments; that is October through December, January
through March, April through June, and July through September. The
forecast shall be updated every six months and is due September 1 and
March 1. Failure to provide a forecast to Mound\'s Radioactive Waste
Management Group may promptly delay acceptance of waste at staging
areas.

### 4.3.4 Identify Potential Conditions for Change

The waste generator must identify potential conditions that would change
the characterization or waste certification of a TRU-waste stream. Any
change in a TRU-waste stream could decertify that waste stream, and the
waste stream would no longer be accepted by Radioactive Waste
Management. Whenever a significant change occurs to the generating or
treatment process of a waste stream, the generator must notify
Radioactive Waste Management. When the process has changed
significantly, it shall be required that the generator re-evaluate the
Waste Stream Characterization Data Sheet and update it as necessary. The
waste must be recharacterized and certified. In addition, the generator
must refer to the TRUCON document to be in compliance with allowable
chemicals in each contact code.

### 4.3.5 Renewal Requirements

The waste generator must have all waste streams recertified every six
months. This will include results of additional waste characterization
that is performed on a routine basis or because of a change in waste
process. If there have been no changes in the generating or treatment
processes of the waste, then the generator may provide a statement that
the information in the original application is unchanged. This renewal
must accompany the March 1 and September 1 three-year forecasts, or the
waste stream will no longer be accepted by Radioactive Waste Management.
This information is forwarded to the WIPP for additional approval.

### 4.3.6 Application Renewal and Approval Process 

Mound\'s Radioactive Waste Management Group will forward all
applications and renewals to the WIPP Project Office (WPO). Applications
and renewals require the waste stream identification number, Waste
Stream Characterization Data Sheet, assay information, and an updated
three-year forecast. After reviewing all data, Radioactive Waste
Management personnel prepare an application, including the waste stream
information, and send it to the WPO. After review by the WPO, any
unanswered comments will need to be answered, and an audit may be
scheduled if the WPO so requires.

### 4.3.7 Conditions for Cancellation

Shipping of a waste stream will be halted if there is a question
regarding the adequacy of meeting the WAC. The waste stream will be
re-evaluated, and if it meets WAC, shipping will be resumed. If the
waste stream does not meet WAC, the generator will be notified.

### 4.3.8 Restrictions or Procurement

Although currently Mound does not generate a large amount of TRU waste,
excessive generation in the future may be unacceptable to Radioactive
Waste Management because of budget constraints. At the present time,
Mound has 104 drums and 70 boxes of TRU waste. Because Mound cannot ship
this waste to the WIPP facility until 1998, any TRU waste generated has
a long-term adverse effect on available storage space.

## 4.4 Waste Transfer

### 4.4.1 Notification

Before moving TRU waste to a Radioactive Waste Management staging area,
contact Radioactive Waste Management and establish a time and date for
the movement.

### 4.4.2 Manifest

A Drum/Box Transfer Form, ML-7042F, (Figure A-8) must accompany all
packages of TRU waste transferred to a Radioactive Waste Management
staging area. List all packages being transferred, on Form ML 7042F.

### 4.4.3 Storage

4.4.3.1 Radioactive Waste Management maintains Buildings 23 and 31 as
the TRU storage areas. These buildings will be monitored daily for alpha
contamination. Health Physics does routine swipe surveys and external
radiation surveys. The buildings have sprinkler systems for protection
against fire. These buildings will also be alarmed and monitored by
Security to control unauthorized entry.

4.4.3.2 Presently Building 31 is used for preshipment staging of
Decommissioning and Decontamination (D&D) TRU soils. These wastes will
be repackaged into standard waste boxes when the WIPP mobile assay unit
becomes available. This building is a D&D warehouse and is under their
control. Only packages that have been certified by a packaging certifier
will shipped from Building 31. Building 23 is currently used for storage
of TRU-combustibles, TRU-noncombustibles, and TRU-corrosives.

### 4.4.4 Response Time

Under normal operation, Radioactive Waste Management will accept
approved waste streams for storage or shipment as soon as the shipment
schedule permits.

### 4.4.5 Containers

Radioactive Waste Management will accept only approved containers in the
staging area. These containers must comply with 49 CFR and WIPP
requirements. These containers must be procured and inspected following
Waste Compliance Group guidelines. Before using a container, the waste
generator must inspect the container and document the inspection on Form
ML-7042B. If a container is not acceptable, it should be tagged and
segregated from approved containers, and a Discrepancy Evaluation
Corrective Action Report (DECAR), Form ML-8654A, shall be issued. When
the DECAR is processed, a determination will be made to scrap, repair,
or use the container as is.

