Joseph L. Epstein, General Manager
Westinghouse Electric Corporation
Waste Isolation Division
U.S. Department of Energy
Carlsbad Area Office
P. O. Box 2078
Carlsbad, NM 88221

The U.S. Department of Energy's Waste Isolation Pilot Plant is scheduled to be the first underground repository for nuclear waste in the United States. In preparation for opening this one-of-a-kind facility in 1998, the Westinghouse Electric Corporation's Waste Isolation Division and the Department of Energy will complete separate and thorough preliminary reviews of the planned operation and oversight of the Waste Isolation Pilot Plant facility.

The Waste Isolation Pilot Plant (WIPP) is the first underground disposal facility for transuranic (TRU) wastes generated by United States defense related activities. It is a facility managed by the U. S. Department of Energy's (DOE) Carlsbad Area Office (CAO), and is located in southeastern New Mexico, 41.8 kilometers southeast of Carlsbad. Disposal of TRU waste will occur in rooms mined in 225-250 million-year-old stable salt formation 656 meters below the surface. Buildings on the surface provide space for receiving and unloading waste shipping containers, utility system installations, and work locations for the operating and administrative staff. The WIPP will initially emplace only contact-handled (CH) TRU waste and begin emplacing remote-handled (RH) TRU waste in 2002.

The DOE has established a process that requires demonstration of safe operation prior to receiving approval for startup or restart of its nuclear facilities. This process set forth in DOE Order 425.1⁽¹⁾ allows a designated authority to grant approval for startup or restart only after documented independent reviews of readiness have been conducted with favorable results. The process requires a phased approach in which a Management and Operating (M&O) contractor achieves readiness, an independent contractor Operational Readiness Review is conducted and, finally, an independent DOE Operational Readiness Review is conducted.

This paper deals with the processes and activities necessary for achieving readiness, the first phase of implementing the DOE Operational Readiness process at the WIPP. The Waste Isolation Division (WID) used a Line Management Assessment approach to achieving readiness for CH waste disposal operations at the WIPP. This approach consisted of a formal review and assessment of waste disposal and supporting processes, an integrated facility checkout, and a performance dry run of the CH waste disposal process.

The WID Line Management Assessment began on July 29, 1996, with the formal review and assessment of CH waste disposal and supporting operations, conducted against a set of criteria developed from the minimum Core Requirements in DOE Order 425.1⁽¹⁾.

Prior to the start of the Line Management Assessment, WID Management tasked a team of knowledgeable WID employees to develop the criteria that would be used in the assessment. For consistency with the DOE readiness process, the team selected the 20 minimum core requirements for evaluating nuclear facility readiness. The team selected an additional core requirement to evaluate the facility's compliance with commitments set forth in the Resource Conservation and Recover Act (RCRA) Part B, permit application (2) and other environmental requirements. These minimum core requirements are listed in Table 1. Three of the original twenty core requirements were not included because they apply strictly to DOE oversight and function, not to the operation of the site itself. The remaining 18 core requirements were broken down into performance objectives. The performance objectives were further broken down into specific, measurable criteria. Figure 1 provides an example of this assessment structure. The criteria were then identified with one or more of 61 functional areas (e.g., waste handling operations, radiation safety, training, etc.) to measure the readiness of systems (hardware), personnel, and processes (procedures).

Section managers and their organizations documented their readiness status on signed statements called affidavits. The affidavits contain a summary statement of the readiness status and other information supporting that status. The affidavits were also used to document deficient conditions, or "findings," and classify those findings as areas needing correction before startup (prestart) and those that could be corrected after startup (post-start).

A lead individual was assigned when a criteria applied to more than one WID organization. The lead was responsible for reviewing affidavit responses to assure consistency, completeness, and an integration of responsibilities among groups.

Once the affidavits, including identification of prestart and post-start findings, were completed, the affidavits were forwarded to the responsible department manager for validation. Each department manager established a methodology for performing these validations. The validations included review of the statement and associated findings (for rigor of assessment, proper supporting documentation, completeness, and logic) and independent sampling of the lines of inquiry presented in the statement. The validation process occasionally produced additional prestart or post-start findings identified for the criterion. Findings were added to the original affidavits and resolved.

The formal review and assessment segment of the Line Management Assessment resulted in 447 prestart findings and 209 post-start findings identified from 1,194 affidavit statements. The following significant improvements resulted from this segment of the Line Management Assessment:

• Qualification of Cognizant System Engineers - A qualification program for cognizant system engineers was developed consistent with the Systematic Approach to Training required by DOE Order 5480.20A⁽³⁾, Personnel Selection, Qualification, and Training Requirements for DOE Nuclear Facilities. This qualification program requires that each Cognizant System Engineer and alternate to demonstrate consistent understanding of design and design approval processes, industrial and nuclear safety requirements, and As Low As Reasonably Achievable concepts. The qualification process culminated in a rigorous oral board examination for each Cognizant Engineer.
• Documented compliance with provisions of the RCRA Part B Permit Application⁽²⁾ - Each functional area was required to demonstrate compliance with provisions of the RCRA Part B Permit Application⁽²⁾. This effort resulted in documentation of compliance and identification of conditions in the application which were inconsistent with field practice. Inconsistencies were either corrected in operating procedures or are being tracked for subsequent change, prior to start up, as appropriate.
• Documentation of the implementation of WIPP Safety Analysis Report and Technical Safety Requirements conditions and programs.
• Completion of a thorough review of the process for developing and assessing the applicability and implementation of regulations and DOE orders through the Standards/Requirements Identification Document.

