TRANSURANIC WASTE SITE CERTIFICATION PROCESS FOR DISPOSAL OF WASTE AT THE WASTE ISOLATION PILOT PLANT
Robert A. Stroud
U.S. Department of Energy
Carlsbad Area Office
Carlsbad, NM
Mark E. Doherty
Advanced Sciences Inc.
Carlsbad, NM
ABSTRACT
The Carlsbad Area Office (CAO) has conducted waste certification audits at three sites for the purpose of granting those sites waste certification authority to dispose of waste at the Waste Isolation Pilot Plant (WIPP). The certification process described in the CAO WIPP Program documents and in the Generator Site Certification Guide was followed to assess each site's readiness to certify waste for transportation to and disposal at WIPP. The experience gained during these audits has resulted in a well-defined process that CAO uses to assess a site's ability to satisfactorily characterize and certify transuranic (TRU) waste. Lessons learned from the process include the following: CAO and the cognizant site officials need to begin weekly communication starting at least eight weeks prior to the audit, all Program documents must be approved and implemented 30 days prior to the audit, and CAO must complete the adequacy review of those documents before the audit.
PROGRAM STATUS
CAO certified the Los Alamos National Laboratory (LANL) in September 1997. The Idaho National Engineering and Environmental Laboratory (INEEL) and the Rocky Flats Environmental Technology Site (RFETS) have both been audited and are expected to be certified in spring 1998. Two mobile vendors and the Nevada Test Site will also be audited this spring. Copies of the audit reports can be requested from Robert Stroud, CAO Waste Certification Manager.
LANL required three audits before CAO could grant certification and transportation authority. Certification authority was limited to retrievably stored debris waste, but will be broadened to newly generated waste and homogeneous waste forms as LANL brings other TRU waste processes into the Program. The areas that required the greatest efforts were use of acceptable knowledge documentation and nondestructive assay. CAO expects these areas will be closely scrutinized by the public and the regulators when waste shipments begin; therefore, the audit team evaluates every aspect of these activities.
INEEL and RFETS had numerous deficiencies to correct after their initial audits. To date, the major effort has been to ensure that the Programmatic requirements as defined in the four CAO requirements documents have adequately flowed down through the site plans and into the site procedures. INEEL and RFETS have revised dozens of documents and procedures in preparation of the follow-up certification audits. CAO has performed the acceptable knowledge portion of the certification audits in advance because of the detail involved with these areas. This allows the cognizant site personnel to be available for the audit team during the larger certification audit.
PATH TO SITE CERTIFICATION
CAO determines site readiness to perform the waste certification and transportation certification activities by reviewing and approving site program documents and performing audits of site implementation of Program requirements. Mobile systems vendors may be used to provide all or part of waste characterization, certification, and packaging activities. They will be approved by CAO to provide these services for the Program. CAO will then certify a site's program, which may include all or part of the available mobile services.
For a TRU-waste site to be granted certification authority (both waste and transportation), the site must first demonstrate how each of the applicable Program requirements will be met. In general, this is accomplished by developing the required site documents and implementing procedures and by training personnel to perform the various waste and transportation certification operations. The required site documents and steps necessary to develop a TRU waste program are detailed in the Generator Site Certification Guide (1).
PREPARING FOR THE AUDIT
CAO has four requirements documents that are issued to the TRU-waste sites. These controlled documents are the Waste Acceptance Criteria for the Waste Isolation Pilot Plant (WAC) (2), Transuranic Waste Characterization Quality Assurance Program Plan (QAPP) (3), Quality Assurance Program Document (QAPD) (4), and TRUPACT-II Authorized Methods for Payload Control (TRAMPAC) (5). These documents contain requirements necessary to prepare TRU waste for disposal in WIPP. Requirements from the CAO documents must flow down to site-specific documents and implementing procedures. Sites are audited against the adequacy of this flowdown.
After a site has developed the necessary Program plans, it must prepare implementing procedures to conduct Program activities. To the extent practical, the site uses existing procedures, making modifications as needed to qualify them for use in the Program. It is important that the operating procedures be implemented at least 30 days prior to the audit so that the site can generate sufficient waste characterization documentation (data packages) for the audit and allow time for the audit team to prepare checklists to the procedures that will be in use at the site.
PRE-AUDIT COMMUNICATIONS
The sites are encouraged to keep CAO informed as they prepare their certification program and as their program matures. This allows CAO to incorporate the site into the CAO schedules and to provide the site with guidance and advice concerning Program requirements. The sites can solicit successful examples of documents or procedures from CAO, can ask CAO to clarify requirements, and can provide CAO with periodic status reports to ensure that their program remains on track for certification. In certain instances, it may be beneficial for the site to host a visit with CAO to familiarize them with the site physical layout and intentions for the waste characterization and certification program. This is also an excellent forum for the site to access CAO's expertise through specific questions concerning any Program area.
