Waste Control Specialists LLC
Operations Department
Special Nuclear Material Exemption Certification
Draft A
OP- X.Y.Z

SPECIAL NUCLEAR MATERIAL EXEMPTION CERTIFICATION

1.0 PURPOSE AND SCOPE
This procedure describes the waste acceptance requirements for Special Nuclear Material, SNM. Sampling and documentation requirements for the waste generator and for Waste Control Specialists, WCS, are described. The procedure lists concentration limits for SNM and the sampling frequency required for characterizing the shipments of various concentrations of SNM.

The requirements of this procedure must be satisfied for all SNM received and processed at WCS.

The requirements of this procedure are in addition to the requirements of other WCS procedures for accepting waste.

2.0 EQUIPMENT AND MATERIALS

None

3.0 RESPONSIBILITIES

3.1 The Waste Generator is responsible for completing the SNM Exemption Certification Attachment, and for ensuring that sampling requirements and documentation provide a complete and accurate characterization of the SNM.

3.2 The Waste Acceptance Specialist is responsibl e for the performance of this procedure and ensuring that all the requirements for receipt, sampling and analysis are satisfied prior to processing SNM.

3.3 The Radiation Safety Officer is responsible for review of the SNM Exemption Certification Attachments and the WCS verification sampling and analysis, and the WCS SNM acceptance checklist.

3.4 The Radiation Safety staff is responsible for performing sampling and analysis required by this procedure.

4.0 PROCEDURE

4.1 PREREQUISITES

4.1.1 In addition to this procedure, the following procedures are also applicable for the proper handling and documentation of SNM shipments:

4.1.1.1 OP-1.1.1, "Pre-shipment Authorization"

4.1.1.2 OP-1.1.2, "Shipment Document Review"

4.1.1.3 OP-1.2.1, ~Arriving Vehicle Safety Inspection"

4.1.1.4 OP-1.2.2, "Waste Shipment Acceptance"

4.1.1.5 OP-1.2.4, "Waste Verification Testing"

4.1.1.6 OP-1.2.6, "Waste Shipment Off-loading"

4.1.1.7 RS-3.1.6, "Surveys of Incoming and Outgoing Shipments1"

4.1.1.8 RS-1.4.2, "Sample Receipt, Storage, and Chain-of-Custody"

4.1.2 A completed Waste Profile, Exhibit B of the WCS Service Agreement, is required to be completed by the Waste Generator and comply with all SNM requirements specified in this procedure.

4.2 PRECAUTIONS AND LIMITATIONS

4.2.1 Special Nuclear Material concentration limits specified in this procedure shall not be exceeded.

4.2.2 When more than one SNM radionuclide is present in the mixture, the sum of the ratios of each radionuclide to it's limH shall not exceed 1.

4.3 INSTRUCTIONS

4.3.1 Special Nuclear Material Limits

4.3.1.1 The License Limits for Special Nuclear Material are shown in Table 1 below. The license limits are in units of grams of SNM per grams of waste and are converted to activity concentration limits of (pCilg). Table 1
Maximum Allowable Concentrations of SNM in Individual Waste Containers

Radionuclide1	Maximum Concentration (g SNM/g waste)	Maximum Concentration(pCi/g)	Measurement Uncertainty4
U-2352	9.891 E-4	2.14 E3	15%
U-2353	6.18 E-4	1.34 E3	15%
U-233	4.732 E-4	4.56 E6	15%
Pu-239	2.795 E-4	1.73 E7	15%
Pu-241	2.15 E-4	2.22 E10	15%

¹Isotopes of uranium and isotopes of plutonium that are not listed in this table can be received in any concentration. There is no limiting concentration for the isotopes that are not listed.

²Less than 10 percent enrichment (U-235 mass enrichment)

³Greater than 10 percent enrichment (U-235 mass enrichment)

⁴The measurement uncertainty of 15% applies when the measurement is at least 5 times the MDA listed in Table 2

4.3.2 Waste Generator Sampling Frequency Guidelines

4.3.2.1 The Waste Generator shall submit a sampling plan for characterizing the SNM waste. The plan shall include:

- sampling methods,

- sampling points,

- number of samples,

- analysis methods,

- detection levels,

- data reduction and analysis

- review of the data, and

- increasing the sampling frequency when the data show higher concentrations of SNM than originally assumed or non-homogeneous concentrations.

4.3.2.2 The Waste Generator is expected to follow these sampling frequency guidelines. The guidelines require a higher frequency of samples to be obtained and documented as the concentration of SNM increases.

4.3.2.2.1 Table 2 lists the activity concentrations for each SNM radionuclide. The columns show the concentrations (action levels) that will define the sampling frequency.

