DEFENSE NUCLEAR FACILITIES SAFETY BOARD

August 28, 1992

MEMORANDUM FOR:     G. W.  Cunningham, Technical Director

COPIES:             Board Members 

FROM:               Dermot M. Winters

SUBJECT:            DNFSB Staff and Outside Experts (MITRE Corporation) WIPP
                    Site Visit; July 27-30, 1992

1.Purpose:  The DNFSB staff and outside experts met with DOE Headquarters, DOE
  WIPP Project Integration Office (WPIO), DOE WIPP Project Site Office (WPSO),
  Westinghouse Waste Isolation Division (WID) and Sandia National Laboratories
  (SNL) personnel at the WIPP site during the period July 27, 1992 through July
  30, 1992.  The purpose of the visit was (1) for outside experts (MITRE) to
  identify, request, and collect pertinent documents describing WIPP's safety
  requirements and procedures in support of an initial standards review and (2)
  for DNFSB staff to investigate the quality of the scientific data collection
  program and to follow up on certain electrical and fire protection issues
  identified during a prior site visit.

2.Summary:  Discussions led by MITRE were held on the status and content of
  documents describing policies, requirements, and procedures in various
  subject areas.  Some preliminary observations that will require follow-up and
  review were identified.

  DNFSB staff investigated the quality of the scientific data collection
  program and followed up on certain electrical and fire protection issues
  identified during a February 1992 site visit.

3.Background:  This initial MITRE visit to the WIPP site was made to initiate
  work on the review and evaluation of safety documentation prepared by WID and
  SNL.  The visit included a tour of the WIPP surface and underground
  facilities, and discussions with WPIO, WPSO, WID, and SNL staff on the status
  and content of documents describing policies, requirements, and procedures in
  the following subject areas: DOE directives, resolution of Operational
  Readiness Review (ORR) findings, safety analysis, quality assurance,
  configuration management, waste management, design standards, maintenance,
  radiation protection, and training.  Additional discussion sessions on fire
  protection and quality assurance, held primarily by DNFSB staff were also
  attended by MITRE.
  During this trip DNFSB staff focused on reviewing activities affecting
  quality associated with the collection of scientific and technical data. 
  Primary emphasis was placed on the procedures used to collect experimental
  data and the processes in place to ensure data integrity, retrievability, and
  traceability.  The review consisted of briefings by SNL and WID, a tour of
  the facility including data acquisition facilities and the core library, and
  a system walk-down of typical experiment data acquisition components.

  The principle purpose for the stringent quality controls on the collection of
  scientific data collected in the experimental program is to provide accurate
  data to support a credible and defensible prediction of the WIPP performance
  for the next 10,000 years as required by 40 CFR 191, Subpart B.  As such the
  requirements of ASME NQA-1, Quality Assurance Program Requirements for
  Nuclear Facilities are imposed through DOE Order 5700.6B, Quality Assurance
  (DOE Order 5700.6C, Quality Assurance, has yet to be implemented at WIPP).
 
  The division of responsibilities for WIPP site testing is defined in a
  Memorandum of Understanding and incorporated in the Test Phase Management
  Plan.  In general, SNL, as the Scientific Program Manager at WIPP has the
  responsibility for design, development, fielding and maintenance of the WIPP
  Experimental Program as well as developing models to interpret the
  experimental data, and applying this information to the experimental models
  in the Performance Assessment.  WID assists SNL by supplying support
  personnel from the Experimental Operations Work.  SNL and WID perform
  independent QA for their areas of responsibility.

  SNL is responsible for design of the experiments in support of the
  Performance Assessment.  The Principle Investigator is responsible for the
  design of the experiment including defining the data needed for the
  Performance Assessment, the conceptual method to obtain the data and
  development of the Experimental Test Requirements (ETR) documents.  For TRU
  Waste tests, WID has the primary responsibility for development and
  installation of the experimental data acquisition equipment.  For Non-TRU
  Waste test, SNL will be the lead for this activity.  SNL is responsible for
  the collection, reduction and analysis of all data.  An experimental Program
  Work Request is used to document and detail the installation procedures.

  During a previous site visit in February an initial DNFSB staff review of
  electrical and fire protection issues was begun.  That review was completed
  during this visit.

4.  Discussion/Observations:

  a. MITRE Observations--Some observations made by MITRE in its draft trip
     report of August 13 are as follows:

     1.WID operating procedures that have been developed so far focus
       primarily on activities related to the experimental bin-scale tests and
       do not yet fully reflect many of the more recently-issued DOE Orders.

