Enclosure 1

Characterization Summary for AMWTP Container Number BN10161094 
2

 

Characterization Summary for 

AMWTP Container Number 

BN10161094 
Characterization Summary for AMWTP Container 

Number BN10161094 

TABLE OF CONTENTS 

1.0 Waste Identification and Segregation........................................................................ 2

2.0 Radiological Content ................................................................................................. 3

3.0 Waste Material Parameters ....................................................................................... 6

4.0 Headspace Gas......................................................................................................... 6

5.0 Ignitable, Corrosive and Reactive Waste................................................................... 7

5.1 Ignitability ............................................................................................................ 7

5.2 Corrosivity ........................................................................................................... 8

5.3 Reactivity ............................................................................................................ 8

6.0 Prohibited Items......................................................................................................... 9

7.0 Waste Compatibility and Characterization............................................................... 10

Attachment 1 – RTR Measurement Control Report............................................................ 11

 
Characterization Summary for AMWTP Container 

Number BN10161094 

2

1.0 Waste Identification and Segregation 

The Central Characterization Project (CCP) Acceptable Knowledge (AK) 

Summary Report for Rocky Flats Combustibles and Plastic Stored at the Idaho 

National Laboratory (INL), CCP-AK-INL-004, Central Characterization Project 

Acceptable Knowledge Summary Report for Rocky Flats Combustibles and 

Plastic Stored at the Idaho National Laboratory, was created to characterize 

waste from Rocky Flats which includes legacy drum BN10161094 (historical 

Rocky Flats drum number RF000107529). Waste characterized under that 

report, including BN10161094, is assigned to waste stream ID-RF-S5300-A. As 

described in Section 4.5 of CCP-AK-INL-004, when waste was initially packaged 

at Rocky Flats, it was segregated by the type of waste matrix and identified by an 

item description code (IDC). Once a drum was full, a prefix and serial number 

were assigned by nuclear material accountability personnel. 

IDCs are a series of three-digit numbers used to identify nuclear material forms 

or process materials. IDC 336, wet combustibles, is assigned to drum 

BN10161094. Drum BN10161094 was originally packaged on November 10, 

1972. Section 5.4.1 of CCP-AK-INL-004 describes IDC 336 as combustibles 

such as cloth, paper, and wood wastes, sorted from dry combustibles (IDC 330) 

based on the criteria that wet combustibles contained a discernable amount of 

moisture within the matrix. Combustible waste items may include wipes, towels, 

rags, tape, protective clothing (e.g., gloves, coveralls, booties), filter paper, wood 

filter frames, cotton swabs, cardboard, sandpaper, labels, tissue paper, and 

gasket material (References P001, P004, P008, P015, P024, P032, P052, P063, 

U512). 

The drum prefix corresponds to a material balance account (MBA) used to 

control the transfer of nuclear material. The MBA can be correlated to an area 

within a particular building. The prefix is identified by the middle part of the 

container number (i.e., 0001 is the prefix for drum number RF000107529). The 

last five digits of the drum number are the serial numbers that indicate the 

sequence in which drums were packaged within a given prefix. Prefix 0001 

corresponds to MBA 1371-31, aqueous plutonium recovery operations in Building 

771. As described in Section 4.3 of CCP-AK-INL-004, Building 771 recovery 

operations used acid to dissolve solid materials containing plutonium. The 

resulting solutions were processed by a series of ion exchange, precipitation, 

calcination, fluorination, and reduction operations to produce purified plutonium 

metal to be recycled back into production operations. Combustible materials 

were typically generated from glovebox housekeeping and maintenance 

associated with these operations (References C170, C184, P024, P053, P061, 

P067, P090, P163, P502, P505, U059, U069, U097). 
Characterization Summar

Number BN10161094 

y for AMWTP Container 

3

2.0 Radiological Content 

 

As described in Section 5.4.2 of CCP-AK-INL-004, the primary radionuclides 

processed at the Rocky Flats Plant included weapons-grade plutonium (Pu), 

americium (Am)-241, enriched uranium, and depleted uranium. The approximate 

isotopic compositions of these materials are presented in Table 5-2 of CCP-AKINL-004 and provided in Table 2-1 below. Historical waste evaluations and 

packaging procedures indicate waste was counted to determine Pu content prior 

to shipment off site. The Transuranic Waste Management Information System 

(TWMIS) database, compiled from shipping records for waste containers shipped 

to INL, identifies no Pu or Am-241 in container BN1016094 and reports the 

values for both as zero. The detection limit for the counter used by Rocky Flats 

had a lower detection limit of 0.7 grams of weapons grade plutonium. Table 2-2 

is a printout of the portion of the TWMIS database containing the drums in 

shipment 72247B from Rocky Flats to INL in 1972. The database shows that the 

reported quantities of Pu and Am-241 were less than the detectable limits; 

therefore, less than 0.7 grams of weapons grade materials are present in the 

drum (References C039, C130, P069, P152, P161, P166, P169, P210, P227, 

U064, U512). 