Column 1 shows the WCS SNM concentration limit. This value shall not be exceeded.

Column 2 shows one-tenth of the WCS SNM concentration limit

Column 3 shows one-hundredth of the WCS SNM concentration limit.

The MDA, Minimum Detectable Activity (95% confidence level) listed, applies to samples that are low in activity (at or below one-hundredth of the WCS limit). When the sample contains measurabie activity, achieving the MDA is not required...samples should be counted long enough to achieve 15% relative error (1 sigma total analysis uncertainty).

Table 2
Activity Concentration Action Levels

Radionuclide	[1] Limit(pCi/g)	[2] 0.1 Limit(pCi/g)	[3] 0.01 Limit(pCi/g)	MDA (pCi/g)
U-235 <10%	2.138E+03	2.138E+02	2.138E+01	4.0E+00
U-235 >10%	1.336E+03	1.336E+02	1.336E+01	2.5E+00
U-233	4.561 E+06	4.561 E+05	4.561 E+04	1.0E+02
Pu-239	1.733E+07	1.733E+06	1.733E+05	1.0E+02
Pu-241	2.215E+10	2.215E+09	2.215E+08	4.0E+02

4.3.2.2.2 The minimum sampling frequency required by the Waste Generator is shown in Table 3.

Table 3
Waste Generator- Minimum Sampling Frequency

Activity Range (See columns in Table 2)	Minimum Sampling Frequency
Col 2 - Col 1 or when shipment is not homogeneous (min and max samples within a factor of 5 of the mean)	One sample for every 450 kg (990 lbs) of waste
Col 3 -	Col 2 One sample for every 4,500 kg (9,900 lbs) of waste
< Col 3	One sample for every 45,000 kg (99,000 lbs) of waste

4.3.3 SNM Waste Profile Homogeneity of Concentrations

The SNM concentrations will be accepted as homogeneous if the waste profile shows that the maximum and minimum concentrations are within a factor of 5 of the average concentrations.

If the container sample concentration uniformity cannot be demonstrated by process knowledge, then the Waste Generator will perform additional sampling and additional information from the Waste Generator certifying the waste will be required in the sampling plan:

Additional sampling requirements (Waste Generator sample and analysis) when the homogeneity cannot be demonstrated are: One sample for every 450 kg (990 lbs) of waste will be required unless it can be demonstrated by some other means (process knowledge or other sampling) that there is less than 350 grams of U-235 and less than 200 grams of U-233 or Pu in the entire waste stream that will be sent to the site under this waste profile.

Direct sampling is the preferred method of waste characterization. Scaling factors and/or process knowledge may be used as an alternative or supportive method of characterization, however the information must be of sumcient detail and quality to justify its use.

4.3.4 Sample Analysis Methods

The analysis method used to analyze the SNM should be an industry accepted method, and analysis should only be perfommed by a certified lab.

Generally accepted methods of analysis include:

- Gamma Spectroscopy

- Isotopic Uranium (alpha spectroscopy)

- Isotopic Plutonium (alpha spectroscopy)

- Liquid Scintillation Counting by plutonium separation/alpha spec to determine separation yield/ gas proportional counting.

- ICP mass spectroscopy

4.3.5 Waste Generator- Special Nuclear Material Exemption Certification

The Waste Generator shall complete Attachment 1 to this procedure, Special Nuclear Material Exemption Certification, to certify that all requirements for shipment and receipt of SNM to WCS have been met. A completed and signed Attachment 1 shall be attached to the waste profile and the waste manifest.

4.3.6 WCS Review of Special Nuclear Material Exemption Certification and Verification Sampling

WCS will review and approve the SNM exemption certification documentation required in Attachment 1 using the guidelines specified in Attachment 2 for preacceptance of SNM at the WCS facility.

WCS will review and approve the SNM exemption certification documentation required in Attachment 1 using the guidelines specified in Attachment 3 for final acceptance of SNM at the WCS facility. WCS will perform verification sampling of the waste shipments when the waste arrives on site at the frequency described in Attachment 3 to this procedure.

5.0 RECORDS

5.1 Attachment 1, Special Nuclear Material Exemption Certification Special Nuclear Material Waste Acceptance Criteria (to be completed by the Waste Generator)

5.2 Attachment 2, Guidelines for Pre-acceptance Review of Shipments Containing Special Nuclear Material for the Purpose of Meeting the Exemption Under 10 CFR 70. (to be completed by WCS)

5.3 Attachment 3, Guidelines for Final Acceptance Review of Shipments Containing Special Nuclear Material for the Purpose of Meeting the Exemption Under 10 CFR 70. (to be completed by WCS)

6.0 REFERENCES

None