The CAO conducted oversight surveillances of WID during the formal review and assessment segment. These oversight activities culminated with a surveillance to validate the proper closure of the prestart findings (all but one were closed by July 21, 1997) .

The second segment of the Line Management Assessment was the Integrated Facility Checkout (IFC). The purpose of the IFC was to place WIPP in an "operational mode" so that planned waste disposal functions could be performed and assessed at anticipated waste receipt rates with simulated waste packages. The IFC was conducted in two phases to allow for the incorporation of lessons learned between phases.

The first phase of the IFC began on April 1, 1997, and ended on April 30, 1997. Among the lessons learned from this first phase of IFC were the following:

• Needed better control of radiological boundaries and the implementation of general radiation work permits for frequently performed work (i.e., preventive maintenance and inspections).
• General radiation theory/radiological control knowledge of some personnel lacked proficiency and required some refresher training.
• Better control and communications required during abnormal event and emergency exercises and drills.

The second phase of the IFC began on May 12, 1997, and ended on June 30, 1997. Observations from the second phase of the IFC indicated that lessons learned were being incorporated and there was notable improvements in the performance of waste disposal functions. Some observations from the second phase of the IFC are:

• Abnormal/emergency drill and exercise performance improved from a level of below average to near excellence on many types of drills and exercises.
• As part of a performance drill, two drums of simulated waste were found imploded during waste shipping evolution. The event was handled as if it were an actual waste shipment. The two drums were not vented and they imploded during the removal of the shipping container internal container vessel lid. Testing was conducted to ensure that drums with installed carbon filters would not implode under the same conditions. The testing was completed successfully. Results of the testing were shared with the TRU generator sites through CAO.
• Coordination between the Radiation Safety and Maintenance organizations in the performance of preventive/corrective maintenance activities in radiation areas improved as the IFC progressed.

The IFC resulted in improved operations performance with stronger interaction with operating and supporting organizations in WID. Site personnel, not directly involved in waste disposal activities, improved in their responses to abnormal and emergency events in the facility through participation and awareness of the drills and exercises.

The last segment of the Line Management Assessment was a formal evaluation of end-to-end waste disposal operations known as the Performance Dry Run. The Performance Dry Run was evaluated by a team of senior WID and CAO personnel.

The Performance Dry Run consisted of:

• An evaluation of the WIPP Waste Information System and its ability to transfer and assess waste shipment data to/from a generator site.
• Confirmed through loading and shipment of simulated waste
• Unloading and emplacement of the simulated waste
• Emplacement of the magnesium oxide backfill on the waste stack
• Concluded with the evaluation of emergency/abnormal event exercises and drills.

The Performance Dry Run also included evaluation of the implementation of conditions and requirements from the WIPP Safety Analysis Report and Technical Safety Requirements Document. The evaluation team assessed the performance of all aspects of the Performance Dry Run as satisfactory.

The Performance Dry Run was observed by officials from the Defense Nuclear Facilities Safety Board, the New Mexico Environmental Evaluation Group and the DOE Operational Readiness Review Team.

Line Management Assessment activities will conclude with the issuance of a Memorandum of Readiness by the WID General Manager, which is expected on December 12, 1997. This memorandum will detail the readiness posture of the division in preparation for the Contractor Operational Readiness Review (ORR).

The Contractor ORR is expected to begin on January 12, 1998, and last for two weeks. The Contractor ORR will validate that the WID has achieved readiness and make its recommendation on WIPP startup.

The Contractor ORR will be followed by a DOE ORR in early March 1998. If the results of this process are positive, a decision by the Startup Authority to begin CH Waste

disposal operations could be made by the end of March 1998. This decision would then provide the operational basis for the Secretary of Energy's decision to operate WIPP as a disposal facility. The Secretary's decision is expected in May 1998.

The rigor and discipline within the WID ORR process as the M&O for the DOE CAO, has resulted in an improved process for the identification of areas in need of improvement. The process will identify needed improvements well before the DOE ORR might identify them. The DOE ORR team of experts from other DOE facilities will find WIPP prepared for its scrutiny.

This ORR process will demonstrate to the American public the principles incorporated into WIPP to protect worker health, community well being, and the environment. Representatives of the international community already use WIPP as their benchmark for development of nuclear disposal facilities. Over the years, they have visited WIPP as it was built and in the period when new regulations and rules were placed on the DOE. They have watched DOE and WID jointly with regulators resolve questions, clarify standards, and garner public support for the world's first repository for some of the nuclear waste generated by the U.S. nuclear weapons programs.

When the WIPP begins disposal of TRU waste, it will be THE example of nuclear cleanup responsibility, not only in this country, but in other nations struggling with these issues as well. WIPP is a demonstration of not only the technical ability to safely dispose of long-lived radioactive wastes, it is also proof of our national commitment to the world community and the environment. This nation will show the path to a cleaner, safer, post-cold war world.

1. DOE Order 425.1, Startup and Restart of Nuclear Facilities, September 1995.
2. DOE/WIPP 91-005, WIPP RCRA Part B Permit Application, Revision 6, April 10, 1996.
3. DOE Order 5480.20A, Personnel Selection, Qualification, and training Requirements for DOE Nuclear Facilities, November 1994.

BACK