SUCCESSFUL INTEGRATION OF TECHNICAL AND QUALITY
ASSURANCE PROGRAM ACTIVITIES FOR THE WASTE
ISOLATION PILOT PLANT
R. Dennis Brown and John W. Ptacek
Quality Assurance
Carlsbad Area Office
P. O. Box 3090, MS-564
101 W. Greene Street
Carlsbad, NM 88221-3090
ABSTRACT
A common consideration among quality assurance (QA) professionals is the need for line and technical organizations to accept responsibility for the performance, self-assessment, and continuing improvement of the work they perform. The Waste Isolation Pilot Plant (WIPP) is the U. S. Department of Energy (DOE) underground repository for storage of defense-generated transuranic (TRU) waste. The Carlsbad Area Office (CAO) has successfully employed this approach while managing the facility and the National TRU Waste Management Program. Except for independent assessment activities, the responsibility for implementing the WIPP QA program rests squarely with the line and technical organizations.
The WIPP is a complex and significantly diverse project. This diversity is manifested by the number of regulatory drivers, assigned missions, waste generator locations, and waste characterization needs. Integration of QA and technical program activities can provide significant benefits for multiple-site or multiple-supplier organization of this size and scope. The practices employed by the WIPP program may have good applicability to other large organizations requiring formal QA programs.
The approach used by the WIPP project to integrate QA requirements into the technical activities include: organizing of the CAO to place QA engineers on staff within each of the technical program offices; providing targeted QA support to the lower-tier WIPP participants; developing a standard suite of WIPP program documents that identifies the many QA and technical requirements applicable to the WIPP project; conducting comprehensive assessments that address both QA and technical issues; and employing a corrective action process that requires the involvement of line management in the resolution of conditions adverse to quality. In aggregate, these practices have resulted in increased worker ownership of the QA process, enhanced QA program flexibility, improved sensitivity to both technical and QA issues, and better quality improvement initiatives.
INTRODUCTION
As an underground repository for defense generated transuranic radioactive and hazardous waste, the WIPP project must comply with a wide array of regulatory drivers (see Figure 1). The Environmental Protection Agency (EPA) regulates the certification of the WIPP as a radioactive waste repository under 40 CFR Parts 191 and 194 which set the technical and quality assurance requirements for the repository. The language of 40 CFR Part 194 additionally invokes as regulatory requirements the quality assurance provisions of: American Society of Mechanical Engineers (ASME) Nuclear Quality Assurance (NQA) Standard, NQA-1-1989, Quality Assurance Program Requirements for Nuclear Facilities; ASME NQA-2a-1990 addenda, part 2.7 to ASME NQA-2-1989, Quality Assurance Requirements for Nuclear Facility Applications; and ASME NQA-3-1989, Quality Assurance Program Requirements for the Collection of Scientific and Technical Information for Site Characterization of High-Level Nuclear Waste Repositories. Additional quality assurance requirements are levied by 10 CFR Part 71, 10 CFR Part 830.120, and the Department of Energy (DOE) Order 5700.6C, Quality Assurance.
The State of New Mexico Environment Department (NMED) regulates the permitting of Resource Conservation and Recovery Act (RCRA) waste disposal facilities within the state under Title 20, Chapter 4, of the New Mexico Code, which conveys the requirements of the EPA RCRA regulations contained in 40 CFR Parts 260 to 265. The Nuclear Regulatory Commission (NRC) regulates and certifies the radioactive waste shipping containers under the requirements of 10 CFR Part 71. The Department of Transportation (DOT) regulates the shipment of radioactive waste through 49 CFR Part 173. The environmental impact assessment provisions of the National Environmental Protection Act are also applicable to the project.
Fig. 1. WIPP requirement sources.
By its very nature, the scope of the WIPP project is broad and complex, encompassing such areas as major mining operations, sophisticated computer modeling, regulatory compliance and licensing, environmental monitoring, scientific research and experimentation, hydrogeological data collection, and radioactive and hazardous waste characterization.