     2.The local DOE process for reviewing and evaluating WID's response, and
       implementing DOE directives is not formalized.

     3.It is not clear what actions will be taken to address the differences
       in design standards invoked in DOE Order 6430.1A, General Design
       Criteria, and those used for WIPP (WIPP was designed and built prior to
       issuance of Order 6430.1A).

     4.There is no formal DOE requirement placed on WID for self-assessments
       directed towards Order Compliance Verification.

     5.The interfaces among WPIO, WPSO, WID, and SNL are, in many instances,
       not clearly defined in a formal manner.

     6.With regard to the resolution of findings from the 1991 EM-ORR, a
       process to close-out ORR findings is in place, but there is no
       documentation available that describes the process and establishes the
       authorities and responsibilities for WPSO, WPIO, DOE-EM, WID, and SNL.A
       copy of a preliminary report from MITRE is attached below.

  b.  Quality of Scientific Data Collection Program--

     1.Data Collection and Storage:  Staff review indicated that the
       procedures for ensuring correct experiment construction and data
       acquisition are detailed and well controlled. The equipment
       installation, including any required boring and sensor installation, is
       completed using a work request that includes necessary design drawings
       and detailed procedures.  

       Sensor locations are referenced to a relative position in the
       underground test room or alcove.  This reference position is then
       referenced to another position at the surface.  This allows
       traceability of all collected data to a common reference point. 
       Sensors are calibrated using a secondary standard.  SNL maintains the
       primary standards in Albuquerque. For the most part, sensors are
       industry standard off-the-shelf sensors.

       The data acquisition system is a general purpose system designed in the
       early 1980's for oil shale experiment data collection.  The system,
       although relatively antiquated, is a proven, highly reliable and
       flexible system that is easily adapted to the various experiments
       conducted at WIPP.  Although the DAS software does not meet the
       requirements of "High Impact" software, changes are controlled using a
       configuration management process and a password access system. 
       Software documentation was not reviewed during this trip.   

       Data is collected and stored in an ANSI standard format on tapes in raw
       form prior to data reduction or conversion to engineering units.  Three
       copies of the data are maintained - WIPP, the Principle Investigator
       and one copy in NQA-1 storage in Carlsbad.  At the SNL WIPP Data
       Reduction Center the data tapes are loaded into a VAX data reduction
       system.  The data is reduced and stored in a database, where it is
       available for analysis.  The raw and reduced data are periodically
       downloaded to optical disk for long term storage.  As many of the
       processes for the control of the data are new it is not evident that
       all older data necessary to support the Performance Assessment are
       retrievable.

       As part of this review DNFSB staff visited the WIPP rock core storage
       library.  This library contains boxed, sequenced, drill cores from site
       geologic investigatory drilling.  Appropriate physical security and
       records management activities were in place.  All cores can be
       accounted for at all times as the result of the formal sign-out
       procedure for any core removed for examination or testing.  Labeled
       wooden spacers are found in core boxes indicating places where sections
       of cores have been removed for examination and testing.  Core logs are
       maintained at the library with backup copies at SNL in Albuquerque.

     2.Data interpretation and incorporation into the Performance Assessment  

       Integration into the Performance Assessment is performed in Albuquerque
       by SNL.  There the data in raw or reduced form is analyzed and used to
       develop models and inputs for the Performance Assessment.  This area
       was not reviewed during this trip and should be reviewed on a future
       staff visit.

  c.  Fire Protection and Electrical Systems
  
     The DNFSB staff reviewed the status of all the electrical modification
     projects and diesel generator systems.  Alternate methods for hoist
     operations during station blackout scenarios were also discussed.  A
     detail review of the Conceptual Design Report to install permanent
     alternate electrical service for the WIPP was performed to verify the
     adequacy of the conceptual design.  This electrical service will provide
     a second independent power source to the WIPP substation.   A walkdown of
     fire detection and protection equipment was performed.  The existing fire
     protection system was reviewed.  Specifically, fire pump/motor design data
     (cable size, overload protection, layout) was reviewed.  A complete review
     will be performed after receipt of the additional required documentation. 
     Fire hazard analysis (FHA) discussed in brief and a complete review of FHA
     will be performed after the receipt of the documents.  The details will be
     discussed in a forthcoming detailed trip report being prepared by A. Gwal
     of the DNFSB staff.

5.  Future Staff Action:  Additional periodic staff review visits to the WIPP
Site will be made to track progress of the WIPP program.