Table 2-1. Isotopic Compositions of Rocky Flats Plutonium and Uranium 

Weapons-Grade Plutonium Enriched Uranium Depleted Uranium

Plutonium-238 0.01 – 

0.05% 

Uranium-234 0.1 – 

1.02% Uranium-234 0.0006% 

Plutonium-239 92.8 – 

94.4% Uranium-235 90 – 94% Uranium-235 0.2 – 0.3% 

Plutonium-240 4.85 – 6.5% Uranium-236 0.4 – 

0.5% 

Uranium-238 99.7 – 

99.8% 

Plutonium-241* 0.3 – 1.0% Uranium-238 5.3 – 

5.5% 

Plutonium-242 0.005 – 

0.60% 

* includes Am-241 daughter product 
y for AMWTP Container 

BN10161094 

Table 2-2 TWMIS Database Shipment 72247B 

CONTAINER_ID 

CNTR_ 

NUM 

CNTR_ 

TYPE IDC 

PACK_ 

DATE 

PRIMARY_ 

NUCLIDE 

PRIMARY_ 

QUANTITY 

SECONDARY

_ 

NUCLIDE 

SECONDARY

_ 

QUANTITY 

SHIP_ 

NUMBER 

RF000107410 000107410 A 336 11/4/1972 Pu 0.00 Am-241 0 72247B RF000107413 000107413 A 336 11/4/1972 Pu 0.00 Am-241 0 72247B RF000107415 000107415 A 336 11/4/1972 Pu 0.00 Am-241 0 72247B RF000107418 000107418 A 336 11/4/1972 Pu 0.00 Am-241 0 72247B RF000107423 000107423 A 336 11/4/1972 Pu 0.00 Am-241 0 72247B RF000107424 000107424 A 336 11/4/1972 Pu 2.00 Am-241 0 72247B RF000107425 000107425 A 336 11/5/1972 Pu 0.00 Am-241 0 72247B RF000107429 000107429 A 336 11/5/1972 Pu 0.00 Am-241 0 72247B RF000107430 000107430 A 336 11/5/1972 Pu 0.00 Am-241 0 72247B RF000107431 000107431 A 336 11/5/1972 Pu 0.00 Am-241 0 72247B RF000107432 000107432 A 336 11/5/1972 Pu 0.00 Am-241 0 72247B RF000107433 000107433 A 336 11/5/1972 Pu 2.00 Am-241 0 72247B RF000107529 000107529 A 336 11/10/1972 Pu 0.00 Am-241 0 72247B RF000107530 000107530 A 336 11/10/1972 Pu 0.00 Am-241 0 72247B RF000107531 000107531 A 336 11/10/1972 Pu 0.00 Am-241 0 72247B RF000107626 000107626 A 336 11/15/1972 Pu 0.00 Am-241 0 72247B 

Characterization SummarNumber 
5

CCP has analyzed the results of certified nondestructive assays (NDA) 

performed on 136 drums of Rocky Flats waste generated and packaged during 

the same time frame as BN10161094. These drums were generated from the 

same processes that produced the subject drum as is evidenced by the historical 

identification number prefix of RF0001. These results are summarized in Table 

2-3 below. 

