DATA QUALIFICATION FOR THE WASTE ISOLATION PILOT PLANT

R. Dennis Brown US Department of Energy Carlsbad Area Office P.O. Box 3090 Carlsbad, NM 8822 1 (505) 234-7484

ABSTRACT

A process to qualify data acquired prior to the implementation of the quality assurance program required by the regulator is described. The results of the application of this process to a variety of types of data are summarized.

INTRODUCTION

The Waste Isolation Pilot Plant (WIPP) site near Carlsbad, New Mexico, has been the subject of scientific and engineering investigations for more than twenty years. Data from these investigations are now being used as part of the process to certify compliance of the WIPP with the governing regulations. Some of these data were collected prior to the development and implementation of the quality assurance (QA) standarL, that are now being applied in the WIPP compliance certification process, and are considered “existing data” within the current QA program. This paper discusses the process for qualification of existing data (QED) defmed for the WIPP project, the implementation of that process, and some of the results. This process incorporates many lessons learned, and should be useful to others in the radioactive waste management system who are dealing with “existing data.”

t; ,+ iJ 3 2 pgg6 Victor J. Harper-Slaboszewicz

S-T I Sandia National Laboratories 1 15 N. Main Street Carlsbad, NM 88220 (505) 234-0055

WORK DESCRIPTION

The QED process developed for the WIPP project is modeled on the logic of NUREG-1298’, and is described in Sandia National Laboratories (SNL) WIPP QAP 20-3. The major elements of the process are

1) identification of records packages to be qualified;

2) assembly of those packages for review;

3) review of those packages by an independent review team (IRT); and

4) improvement of those packages with identified deficiencies.

The data to be qualified are those data from completed SNL experimental activities that are used as input to the calculations of the long-term performance of the WIPP repository. Data from work in progress are qualified by audit, but this option is unavailable for completed activities. Individual records packages are identified by the associated test plan and data report. In cases where no formal test plan was prepared, the data are grouped as sets of related data collected by a single group during a continuous period. A package may include data collected under more than one contract, if the effort was ongoing. The data are assembled into a format specified in QAP 20-3, which is designed to

allow evaluation of the elements ofNQA-I2. If the data are already in a well-organized records system, a roadmap is assembled with pointers to the relevant records. The Assembly Team then prepares a Statement of Content that describes the contents of the records package, with particular emphasis on the completeness or incompleteness of specific sets of records.

The records package is then reviewed by an IRT managed by a contractor independent of SNL. The IRT selection process ensures reviewer independence and qualification using standards similar to those in NUREG- 12973. Related records packages are grouped and reviewed together. The review considers both QA and technical issues. The review determines whether a QA program equivalent to NQA-12, NQA-24 (Section 2.7), and NQA-35 was implemented to control the collection of the data under review. The review also assesses the technical validity of the data using a process similar to the Peer Review procedure described in NUREG-12973. The IRT concludes the review by preparing a Statement of Condition summarizing their conclusions related to both QA equivalence and technical validity.

The options for improving those packages with identified deficiencies include development of corroborating data, performance of confirmatory testing, conduct of a peer review in accordance with the requirements of NUREG- 12973, and abandonment of the data for use in compliance. The choice of which option to pursue is a management decision made by the Qualification Method Team (QMT).

RESULTS

This process has been used to evaluate numerous packages of existing data resulting from SNL experimental programs that are used as input to the performance assessment calculations being performed by SNL in support of the WIPP compliance certification application. Experience has shown that the process can be applied effectively to a range of activities, ranging in scale from laboratory tests to field test programs involving extensive mining and drilling, and ranging in approach from precision measurements of parameters in detailed multi-mechanism models to empirical measurements of “typical” material properties.

The ability to contact to principal investigator to identify additional sources of records to support the evaluation of the experiments has proven to be important in the QED process. In most cases, the principal investigator could be contacted for support. In those few cases where the principal investigator could not be contacted, the completeness of the data packages was negatively impacted.

The QA evaluations conducted in the QED process tended to show a pattern. The QA programs were found to be acceptable on the Thermal-Structural Interaction Tests at the WIPP site, the rock mechanics experiments at the =/SPEC laboratories, the gas generation measurements at the national laboratories, and the field hydrogeological measurements supported by Intera. These experiments have two characteristics in common. First, they were large-scale programs that extended over several years. Second, they had continuity in the responsible principal investigator over an extended period, of order ten years. Data developed under smaller test programs, or programs with more rapid turnover in the responsible principal investigator, generally fared more poorly.

The technical evaluations conducted in the QED process also tended to show a pattern. Most (approximately 90%) of the data packages were considered to be technically valid by the reviewers. In many cases, however, the reviewers considered it necessary to note that limitations should be applied to the use of the data. These limitations are generally consistent with the intent of the experiments, and are consistent with the planned use of the data in WIPP compliance.

CONCLUSION AND DISCUSSION

A consistent and verifiable process for qualification of data taken subsequent to the implementation of current QA standards has been successfully developed and implemented. The process has been improved continuously based on application to different types of data and on feedback from internal process users and external observers. This QED process may be useful in optimizing the application of existing data in other parts of the radioactive waste management system.

ACKNOWLEDGMENTS

We would like to acknowledge the very substantial contributions to this effort by AI Stevens of SNL, John Thies of Informatics, Leo Scully of LATA, and the large team that implemented this process. This work was supported by the United States Department of Energy under contract DE-AC04-94AL85000.

REFERENCES

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Altman, W.D., J.P. Donnelly, and J.E. Kennedy. 1988. Qualijkation of Existing Data for High-Level Nuclear Waste Repositories. NUREG-1298. Washington, DC: U.S. Nuclear Regulatory Commission.

ASME (American Society of Mechanical Engineers). 1989. ASME NQA-1-1989 Edition Quality Assurance Program Requirements for Nuclear Facilities. ASME NQA- 1-1 989 edition. New York, NY: American Society of Mechanical Engineers.

Altman, W.D., J.P. Donnelly, and J.E. Kennedy. 1 98 8. Peer Review for High-Level Nuclear Wmte Repositories. NUREG-1297. Washington, DC: U.S. Nuclear Regulatory Commission.

ASME (American Society of Mechanical Engineers). 1990. Addenda to ASME NQA-2a-1990 Edition Quality Assurance Requirements for Nuclear Facility Applications. ASME NQA-2a- 1990. New York, NY: American Society of Mechanical Engineers.

ASME (American Society of Mechanical Engineers). 1989. Qualiw Assurance Program Requirements for the Collection of Scientific and Technical Information for Site Characterization of High-Level Nuclear Waste Repositories. ASME NQA-3-1989 edition. New York, NY: American Society of Mechanical Engineers.

DISCLAIMER

This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsi- bility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Refer- ence herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recom- mendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

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