The waste characterization processes in particular must be responsive to all the regulatory requirements applicable to WIPP and must also be integrated with the variety of transuranic waste forms derived from the many different processes used in weapons production over the past decades at nearly two dozen TRU waste sites. The TRU waste sites are scattered throughout the continental United States. The types of analysis mandated for TRU waste characterization include container headspace gas analysis, visual examination, real-time-radiography, non-destructive assay, acceptable knowledge, and waste core sampling and analysis for volatile organics, semi-volatile organics, and RCRA metals. It is also important to ensure that the waste characterization requirements are flexible enough to accommodate the many different technologies and analytical approaches that are available and appropriate for these activities.
THE APPROACH TO QUALITY ASSURANCE AT WIPP
Effectively addressing the needs of the WIPP quality assurance program and successfully incorporating these requirements into the many technical project activities is best supported by the direct involvement of the line management and technical organizations. To achieve this, a multi-pronged approach has been employed on the WIPP project that focuses on the delegation of QA responsibilities to the line management and the use of techniques that support the integration of quality assurance requirements into the technical elements. As illustrated in Figure 2, the responsibility for implementing the WIPP QA program rests squarely with the line and technical organizations, except for the independent assessment of activities. The tools and practices used by the WIPP project to integrate QA requirements into the technical activities can be grouped into the categories of organization, documentation, assessment, and corrective action. Each is discussed in detail in the following sections.
ORGANIZATION
The WIPP project is under the cognizance of the DOE Office of Environmental Restoration and Waste Management (EM-1), in conjunction with the DOE Office of Waste Management, Western Operations, and is managed by the DOE’s Carlsbad Area Office (CAO) in Carlsbad, New Mexico. The CAO is organized into three offices to address the three primary areas associated with the WIPP project (refer to Figure 2). The Office of Regulatory Compliance is responsible for compliance with regulatory requirements and for managing the WIPP experimental programs. The Office of National TRU Waste Operations manages the national TRU program and oversees the actual WIPP site. The Office of Program Support and Assurance assists the Assurance Team with the integrated responsibilities for quality assurance, environmental management, and safety and occupational health.
The CAO QA Manager reports directly to the CAO Manager and has been delegated the authority and overall responsibility to independently assess the effective implementation of the WIPP QA program, within both the DOE organization and participant organizations. Each of the three offices is assigned a quality assurance engineer who reports to an assistant manager in a technical capacity, but also is responsible for: (1) maintaining coordination with the QA Manager on quality matters affecting the office; and (2) providing QA support to the lower-tier WIPP participants.
The primary WIPP project participants include Sandia National Laboratories (SNL), Westinghouse Waste Isolation Division (WID), the nearly two dozen TRU waste sites that will eventually ship waste to the WIPP, and their various subcontractors. SNL is the chief scientific advisor and is responsible for scientific research, geohydrologic data collection, and for the development of the complex computer models used to predict the WIPP performance over the regulatory interval of 10,000 years. The WID is the management and operating (M&O) contractor for the repository site and conducts the necessary mining operations, environmental monitoring, and the emplacement and tracking of received waste. The TRU waste sites are responsible for characterizing and certifying the TRU waste and shipping it to WIPP.
Fig. 2. CAO Organization chart.
Each WIPP participant is responsible for establishing a QA program function within their organization and for preparing QA program documents and implementing procedures that comply with all the requirements applicable to the activities conducted by the organization. Participant upper-level QA program documents are reviewed and approved by CAO and the CAO also performs regular independent assessments of the individual programs. The routine oversight of a participant QA program is the responsibility of the participant. The use of a locally staffed and participant-oriented QA function is the preferred approach because it provides improved technical organization ownership of the QA program and enhanced credibility of the QA function. It also provides the immediate on-site availability of QA input often needed to resolve emergent issues and provides a level of site-specific technical information and local process knowledge that could not be readily duplicated by CAO resources.
This is particularly true in reference to the TRU waste sites. Over the past 20 to 30 years, each has fulfilled different roles in DOE defense-related activities. The sites: (1) are tasked through different DOE field offices; (2) have generated different wastes; and (3) possess different technological skills and capabilities for characterizing the waste. The day-to-day CAO effort with respect to the TRU waste sites is to provide an optimum level of assistance and guidance to the site QA staff via close support, frequent assistance, and feedback on QA programmatic issues. This support often involves QA training of staff personnel in the areas of QA requirements, auditor training, and corrective action courses. Feedback mechanisms also include periodic QA Managers meetings conducted by CAO at the different sites.
