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)
The receipt and inspection of all incoming low ievel waste shipments shall be performed in accordance
with OP-1.2.2.
Final acceptance review of the waste manifest information shall be performed in accordance with OP-1.
1.2 and as supplemented by this procedure if SNM is present in the waste.
A Special Nuclear Material Exemption Certification form (Attachment 1 from this procedure) must be
attached to each waste manifest. Upon receipt of the waste, perform the same review and verification of
the Special Nuclear Material Exemption Certification form against each waste manifest using the
guidelines for only Condition 1 and 2 of the above pre-acceptance review, unless an alternative sampling
plan was approved at the pre-acceptance stage, then a full review is required.
WCS Verification Sampling
After arrival at the site, WCS will perform verification sampling of all waste containing SNM at the
following frequency:
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 WCS shall obtain one sample for every 1,500
kg (3,300 Ibs) of waste for the first shipment and one sample for every 4,500 kg (9,900 Ibs) of
waste for each shipment after the first.
- The average concentration is between one-tenth and one-hundredth of the limit in Condition 1:
WCS shall obtain one sample for every 20,000 kg +,000 Ibs) of waste for the first shipment and one sample for every 45,000 kg (99,000 Ibs) of waste for each shipment after the first.
- The average concentration is less than one-hundredth of the limit in Condition 1: WCS shall
obtain one sample for every 450,000 kg (990,000 Ibs) of waste.
- If Condition 2.b. has not been verified (the distribution of SNM is not homogeneous): One
sample for every 1,500 kg (3,300 Ibs) of waste for the nrst shipment and one sample for every
4,500 kg (9,900 Ibs) of waste for each shipment after the first will be required unless it has been
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.
Acceptance sampling of the waste by WCS shall be performed in general accordance with OP-1.2.4.
Sample handling, chain of custody, and quality assurance shall be performed in accordance with RS-3.1.6.
The minimum detectable activity (MDA) at the 95 % confidence level and the 1 sigma relative error
uncertainty for the various SNM radionuclides shall be as follows:
| Radionuclide | MDL (pCi/gm) | Uncertainty* |
| U-235 | 5.0 | 15% |
| U-233 | 100 | 15% |
| Pu-239 | 100 | 15% |
| Pu-241 | 400 | 15% |
*Measurement uncertainty applies when there is activity at least 5 times the detection level. The
uncertainty for measurements near the detection level will be greater and likely will not be withing 15%.
Analysis will be performed by a certified laboratory using industry accepted methods.
If the result of the verification sampling for the SNM radionuclides is greater/ less than three times the
manifest values, the customer will be contacted to resolve the discrepancy in results. For low activity
waste (near the MDL), the verification sampling results may be up to a factor of ten different than the
manifest values.
Approval
Waste Acceptance Specialist ________
Approval ________
Radiation Safety Officer