 Table 2-3 Summary of CCP Certified NDA for 136 RF0001 IDC-336 Drums 

 Generated Between 1972 and 1973

Range 

Radionuclide/Calculation Average Low High 

AM-241 (g) 1.11E-04 0.00E+00 2.64E-03

CS-137 (g) 6.07E-12 0.00E+00 2.95E-10

NP-237 (g) 1.60E-05 0.00E+00 2.61E-04

PU-238 (g) 6.45E-06 0.00E+00 2.13E-04

PU-239 (g) 5.21E-02 0.00E+00 1.46E+00

PU-240 (g) 3.09E-03 0.00E+00 9.33E-02

PU-241 (g) 4.77E-05 0.00E+00 1.25E-03

PU-242 (g) 1.54E-05 0.00E+00 4.12E-04

RA-226 (g) 1.53E-09 0.00E+00 1.65E-07

SR-90 (g) 4.25E-12 0.00E+00 2.06E-10

U-232 (g) 4.48E-12 0.00E+00 6.09E-10

U-233 (g) 0.00E+00 0.00E+00 0.00E+00

U-234 (g) 0.00E+00 0.00E+00 0.00E+00

U-235 (g) 0.00E+00 0.00E+00 0.00E+00

U-238 (g) 0.00E+00 0.00E+00 0.00E+00

Plutonium Equivalent Curies (Ci) 4.57E-03 0.00E+00 1.28E-01

Plutonium Fissile Gram Equivalents (g) 5.23E-02 0.00E+00 1.47E+00

g = grams 

 Ci = Curies 

Based on these results and the historical data from the TWMIS database (see 

Table 2-2) it is reasonable to conclude that the radionuclide content in drum 

BN10161094 does not pose any unacceptable risk for disposal at WIPP. In fact, 

based on the results of assays from drums of this type and from the Rocky Flats 

data on this drum it would be reasonable to conclude that drum BN10161094 

contains less than the 0.7 grams of weapons grade Pu as indicated by the 

TWMIS data. Based on this and a review of the historical NDA data on similar 

containers the container will be assigned a calculated value of weapons grade 

Pu based on the Rocky Flats assay showing less than 0.7 grams of Pu. The 

weapons grade Pu mass fractions used for this calculation are provided in the 

NDA Memorandum for waste stream ID-RF-S5300-A. 
6

3.0 Waste Material Parameters 

Drum BN10161094 was subject to a Real-Time Radiography (RTR) fast scan per 

CCP procedure CCP-TP-066, CCP Radiography Screening Procedure for 

Prohibited Items. The purpose of this procedure is to identify all prohibited items 

within the waste container but it is not intended to satisfy the Waste Analysis 

Plan (WAP) requirements for identifying waste material parameters within the 

container. From the process description it is known that the drum contains a 

debris waste known as wet combustibles. The AK information which supports 

this is presented above in Section 1.0, Waste Identification and Segregation. In 

addition, CCP has performed a certified RTR scan on 117 drums that were 

generated by Rocky Flats during the same time frame, have the same IDC, and 

were from the same process as is evidenced by the drum prefix of RF0001. The 

average results for these drums are presented in Table 3-1. 

However, for drum BN10161094 the entire contents, or 35.24 Kg will be reported 

as plastic in WWIS. When compared to the summary data derived from other 

drums from the same process it is apparent that this assignment is conservative 

with regard to the amount of cellulosics, plastics, and rubber (CPR) in this waste 

stream. Reporting in this manner is also conservative with regard to the CPR 

allowed in the repository, as detailed in Table 4-11 of the Compliance 

Recertification Application. 

 Table 3-1 Average Volume % Waste Material Parameters for 

 117 RF0001 IDC 336 Containers 

Waste Material Parameter 

Average 

Volume % 

Cellulosics Volume % 55.97%

Plastics Volume % 37.58%

Rubber Volume % 3.15%

Organic Matrix Volume % 0.00%

Inorganic Matrix Volume % 0.00%

Iron-based Metals Volume % 0.49%

Al-based Metals Volume % 0.07%

Other Metals Volume % 0.05%

Other Inorganics Volume % 2.69%

Total Volume 100.00%

4.0 Headspace Gas 

Container number BN10161094 is included in ID-RF-S5300-A Random Selection 

Lot 2 but was not selected for headspace gas sampling since its associated 

position in the random selection order was number 11,730. This container has 

met the WAP requirements regarding headspace gas sampling and analysis. 
7

5.0 Ignitable, Corrosive and Reactive Waste 

5.1 Ignitability 

The materials in BN10161094 do not meet the definition of ignitability as 

defined in 40 CFR 261.21. According to Rocky Flats packaging 

procedures, absorbents (e.g., Oil-Dri or Portland cement) were added to 

wastes having the potential of generating residual liquids (i.e., wet 

combustibles or plastic bottles containing liquid). Residual liquids have 

been identified in drums of combustibles and plastic (IDCs 330, 336, and 

337) from Rocky Flats; however, analysis of the liquids did not identify the 

presence of ignitable liquids. The analyses of these liquids also 

determined that water-based solutions were the most common liquids 

present. The materials in this drum are not compressed gases. The 

materials are not capable of causing fire through friction or absorption of 

moisture. In addition, a review of historical AK indicates that ignitable 

liquids were not used during Building 771 aqueous Pu recovery operations 

(References P012, P014, P015, P024, P090, P503, P505). 