### 4.4.6 Marking and Identification

4.4.6.1 In addition to Department of Transportation (DOT) labeling
requirements, each waste package shall be uniquely identified with a
label permanently attached in a conspicuous location. The package
identification number shall be barcoded with code 39 bar code symbols,
per MIL-STD-1189, with characters at least 1 in. high. Alphanumeric
characters shall be at least 0.5 in. high.

4.4.6.2 The identification number must also be placed on the Form 7042B
by the generator of the package. A drum and box from an area with scales
must also have its weight marked on the package. A drum or box that does
not have its weight marked on it must be accompanied by the original
copy of Form ML-7042B so that the weight can be entered by Radioactive
Waste Management personnel. In addition to the operations and safety
criteria, each waste package shall be marked with the shipping category
after verification of all payload parameters.

### 4.4.7 Packaging

4.4.7.1 The waste generator shall have procedures to ensure proper
selection of approved containers, to ensure preuse inspection, and to
define the method of loading. The selection of approved containers
ensures that only those containers approved for the waste stream are
used. The preuse inspection ensures that the container is in proper
condition prior to use. The method of loading addresses how the TRU
waste is loaded into the package. This procedure should address the
method of covering sharp edges, loading and shoring of heavy objects, or
any condition that would damage the package during the handling and
shipment.

4.4.7.2 All TRU waste must be packaged as Type B waste. All TRU waste
being shipped to the WIPP must be packaged in a TRUPACT-II (TRANSURANIC
Packaging Transporter). The TRUPACT-II Type B shipping container is
fully licensed with the Nuclear Regulatory Commission (NRC) and follows
guidelines set forth in 10 CFR, Part 71. In addition, all drums and
boxes must be sealed with Tamper Indicating Devices (TID).

### 4.4.8 Conditions of Non-Acceptance

-   Package without completed and signed Form ML-7042B

-   Package not listed on Form ML-7042F

-   Damaged package

-   Weathered or rusty package

-   Package with missing or broken TID

-   Package without legible, unique identification

-   Package without weight marked on package

-   Package without proper assay information

-   Package delivered without prior notification

## 4.5 Waste Acceptance Criteria 

Radioactive Waste Managemet\'s transuranic WAC is a reiteration of
\"Waste Acceptance Criteria for Waste Isolation Pilot Plant,\"
WIPP-DOE-069. The WIPP-DOE-069 criteria addressed in this document is
dated June 1991, and any subsequent revision must be used as the Mound
TRU acceptance criteria. As these revisions in their final form are
received, they will be forwarded to the waste generators for their
immediate implementation, while Mound\'s acceptance criteria is updated.

### 4.5.1 Quantities and Concentrations

Radioactive Waste Management will accept TRU waste that meets the
following criteria, for shipment to the Waste Isolation Pilot Plant:

-   All radioactive waste not classified as high-level waste, spent
    nuclear fuel, uranium mill tailing, mixed waste, low-level waste,
    and classified waste.

-   Radioactive waste that contains TRU radionuclides equal to or in
    excess of 100 nanocuries per gram (nCi/g).

-   Transuranic wastes that meet chemical requirements of TRUPACT-II and
    the list of chemical compounds for each content code in the TRUCON
    document.

### 4.5.2 Criticality

4.5.2.1 The fissile or fissionable radionuclide content of CH-TRU waste
packages shall be no greater than the following values of Pu-239 fissile
gram equivalents (FGE):

-   200 g/55 gal drum

-   325 g/standard waste box

-   325 g/TRUPACT-II

4.5.2.2 The Pu-239 FGE shall be calculated using the methods detailed in
the Appendix of the TRUPACT-II SARP. An operating limit of 1000 FGE of
Pu-239 for each waste package has been established. Waste acceptance
criteria such as criticality and thermal power generally limit the
activity in a waste container to significantly less than 1000 Pu-239
FGE.

### 4.5.3 Classification

Radioactive Waste Management does not have a classified TRU staging
area. Currently the WIPP does not have provisions for storage of any
classified waste. If the need arises to generate such a waste stream,
contact Radioactive Waste Management before generating the waste stream.
Provisions will need to be made to declassify such a waste stream before
acceptance by Radioactive Waste Management.

### 4.5.4 Thermal Power

Individual CH-TRU waste packages in which the average thermal power
density exceeds 0.1 W/ft3 (3.5 W/m3) shall have the thermal power
recorded on all data packages. The maximum allowable wattage per
TRUPACT-II (14 drums) is 40 W. Refer to TRUCON documents for maximum
allowable wattage for each content code.