DOCUMENTS
Recognizing the potential pitfalls within the confusing and overlapping technical and QA regulatory requirements surrounding the WIPP project, the CAO developed a standard suite of WIPP program documents that capture, integrate, and consolidate both QA and technical requirements for the participants (See Figure 3). The primary document is the CAO Quality Assurance Program Document (QAPD) which contains the QA programmatic requirements from NQA-1, NQA-2, NQA-3, DOE Order 5700.6C, 40 CFR Part 194, and 10 CFR Part 830.120. This document applies to all WIPP participants.
A second document, the CAO Quality Assurance Program Plan (QAPP) for TRU Waste Characterization, provides the technical requirements for characterizing TRU waste. This document employs an approach which provides flexibility in the methods and analytical processes used to characterize TRU waste, provided that the appropriate prescribed Quality Assurance Objectives (QAOs) are met. The CAO Sampling and Analysis Methods Manual (S&AMM) is a companion document to the QAPP and is a compendium of approved analytical methods for characterizing TRU waste. The QAPP and the S&AMM are primarily applicable to the TRU waste sites, each of which must prepare their own Quality Assurance Project Plan (QAPjP) that conforms to the requirements of these two documents.
The CAO Waste Analysis Plan (WAP) provides the detailed plan for ensuring that all regulatory requirements are met prior to placing waste in the repository The WAP is a major part of the WIPP application for permitting as a hazardous waste repository. The WIPP Waste Acceptance Criteria (WAC) document provides the detailed requirements for certification of TRU waste for acceptance by the WIPP site for emplacement. Each of the TRU waste sites develops a site-specific TRU waste certification plan that documents how compliance with each requirement in the WAC will be accomplished by the site.
Fig. 3. Document hierarchy.
ASSESSMENTS
The CAO QA Manager conducts regular, comprehensive assessments of the WIPP participant QA programs. These assessments evaluate the adequacy, implementation, and effectiveness of the QA programs. Adequacy is the measure of how completely an organization’s documents address the WIPP QA requirements applicable to that site. Implementation is an evaluation of whether or not the organization’s procedures are being followed. Effectiveness is the determination of whether or not the QA program is yielding the necessary results.
The CAO assessments are also used to evaluate the technical effectiveness of the WIPP activities. The CAO assessment teams are led by a certified NQA-1 Lead Auditor and are composed of personnel from both technical and QA backgrounds. Extensive use is made of technical specialists who are highly qualified in the specific technical areas and disciplines under review. This practice provides the credibility, consistency, perspective, and skill base necessary to assess the many diverse organizations that participate in the WIPP project.
CORRECTIVE ACTION PROCESS
The corrective action process employed on the WIPP project uses Corrective Action Reports (CARs) to document and resolve conditions adverse to quality. The CAO line management is directly involved in the process at three points: (1) approval and issuance of the CAR; (2) acceptance of the CAR response (corrective action plan); and (3) acceptance of completed corrective actions and closure of the CAR. This provides the line managers an intimate knowledge of the deficiencies that exist in the organizations that they are responsible for and how those organizations plan to respond to and resolve those deficiencies.
The CAO has recently evolved the corrective action process to empower the line managers to delegate the CAR processing responsibilities to the leaders of the teams conducting the assessments for them. This is intended to provide better accountability and a more intimate knowledge of the specifics of the deficiency, while retaining a reasonable level of interaction with line management.
CONCLUSIONS
The WIPP project is a highly regulated, geographically diffuse, and technically intensive project that faces many of the quality assurance program challenges of any heavily regulated major organization. In meeting these challenges, the WIPP project has employed a mix of time-tested quality assurance processes combined with new and innovative management practices. These techniques have resulted in increased worker ownership of the QA process, enhanced QA program flexibility, improved sensitivity to technical issues, and better quality improvement initiatives.
The following is a summary of the QA practices utilized on the WIPP project which may have applicability and be of value in other similar organizations:
REFERENCES