Prior to 1974, nitric acid (the most common acid used during recovery 

operations) was not rinsed from combustibles prior to removal from the 

glovebox and therefore wet combustibles (IDC 336) drums generated prior 

to 1974 may be contaminated with minimal amounts of nitrate salts. 

However, nitration of material does not result from casual or incidental 

contact. Further, any potential for self-ignition due to nitrate salt formation 

would have occurred within a relatively short time-frame (i.e., prior to 

shipment to INL); there has been no observed chemical reaction over the 

past 35 or more years. As described below, RTR of drum BN10161094 

identified a 1⁄2-cup of liquid in a glass container and 2 tablespoons of liquid 

in a plastic container. The chemical composition of the liquids was not 

documented, but based on the waste generating operation, the liquid 

could potentially be water, nitric acid or sulfuric acid. Nitric acid was the 

most common acid used in plutonium recovery, but sulfuric acid was also 

used. The conditions needed to produce nitrocellulose, including the 

presence of both concentrated nitric acid and sulfuric acid, were not and 

are not present. Further, had the formation of nitrocellulose occur, ignition 

would be immediate. These acids were used independently of one 

another, and therefore, the liquid in these inner containers is not expected 

to be a nitric/sulfuric acid mixture. Drum BN10161094 is therefore not an 

ignitable waste (D001) (References C076, P024, P239, P282, P283, 

P284, P285, U060, U097). 
8

5.2 Corrosivity 

The materials in BN10161094 are not expected to meet the definition of 

corrosivity as defined in 40 CFR 261.22. According to Rocky Flats 

packaging procedures, absorbents (e.g., Oil-Dri or Portland cement) were 

added to wastes having the potential of generating residual liquids (i.e., 

wet combustibles or plastic bottles containing liquid). Residual liquids 

have been identified in drums of combustibles and plastic (IDCs 330, 336, 

and 337) from Rocky Flats; however, analyses of the liquids indicated pH 

values from 5 to 12, which are not corrosive by definition. The analyses of 

these liquids also indicate that water-based solutions were the most 

common liquids present (References P012, P015, P024, P503, U060). 

As described in Section 6.0, RTR of drum BN10161094 identified a 1⁄2-cup 

of liquid in a glass container and 2 tablespoons of liquid in a plastic 

container. The chemical composition of the liquids was not documented, 

but based on the waste generating operation, the liquid could potentially 

be an acid which was commonly used in plutonium recovery. However, 

acidic liquids used in recovery operations were collected through process 

drain networks and stored in holding tanks in the process areas. These 

tanks were sampled to determine the plutonium content. If liquids were 

below the Economic Discard Limit (EDL), they were transferred to Building 

774 for treatment, otherwise, the liquids went back through the recovery 

process. However, since the liquids in drum BN10161094 are in small 

containers, a more likely scenario is that the liquids are from 

decontamination and housekeeping of the plutonium recovery gloveboxes 

and equipment. Decontamination solutions included soap and water, nitric 

acid, caustic solutions, and KW detergent. KW detergent is a water 

solution containing citric acid, Versene (a trade name for ethylenediamine 

tetraacetic acid), and Igepal (a strong non-toxic detergent or wetting 

agent) (References P024, P053, P061, P068, P090, P163, U097, U512). 

5.3 Reactivity 

The materials in BN10161094 do not meet the definition of reactivity as 

defined in 40 CFR 261.23, and at no time have these materials been 

managed as reactive wastes. The materials are stable and will not 

undergo violent chemical change. The materials will not react violently 

with water, form potentially explosive mixtures with water, or generate 

toxic gases, vapors, or fumes when mixed with water. The materials are 

not capable of detonation or explosive reaction and there is no evidence of 

explosive materials. The materials do not contain sulfide compounds. 