### 4.5.5 TRU Mixed Wastes

TRU wastes shall contain no hazardous wastes unless they exist as
co-contaminants with Transuranics. Waste packages containing hazardous
waste shall be identified with the appropriate DOT label.
TRU-contaminated, corrosive, reactive, and ignitable materials shall be
neutralized and rendered nonhazardous. Hazardous materials to be
repacked are listed in 40 CFR, Part 261, Subparts C and D. In addition,
each hazardous waste must be assigned one or more of the applicable EPA
hazardous waste codes.

### 4.5.6 Pyrophoric Materials

Pyrophoric materials, other than radionuclides, shall be rendered
chemically safe by processing before being placed in the waste
container. Less than 1% by weight of the waste in each waste container
may be pyrophoric forms of radionuclides, and these shall be dispersed
homogeneously throughout the waste matrix.

### 4.5.7 Free Liquids

Liquid waste will not be emplaced at the WIPP. TRU waste for emplacement
at WIPP shall contain as little residual liquid as is reasonable
achievable. All internal containers (e.g., bottles, cans, etc.) must be
well drained but may contain residual liquids. Residual liquids are
defined here as liquids in quantities of less than 1 vol % of the waste
container and that result from liquid residues remaining in well-drained
internal containers; from condensation of moisture; and from liquid
separation resulting from sludge or resin settling.

### 4.5.8 Explosive and Compressed Gases

TRU waste shall contain no explosives or compressed gases. 49 CFR, Part
173, Subpart C defines explosives and 49 CFR, Part 173, Subpart G,
defines compressed gases. Documented procedures are used to exclude
explosive items, including compounds or combinations of materials that
could form explosive compounds within the waste package. If such
materials are present, they must be treated or diluted in such a way
that a detonation is not possible.

### 4.5.9 Immobilization

Fine particulate wastes shall be immobilized so that the waste package
contains no more than 1 wt % of less-than-10-µm-diameter particles, or
15 wt % of less-than-200-µm-diameter particles with radiative
contamination.

### 4.5.10 Gas Generation

Gas generation and release characteristics of the waste containers shall
be controlled by complying with the following requirements:

-   All waste containers shall be vented with carbon composite filters,
    as described in TRUPACT-II SARP, at a minimum of one filter per drum
    and two filters per standard waste box.

-   Any rigid drum liners used in waste packaging will be either
    filtered or punctured.

-   Any confinement layers used in the waste containers shall be closed
    only by a twist and tape or fold and tape closure. No sealed
    containers greater than one gallon may be present.

-   The maximum number of confinement layers in the waste containers
    shall be know and shall conform to the shipping category description
    in the TRUPACT-II SARP and the TRUPACT-II content codes document.

-   Chemicals and materials present in concentrations greater than 1 wt
    %, shall conform to the allowable chemicals in each waste material
    type, as defined in the TRUPACT-II SARP.

-   The total concentration of potentially flammable volatile organic
    compounds (VOCs) shall be limited to 500 ppm in the headspace of a
    waste package.

### 4.5.11 Waste Containers

Standard Type A 55-gal metal drums, standard waste boxes (SWB) (Figure
A-12), 55-gal drums overpacked in a SWB, or an experimental bin
overpacked in a SWB are authorized for shipment of CH-TRU waste or
TRUPACT-II. The TRUPACT-II (Transuranic Package Transporter) is an NRC
licensed Type B shipping container (Figures A-13). It is designed to
hold either 14 55-gal Type A TRU drums or two SWBs. See Figure A-14 for
an illustration of a loaded trailer.

### 4.5.12 Specific Activity

Documented evidence shall exist to show that the specific activity of a
TRU-waste package is greater than 100 Nci/g of waste. This limit shall
apply to the contents of any single waste package at the time of assay.
The mass of the waste container, including shielding, shall not be used
in calculating specific activity. In addition, this limit does not apply
to dunnage (empty) drums or empty SWBs, for the purpose of filling void
space in the TRUPACT-II. These drums and SWBs shall be empty only; no
low specific activity (LSA) or low-level wastes (LLW) may be used for
filling void space.

### 4.5.13 Waste Package Weight

4.5.13.1 The following weight limits shall apply for waste package
assemblies transported in the TRUPACT-II package:

-   1,000 lb/drum

-   1,450 lb/drum overpacked in a SWB

-   4,000 lb/SWB

-   7,265 lb/TRUPACT-II payload

-   19,250 lb/TRUPACT-II payload, including weight of TRUPACT-II

4.5.13.2 When packaging a TRUPACT-II, the top 7 drums of the 14-pack
must be equal to or less than the weight of the bottom 7 drums. The
heaviest drum of each 7-pack should be in the middle.

