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)

Pre-acceptance review of the waste profile information shall be performed in accordance with OP-1.1. and as supplemented by this procedure when SNM is present in the waste.

A Special Nuclear Material Exemption Certification (Attachment 1 of this procedure) must be attached to the waste profile if any of the radionuclides in condition 1 (of the SNM Exemption Certification) appear on the waste profile.

The Special Nuclear Material Exemption Certification Attachment shall be reviewed and verify as follows:

Condition 1: Verify that at least one box has been checked in Condition 1 and this matches the information on the waste profile.

Condition 2: Verify that all boxes in Condition 2 have been checked.

2.a. The value for the checked radionuclide is less than the maximum indicated limit in Condition 1 and that no other radionuclides listed in Condition 1 appear on the waste profile.

2.b. Based on review of information in Condition 3.c. and the radiological data in the waste profile, verify that the SNM concentration is homogeneous. (Maximum and minimum concentrations within a factor of five times the average.) Additional sampling with documentation in the sampling plan may be required if this condition cannot be verified by process knowledge andlor initial sampling. If not checked or verified see guidelines for condition 3.b. below.

2.c. Verify by review of the waste profile and the infommation in Condition 3.a. that the listed chemicals are not present.

2.d. Verify by review of the waste profile and the information in Condition 3.a. that the listed materials do not exceed 0.1%.

2.e. Verify by review of the waste profile and the information in Condition 3.a. that the waste does do not contain soluble forms of plutonium and uranium greater than the amounts indicated.

Condition 3: Verify that all boxes in Condition 3 have been checked and the required additional information is attached.

3.a. Review the information to verify that it supports the certification provided in condition 2.c., d., and e.

3.b. Verify that the Waste Generator's waste sampling and characterization methodology meets the following guideiines.

If Condition 2.b. has been verified and:

- The average concentration of the SNM radionuclide with the highest concentration is between the limit in Condition 1 and one-tenth of the limit: At least one sample for every 450 kg (990 Ibs) of waste.

- The average concentration is between one-tenth and one-hundredth of the limit in Condition 1: At least one sample for every 4500 kg (9900 Ibs) of waste.

- The average concentration is less than one-hundredth of the limit in Condition 1: At least one sample for every 45000 kg (99000 lbs) of waste.

If Condition 2.b. has not been verified (the distribution of SNM is not homogeneous): One sample for every 450 kg (990 Ibs) of waste will be required unless it can be demonstrated by some other means (process knowledge or 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 provided in 3.d. must be of sufficient detail and quality to justify its use.

If direct sampling is performed and the sample frequency is not otherwise limited by the above weights, the following is the minimum sampling frequency for acceptance at WCS:

- 20-yd³ Rolloffs: A composite sample consisting of two aliquots from different locations in the box.

- Boxes, Drums, and Smaller Containers: A composite sample consisting of one aliquot from each container to achieve the above total weight per sample.

- Debris. Sampling should be performed by taking representative cuttings, borings, or small pieces. If this is not possible, the concentration may be determined by performing surface surveys and converting the survey data to total mass of each SNM radionuclide, and then dividing by the mass of the material.

3.c. Verify that the information submitted is supported by measurements and/ or other data that provides reasonable assurance that the conclusion of uniform distribution is valid. Additional documentation and sampling may be required if this condition cannot be verified by process knowledge and/or initial sampling.

3.d. Verify that the uncertainty in the methods used to obtain the SNM concentrations on the waste profile is within the limits of Condition 1. If other than direct measurements are used, additional statistical or other data should be provided to show that these correlations meet the uncertainty requirements under condition 1.

If proper justification has been given to WCS, a different sampling plan (site characterization data) may be submitted for approval at the pre-acceptance (waste profile) stage. If pre-acceptance approval is given on this basis then the entire package of inforrnation (Condition 1, 2, and 3) must again be submitted at the final acceptance (waste manifest) stage.

Approval
Waste Acceptance Specialist______

Approval
Radiation Safety Officer_______