Trace quantities of cyanide from analytical laboratory and electroplating 

operations may be present in the waste stream, but BN10161094 will not 

contain cyanide because this drum originated from aqueous recovery 

operations. The materials were generated in 1972 and since then have 

been packaged, stored, examined, and transported multiple times. During 

this time no documented violent chemical change has been observed in 
9

this or similar drums. Drum BN10161094 is therefore not a reactive waste 

(D003) (References D003, P012, P015, P024, P052, P081, P284, P285, 

P501). 

6.0 Prohibited Items 

Drum BN10161094 was subject to an RTR fast scan per CCP procedure CCPTP-066. The purpose of this procedure is to identify prohibited items within the 

waste container but it is not intended to satisfy the WAP characterization 

requirements. RTR of the materials in BN10161094 identified the presence of 

containerized liquid (1/2 cup of liquid in a glass container and 2 tablespoons of 

liquid in a plastic container). The quantity of liquid identified is less than one 

percent of the 55-gallon container volume and is considered to be non-residual 

liquid because of the amount in the inner container. Additional discussion of this 

liquid is presented above in Sections 5.1 and 5.2. 

The quantity of liquid is only prohibited because it is not a residual liquid 

remaining in a well-drained internal container. As discussed above in Section 

5.2, the containerized liquid is most likely a water-based solution, however, if the 

liquid is corrosive, the current configuration is the safest for human, health, and 

the environment (i.e., the liquid waste would not have the opportunity to corrode 

the drum/standard waste box and enter the environment). In a worst-case 

scenario, if the liquid waste is acidic, and is released from the individual internal 

containers it would not enter the environment. It would most likely not make 

contact with the steel drum because of interaction with the other materials in the 

drum, including absorbent which was typically added when liquids were present. 

This is a very small amount of liquid and most would likely be absorbed by the 

drum contents. Any traces of acid that might reach the drum wall would be 

neutralized by interaction with the iron drum without affecting the standard waste 

box. 

The procedure requires a full scan of the drum and identification of all prohibited 

items. The only prohibited item identified for container BN10161094 was the 

amount of prohibited liquid identified during the scan. The results of this scan are 

provided in Attachment 1. 
10

7.0 Waste Compatibility and Characterization 

The chemical characteristics of each waste stream are documented on the 

individual Waste Stream Profile Form, including the Environmental Protection 

Agency (EPA) hazardous waste numbers (HWNs). Because both the sludge 

waste stream, BNINW216, and the combustible waste stream, ID-RF-S5300-A, 

are approved waste streams, there are no issues regarding the chemical 

compatibility of container BN10161094 with the sludge containers also in the 

standard waste box or the repository. In addition, the EPA HWNs assigned to 

waste stream ID-RF-S5300-A bound those assigned to the waste stream 

BNINW216 sludge. Specifically, waste stream ID-RF-S5300-A includes 

combustible materials generated from the Building 774 aqueous waste treatment 

operations which generated the IDC 002 sludge in waste stream BNINW216. 

These wastes were segregated and packaged separately at the point of 

generation to achieve more accurate drum assay results, not due to any potential 

chemical compatibility issues. Further, the potential sludge content on 

combustibles is the basis for the assignment of EPA HWNs F006, F007, and 

F009 to waste stream RF-ID-S5300-A. The differences in EPA HWNs assigned 

to each waste stream result from differences in characterization approaches 

rather than chemical content. F003 is conservatively assigned to waste stream 

BNINW216 based on the potential presence of acetone, butanol, ethyl benzene, 

ethyl ether, methanol, and xylene used at Rocky Flats as solvents. These 

constituents are also identified as potential contaminants of waste stream ID-RFS5300-A. However, F003-listed solvents are listed solely for ignitability, and this 

waste stream does not exhibit the characteristic of ignitability because the small 

amount of residual liquid is most likely aqueous and is not expected to be a 

solvent. Therefore, EPA HWN F003 is not assigned to waste stream ID-RFS5300-A. EPA HWNs for organic toxicity characteristic 1,2-dichloroethane 

(D028) and 1,1-dichloroethylene (D029) are also conservatively assigned to 

waste stream ID-RF-S5300-A since they are identified as potential contaminates 

on combustibles in the waste stream. However, since solids analysis data for 

waste stream BNINW216 shows these constituents were present in the sludge 

below regulatory levels; these EPA HWNs were not added to the sludge waste 

stream. Headspace gas sampling for both waste streams has indicated that 

there are no additional HWN assignments required beyond what is identified in 

CCP-AK-INL-004. 
Attachment 1 – RTR Measurement Control Report 

11
Attachment 1 – RTR Measurement Control Report (Continued) 

12
Attachment 1 – RTR Measurement Control Report (Continued) 

13
Enclosure 2 

Panel 4, Room 6 Volatile Organic Compounds Impact Evaluation 
Impact Evaluation of Drum BN10161094 on VOC Concentrations in Room 6 of Panel 4 