### 4.5.14 Surface Dose Rate

Waste packages shall have a maximum total-surface dose rate of 200
mrem/h. If the neutron dose rate exceeds 20 mrem/h for the total waste
package, it shall be reported separately in the data package. The
external total dose rate of the loaded TRUPACT-II on the trailer is
limited to 200 mrem/h at surface and 10 mrem/h at 2 meters. Total dose
rate refers to gamma-neutron contribution. In addition, shielded
containers are allowed for as low as reasonably achievable (ALARA)
purposes only.

### 4.5.15 Removable Surface Contamination

Removable surface contamination on waste packages shall not exceed 50
picocuries (pCi)/100 cm2 for alpha emitting radionuclides and 450
pCi/100 cm2 for beta-gamma emitting radionuclides. Fixation of surface
contamination to meet the above criteria is not permitted. Each operator
is responsible for the measurement of removable surface contamination
for each waste package before shipment. Sampling methods are provided in
49 CFR, Part 173.443; this measurement must be documented.

## 4.6 Responsibility

### 4.6.1 Custodial

TRU waste is the responsibility of the generator until the waste stream
has been approved. When the waste stream is approved and the TRU is
properly packaged and documented, it will be accepted by Radioactive
Waste Management.

### 4.6.2 Excess Generation

Any excess generation in a waste stream that is not forecasted will be
reviewed by Radioactive Waste Management personnel to determine if
funding and manpower are available to store or dispose of the excess
waste. If the waste stream is overbearing or if manpower and funding are
insufficient, it will be refused by Radioactive Waste Management.

### 4.6.3 Funding

4.6.3.1 The waste generator is responsible for costs associated with
containers and packaging materials, waste packaging, labeling, and
sampling of TRU wastes.

4.6.3.2 The Radioactive Waste Management program is responsible for
costs associated with TRU-waste treatment, storage, technical support,
technical capabilities, and equipment.

4.6.3.3 At this present time, it has not been established who will
provide funding for characterization with the mobile assay unit and for
disposal at the WIPP site.

### 4.6.4 Issues Resolution

4.6.4.1 Radioactive Waste Management will negotiate all acceptance
criteria, certifications, and applications with the WIPP Project Office
and with WACCC.

4.6.4.2 The Material Review Board will resolve all DECARS and Materials
Acceptance Report rejections.

4.6.4.3 The Mound Waste Certification Official has final authority for
any waste shipped.

## 4.7 Treatment, Storage, and Disposal (TSD) Requirements

### 4.7.1 Compliant TSD Operations

Based on the latest DOE guidance, Mound TRU waste will most likely be
shipped to the WIPP. In this regard, compliance to WIPP/DOE-069, Rev 4,
Draft 6 is recommended.

### 4.7.2 Commitment for Disposal

The TRU-waste generator makes the commitment for disposal.

### 4.7.3 Technical Support

Radioactive Waste Management furnishes the technical support to
interpret regulations, acceptance criteria, and TRU-waste
characterization. Radioactive Waste Management will submit and negotiate
all applicable guidelines and documents to ship to WIPP and negotiate
new waste streams as needed.

### 4.7.4 Transportation (Onsite and Offsite)

4.7.4.1 The onsite movement of TRU is the responsibility of the waste
generator and is to be carried out in accordance with Technical Manual
MD-10246, On-Site Transportation of Hazardous Materials.

4.7.4.2 The offsite movement of waste is the responsibility of the
Traffic Group and will be carried out following DOE Order 5480.3,
\"Safety Requirements for Packaging and Transportation of Hazardous
Materials, Hazardous Substances and Hazardous Waste\" and DOE Order
1540.1, \"Material Transportation and Traffic Management.\"

4.7.4.3 All offsite shipment of TRU waste will be in accordance with
Title 49 CFR, \"Transportation,\" Parts 100 to 177; Mound\'s site
specific TRAMPAC; and WIPP Waste Acceptance Criteria (WIPP-DOE-069).

### 4.7.5 Assurance for Capability/Capacity

4.7.5.1 The waste generator is responsible for ensuring that the waste
containers located in his or her storage areas have not exceeded their
capabilities.

4.7.5.2 The waste generator is responsible for ensuring that the waste
containers located in his or her storage area have not exceeded their
storage capacities.

### 4.7.6 Oversight of Generators Activity

4.7.6.1 All aspects of the TRU program will be in accordance with DOE
Order 5700.6C, \"Quality Assurance,\" with oversight from the
Performance Assurance Department. Mound Waste Management has a waste
certification program per DOE Order 5820.2A to provide assurance that
DOE, EPA, DOT, NMED, WACCC, WIPP waste packaging, transport and
acceptance criteria are met.

4.7.6.2 The purpose of the waste certification program is to ensure
safe, efficient, and effective management of waste received by Mound
Radioactive Waste Management by providing an auditable system for
verifying that the generators are properly identifying, characterizing,
segregating, packaging, and transferring TRU.