The sites may provide draft copies of their program plans to CAO. The draft documents will be reviewed by CAO, who will provide the site with an informal set of comments describing where the documents need additional work prior to approval. Once the site is confident that the documents meet Program requirements, they submit them to CAO for formal review and approval.
Planning for the site certification audit begins once site procedures for waste characterization, certification, and transportation have been developed and implemented. This planning includes defining the scope of the audit and identifying the implementing procedures that define that scope.
CERTIFICATION AUDITS
The audit begins with a CAO evaluation of the adequacy of site plans and procedures. The site will provide all pertinent material to CAO. The audit team will review the materials to ensure that all Program requirements are addressed by the site program. CAO will provide comments on each document to the site, who will address those comments and revise the documents if necessary.
Once CAO has determined that the site plans and procedures are adequate, the tentative site audit date will be made formal. CAO may conduct a scoping visit to the site to address logistical questions and to refine the scope of the audit. CAO will provide the site with copies of the checklists the audit team will be using during the audit. Typically these are forwarded to the site by e-mail about a week in advance of the audit.
AUDIT FINDINGS AND FOLLOW-UP AUDITS
During the course of the audit, the audit team will keep site personnel apprised of concerns as they are identified. The site is encouraged to address as many of these issues as possible during the audit. Those that cannot be adequately addressed during the audit will result in Corrective Action Reports, which require formal responses to provide objective evidence that the issue has been resolved. It is expected that sites will require follow-up audits to completely cover the scope of waste characterization and certification activities. Those areas deemed adequate during previous audits will not be re-visited; however, processes that have been changed or that require Corrective Action Report closure review will be addressed. Once all Corrective Action Reports have been addressed, all areas within the scope of the audit have been evaluated and are satisfactory, and CAO is satisfied that the site program is acceptable, the site will receive certification and transportation authority.
LESSONS LEARNED DURING PREVIOUS AUDITS
One of the main lessons learned as a result of the initial certification audits was that early contact with CAO can help a site avoid expending time and effort on issues or in a direction not acceptable to CAO. It is best for a site to keep CAO informed of the status of the program as it is being developed. It is much easier for the site to craft a program that will be satisfactory to CAO based on discussions with CAO than to defend or rationalize a program after it has been established. CAO began communications with Hanford and the Savannah River Site about a year in advance of the initial audit.
CAO has attempted to expedite document review cycles through the use of informal comment submittal directly to the document author prior to formal submission of those documents to CAO. This will minimize the time required for the various iterations of the review cycle by allowing the author to make corrections without the time-consuming correspondence required to get comments from the reviewers, through CAO, to the site DOE field element, to the site managing contractor, to the author, and finally to reverse the process to get the author's responses back to the reviewers. A review by technical and quality assurance personnel prior to formal submittal will allow the site to provide a document to CAO for formal review that will produce minimal comments to address. In practice, these comments generally are major issues that needed policy decisions from CAO or site management.
Of all the pre-audit activities conducted by CAO, the adequacy review is the most labor intensive. Each site procedure is reviewed to determine if all of the CAO requirements have been addressed. The number of adequacy comments to address can be expected to number in the thousands if a site is not rigorous about procedure preparation. Past experience has shown that sites that do not include the operations level in preparation of the Program plans or become familiar with the CAO requirements documents will probably not produce procedures that include the necessary requirements.
Sites can use existing procedures to meet Program requirements if those procedures meet all of the CAO requirements, both technical and programmatic. A typical weakness found during audits has been that a site has most of the necessary procedures in place as site-wide quality assurance direction, and that they offer these procedures for the TRU-waste program. In most cases they do not meet specific Program requirements. All quality-affecting activities will be closely scrutinized to ensure that Program requirements will be met and documented. It can be beneficial for a site to take existing site-wide procedures and revise them for use in the TRU-waste program. This is especially true if a revision to a site-wide procedure would present problems or be an unnecessary burden on the rest of the site.
For a site's ability to perform Program activities to be effectively audited, the site must have performed some work for the audit team to review. CAO requires the site to implement Program activities 30 days prior to the audit. It is expected that the site will have accumulated sufficient characterization and certification documentation for the audit team to assess. If sufficient Program activities have not been performed, there will be nothing for the audit team to evaluate; therefore, CAO will not schedule an audit until it is clear that the site program will have been implemented.
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