This Volatile Organic Compound (VOC) data evaluation is being made to aid in determination of 

a path forward in final disposition of the drum BN10161094 that was emplaced in Room 6 of 

Panel 4 on June 27th, 2007. The evaluation compares VOC concentrations in Room 6 of Panel 

4 prior to the emplacement of that waste container, and VOC data collected post emplacement. 

The disposal room VOC monitoring program consists of sampling for VOCs within each room 

containing waste in an active panel. Each individual room has two sampling points, one at the 

exhaust side of the room and the other at the inlet side. The exhaust side sampling location is 

activated upon waste emplacement (RH or CH) within each room. The inlet sampling location is 

activated after the room is full and the ventilation barriers have been installed. 

The Room 6 exhaust sampling location was activated in early 2007 with the initiation of RH 

waste emplacement within the room. The room has remained active since the initiation of waste 

disposal activities. Therefore the inlet sampling location in Room 6 has remained inactive. 

Sampling at the exhaust side is conducted on a bi-weekly basis. 

Drum BN10161094 was disposed of on June 27th, 2007. Since that time two samples have been 

collected: July 5th and July 17th. Of the two samples, results are available for the July 5th

sample. Sample results prior to the disposal of the drum show very low levels of VOCs within 

the room with four of the nine target VOCs having been detected (Toluene, 1,1,1-

trichloroethane, Carbon Tetrachloride, and Methylene Chloride). The remaining five target 

compounds were not detected in any sample prior to the disposal of the drum in question. 

Results received from the first sample after the disposal of the drum indicate the VOC room 

environment has not changed since June 27th, 2007. The results show detection of Toluene, 

1,1,1-trichloroethane, Carbon Tetrachloride, and Methylene Chloride at levels that are lower 

than the maximum detected concentrations for that room. The results also did not yield 

detections for any of the five previously undetected target compounds. 

Drum BN10161094 did not impact the VOC concentrations in room six of panel four. 
Enclosure 3 

AMWTP CAR #28920 Corrective Action Report Containing the Corrective Action Plan 
CORRECTIVE ACTION

 REPORT 

CAR #: 28920

PARENT:

Finding #:

Dumas, Elvin

Source Type: As Found Condition

7/18/2007 2:03:00PM

On 7/16/2007, personnel at the Advanced Mixed Waste Treatment Project (AMWTP) discovered that a 

shipment of Transuranic Waste (TRU) made on June 23, 2007 to the Waste Isolation Pilot Plant (WIPP) had 

contained a drum which was not approved to be shipped. This container was shipped in TRUPACT- II cask 

serial number 190, in shipment IN070356. This condition caused non-compliances with WIPP Program 

requirements. Therefore, this event was categorized as reportable under ORPS.

During a routine inventory of waste stored at the AMWTP, the production planning manager found a drum that 

was recorded as having been shipped to WIPP the previous month. Subsequent investigations showed that the 

drum had been approved to be placed in a Standard Waste Box (SWB) - a type of overpack container - for the 

shipment, but that another drum had been mistakenly put in the SWB. The drum that was recorded as having 

been placed in the SWB had not been certified to WIPP program requirements prior to shipment. The container 

identification number of this drum is 10161094. The container identification number of the drum that should have 

been overpacked in the SWB was 10106194.

A fact finding meeting was held the next day. This revealed that an incorrect drum was retrieved from storage for 

the overpack payload. The operators who retrieved it did not ensure the drum had the proper barcode label (i.e., 

that the barcode scanned and entered into the Waste Tracking System (WTS) matched the WIPP waste 

information system (WWIS) build instruction that had been provided by the Transportation Certification 

Official). This error was further propagated due to the procedure steps for verification that drums being placed 

into an overpack (SWB or Ten Drum Overpack) match the WWIS build instructions from the Transportation 

Certification Official (TCO), are not as clearly delineated as the applicable procedure steps for verification of 

non-overpacked containers.

WIPP Data

Incorrect Drum Shipped to Waste Isolation Pilot Plant

Description of CAR:

Requirement Violated:

Source Type Doc. No. :

Date Opened:

Originator:

Title:

Category:

ORPS No.: EM-ID--BBWI-AMWTF-2007-0013

MP-TRUW-8.1; MP-TRUW-8.2; MP-TRUW-8.3

N/A ORPS Category: 3

ORPS Reportable: Yes

Manager Review By: Manager Review Date:

QA Closed-Cancelled By: QA Closed-Cancelled Date:

Note: QA Closed-Cancelled Signature is based on concurrence between Responsible Manager and Quality Assurance

Elvin Dumas 7/18/2007 3:30:00PM
CORRECTIVE ACTION

 REPORT 

CAR #: 28920

PARENT:

Is Valid:

Significant :

PAAA Applicable:

PAAA Reportable:

PO Number:

Yes Yes Stop Work Order:

Yes

No

Responsible Department: Waste Programs

Operations Group: Operations

WIPP Submittal Req'd?:

QA Mgr Rev Sign By: Elvin Dumas QA Mgr Rev Sign Date: 7/18/2007 5:46:00PM

Yes

Disposition Due Date: 7/20/2007 3:29:00PM

10 CFR 820: 10 CFR 830 Subpart A:

10 CFR 830 Subpart B: 10 CFR 835 Rad Protection:

10 CFR 851Safety/Health:

Yes

No

No

PAAA Regulations

NTS Report Number:

NTS Report Date:

No

Yes

Yes
CORRECTIVE ACTION

 REPORT 

CAR #: 28920

PARENT:

Immediate Actions:

1. Suspended all payload assembly activities involving overpacks. 

2. Suspended all shipments to WIPP.

Immediate Actions for resumption of shipments:

3. Identified all shipments enroute to WIPP, and received at WIPP but not yet emplaced, that contained overpack 

payload containers. Eight shipments were identified containing a total of 21 overpack payloads, with 128 inner 

containers. 

4. Performed a 100% verification of the eight shipments to confirm that all inner containers for all overpack 

payloads certified in the WWIS are accurately identified in the AMWTP Waste Tracking System (WTS) and were 

traceable to each of the overpacks.

5. Evaluated the WTS container movement history and confirmed movement of all 128 containers to WMF-635 

staging location for overpack.

6. All previously assembled overpack payloads remaining at AMWTP will be reverified to confirm that all inner 

containers for all overpack payloads are accurately identified in the AMWTP Waste Tracking System against the 

WWIS approved payload configuration, under the oversight of CBFO designated personnel.

7. Modify INST-OI-21, Payload Assembly and MP-TRUW-8.5, TRU Waste Certification, to incorporate DOE-CBFO 

directed changes.

8. Provide training to Operations, Transportation Certification, and Shipping personnel on INST-OI-21, Payload 

Assembly, MP-TRUW-8.5, Waste Certification, and an overview of TRU Program requirements for certification. 

 

Investigative action:

A formal investigation and root cause analysis has been initiated. Reference RCA-07-005. 

Investigative Action:

Formal Investigation and Root Cause analysis RCA-07-005 was completed and determined that INST-OI-21, Rev. 

26; Payload Assembly does not provide sufficient instructions for Non-Facility Operations personnel to confirm 

containers being loaded into SWBs are the same containers as those identified on the OPCTCD provided by the 

TCO. Furthermore, the procedure does not explicitly require dual verification of overpacked containers by the TCO.

Root Cause:

A5/B2/C08 - Communication LTA, Written Communication LTA, Incomplete/Situation Not Covered

Contributing Cause(s):

Corrective Action 

Plan:

Root Cause Analysis: Yes

Level A Cause Code:

Assigned Actionee: Wale, Doug

Level B Cause Code:

Level C Cause Code:

B2 - Written Communication Content LT

C08 - Incomplete/Situation Not Covered

A5 - Communications LTA Contibuting Cause Level A:

Contibuting Cause Level B:

Contibuting Cause Level C:

Responsible Manager: Raish, Scott

Date Due: 10/16/2007

A5 - Communications LTA

B3 - Written Communication Not Us

C01 - Lack of Written Communicatio

Con OPs Category: Operations Procedures
CORRECTIVE ACTION

 REPORT 

CAR #: 28920

PARENT:

1. Previous assessments have not been performed specifically on the payload assembly process as provided in 

INST-OI-21, Rev. 26; Payload Assembly.

A4/B1/C04 - Management Problem, Management Methods LTA, Management Follow Up/Monitoring of Activities 

did not identify problems

2. Manual entry of containers identified on the OPCTCD into WTS to query for container location results in wrong 

container retrieved from storage.

A3/B1/C01 - Human Performance LTA, Skill Based Error, Check of Work LTA

3. There is no formal process/procedure for development, control, and issue of the Production Planning Payload 

Build Report and subsequent hand-off to Operations.

A5/B3/C01 - Communication LTA, Written Communication Not Used, Lack of Written Communication

Investigative and Remedial Actions:

In addition to the Immediate actions, the following Investigative Actions will be implemented to determine Extent of 

Condition:

1. A physical verification of 55 and 83 gallon containers in storage at WMF-610, WMF-628, WMF-629, WMF-630, 

WMF-631, WMF-632, WMF-633, WMF-634, WMF-635, WMF-636, and WMF-676 will be performed in accordance 

with the AMWTP Drum Physical Inventory Plan, AMWTP-PLN-016 in comparison to the Waste Tracking System 

electronic data to reconcile the inventory balance. 

 a. Physical verification of the inventory in the identified storage modules.

 Actionee: J. Mousseau/Plant Manager

 Completion Date: 7/26/07

 b. A final report will be issued to document the results of the inventory validation and reconciliation of any 

identified anomalies. 

 Actionee: S. Raish/Waste Programs Manager

 Completion Date: 8/3/07

 

2. As a Remedial Action, a Short Term Instruction will be issued to direct movement of containers using only move 

sheets from production planning. 

 Actionee: D. Wale/Operations Manager 

 Completion Date: 7/26/07

Actions to Preclude Recurrence:

(Note that the root cause is addressed in the Immediate Action, Item # 7)

3. Establish waste storage rows for certified containers and implement controls to ensure that containers sent to 

WMF-635 for payload assembly are retrieved only from the established certified container storage rows. 

 Actionee: C. Sisson/Production Planning

 Completion Date: 8/1/07

4. Certified container rows will be roped and clearly marked as such. 

 Actionee: C. Sisson/Production Planning

 Completion Date: 8/1/07

5. All storage rows containing reject containers (i.e. nonconforming) will be roped off, clearly marked as containing 

rejected containers, and containers identified on a row map.

 Actionee: C. Sisson/Production Planning

 Completion Date: 8/1/07
CORRECTIVE ACTION

 REPORT 

CAR #: 28920

PARENT:

6. All storage modules that do not contain certified waste will be posted at the entrances to alert personnel that the 

building does not contained certified drums.

 Actionee: C. Sisson/Production Planning

 Action Completed: 7/24/07

7. Establish a Production Planning procedure to standardize and control the issuance of container move orders. 

 Actionee: R. Hose/Production Planning and Project Integration Manager

 Completion Date: 8/24/07

8. Provide training to Operations personnel on the requirements of INST-OI-11, Waste Container Handling. 

 Actionee: D. Croft/Waste Processing

 Action Completed: 7/19/07

9. Schedule Management Assessments for effectiveness review of changes and corrective actions for 

TRUPACT-II loading, payload assembly, certification, and shipping procedures and processes. These assessments 

will evaluate the corrective actions taken for CAR 28920 to ensure actions taken and procedural controls 

implemented, will effectively prevent recurrence. 

Actionees: J. Mousseau/Plant Manager and S. Raish/Waste Programs Manager

Completion Date: 10/12/07

10. Develop an implementation plan/schedule to transition to CCP Transportation Authorization with concurrence 

from DOE-ID, DOE-ID Contracting Officer and CBFO.

 Actionee: S. Raish/Waste Programs Manager

 Completion Date: 8/10/07

Elvin Dumas

7/25/2007 4:12:00PM

7/25/2007 4:10:00PM

Scott Raish

Scott Raish Mgr Disp App Date: 7/25/2007 2:21:00PM

QA Mgr Rev Disp Sign Date:

Mgr Disp App By:

QA Mgr Rev Disp Sign By:

QA Add'l Disp. Req'd By: QA Add'l Disp. Req'd Date:

Mgr Add'l. Disp App By: Mgr Add'l. Disp App Date:

CAP Complete Comments:

Action Complete By: Action Complete Date:

QA Add'l Action Req'd By: QA Add'l Action Req'd Date:

Add'l Action Complete By: Add'l Action Complete Date:

QA Verification Complete By: QA Verification Comp Date: