SP 9-4

Revision 2 Page 1 of 4

© 2009 Sandia Corporation IMPORTANT NOTICE: The current official version of this document is available via the Sandia National Laboratories WIPP Online Documents web site. A printed copy of this document may not be the version currently in effect.

ACTIVITY/PROJECT SPECIFIC PROCEDURE



### SP 9-4

PERFORMING FEPs BASELINE IMPACT ASSESSMENTS

FOR PLANNED OR UNPLANNED CHANGES

Revision 2

Effective Date: 08/24/09

Author: Ross Kirkes Original signed by Ross Kirkes 8/24/09 (printed name) (signature) (date)



## 1.0 Purpose and Scope

This specific procedure (SP) prescribes the Sandia National Laboratories (SNL) Waste Isolation Pilot Plant (WIPP) process for assessing the impact of changes upon the features, events, and processes (FEPs) baseline. Changes may be either planned or unplanned. “Planned changes” are those initiated by the Department of Energy (DOE) and repr esent a condition or description that differs from that in the most recent certification baseline. Planned changes must be approved by the Environmental Protection Agency (EPA) prior to implementation. “Unplanned changes” are those conditions or events that have not been initiated by t he DOE, but differ from that described in the most recent certification baseline. Both planned and unplanned changes are evaluated to determine their impact to key PA components. Key PA components consist of:

• FEPs

• PA Scenarios

• Conceptual models

• Numerical models

• Computer Codes

• PA Parameters

Because the FEPs baseline documents what is , and what is not considered in PA, it is the logical starting point for the assessment of potential impacts from planned and unplanned changes. Based on the results of FEPs baseline impact assessments, other more detailed analyses may be conducted to determine potential impacts to the predicted performance of the WIPP in a more quantitative manner, if necessary. This procedure only addresses the initial step; the FEPs baseline impact assessment. If deemed necessary, further analyses or assessments are recommended as one of the concluding steps of FEPs baseline impact assessment s and must meet the requirements of NP 9-1, Analyses

.

Acronyms and definitions for terms used in this procedure may be found in the Glossary located at the Sandia National Laboratories (SNL) WIPP Online Documents web site.Performing FEPs Baseline Impact Assessments for SP 9-4 Planned or Unplanned Changes Revision 2 Page 2 of 4



## 2.0 Implementation Actions

2.1 Safety

No unusual health and safety concerns are expected as part of activities conducted under this procedure. The tasks associated with this activity are expected to be performed under a normal office

environment.

2.2 Key Terms

Baseline FEPs List (BFL): The most current listing of FEPs, their descriptions, arguments, and decisions. This list is a Quality Assurance (QA) record and maintained in the Sandia Records Center in Records Package 539355.

Future: A term used in defining the period of time in the future that applies to a certain FEPs, typically beginning after the closure of WIPP, and lasting until the end of the 10,000-year regulatory timeframe.

Historic, Current, and Near-Future (HCN): A term used to describe the timeframe that a given FEP is applicable. Generally implies that the FEP has happened in recorded history, is happening currently, and/or may happen in the foreseeable future.

Screening Argument: The FEP description, discussion, and relationship with the WIPP disposal system as presented in the baseline FEPs screening document (DOE 2009, Appendix SCR).

Screening Decision: The conclusive decision that either includes, or excludes a FEP from performance assessment (PA) scenarios; Screening decisions are abbreviated as DP, UP, SO-C, SO-P, and SO-R, and are described below.

Screened in – Disturbed Performance (DP): A FEP retained and accounted for in disturbed performance scenarios.

Screened in – Undisturbed Performance (UP): A FEP retained and accounted for in undisturbed performance scenarios.

Screened Out – Consequence (SO-C): A screening decision that excludes a FEP from consideration in PA scenarios based on no, or low consequence to the disposal system. FEPs may also be SO-C

due to beneficial consequence. That is, a FEP that has a positive or beneficial effect to the disposal system may be screened out because the difficulty of accurately representing the FEP in PA scenarios and models may be such that not accounting for the FEP is a conservative alternative to undergoing the expense and additional modeling complexity to accurately represent the FEP.

Screened Out – Probability (SO-P): A screening decision that excludes a FEP from consideration in PA scenarios based on very low probability of occurrence.

Screened Out – Regulation (SO-R): A screening decision that excludes a FEP from consideration in PA due to a regulatory directive.Performing FEPs Baseline Impact Assessments for SP 9-4 Planned or Unplanned Changes Revision 2 Page 3 of 4

2.3 Roles and Responsibilities

FEPs Analyst: The FEPs Analyst is responsible for conducting FEPs impact assessment according to this SP, and is the primary author of the requisite reports and record submittals.

FEPs Coordinator: The FEPs Coordinator is responsible for maintenance of the Baseline FEPs List (BFL), and submission of all associated record submittals.

Performance Assessment Manager: For the purpos es of this procedure, the Performance Assessment (PA) Manager is responsible for comm unicating any impacts identified by assessments conducted under this SP to the appropriate PA Process Model Sponsor. The PA Manager is also responsible for assuring that any further analyses recommended by impact assessments conducted

under this SP are carried out and documented.

Process Model Sponsor: The Process Model Sponsor is the principal investigator (PI) responsible for the maintenance, conduct, and documentation of any of the primary PA process models. These include: Salado Flow and Transport, Culebra Flow, Culebra Transport, and Direct Release Mechanisms (spallings, cuttings, cavings, direct brine release).

2.4 Implementing Actions

2.4.1 Obtain the most recent version of the BFL from the Sandia Records Center, Records Package

539355.

2.4.2 Compare the nature and scope of the planned or unplanned change with the current FEPs baseline and identify all related FEPs.

2.4.3 Determine if there are new FEPs associated with the proposed change that are not within the current WIPP BFL. Note: Adding FEPs to the BFL must be done in accordance with NP 6-1

, Document Review Process , and is not done under this SP. Adding FEPs to the BFL can only be done by the FEPs coordinator.

2.4.4 Determine if the screening arguments and decisions for FEPs identified in Step 2.4.2 need revision to reflect aspects of the proposed change; revise as appropriate. Evaluation of screening arguments and descriptions must use the most current FEPs screening document

. See Compliance Recertification Application – 2009, Appendix SCR (DOE 2009).

2.4.5 Identify additional activities based on any revised screening arguments and/or decisions. Additional activities may include but are not limited to: 1

• New or modified screening calculations

• New or revised conceptual models

• New or revised performance scenarios

• New or revised parameterization

• New or revised process models

• New or revised modeling assumptions

1 Analyses performed under this SP are limited to the ident ification of impacts to the FEPs baseline. Any subsequent action must be performed under a separate Analysis Plan.Performing FEPs Baseline Impact Assessments for SP 9-4 Planned or Unplanned Changes Revision 2 Page 4 of 4

2.4.6 Summarize potential impacts to the FEPs baseline.

2.4.7 If the results of Step 2.4.3 conclude that revision to the BFL is necessary, revision must be done according to NP 6-1 , Document Review Process and shall be maintained as a QA record, according to NP 17-1, Records.

2.4.8 Document the results and recommendations of this Baseline FEPs Assessment in an appropriate analysis report following NP 6-1 and NP 17-1 as appropriate. Report format should follow NP 9-1, Appendix A. The results of all FEPs assessments conducted under this AP should be placed in records package 549146. 2

2.4.9 Communicate any recommended analyses or further activities to the PA Manager for assignment and disposition. This activity is validated by the mandatory signature of the PA manager on the FEPs Impact Assessment Report cover sheet.

2.5 References

U.S. Department of Energy (DOE). 2009. Appendix SCR. Title 40 CFR Part 191 Compliance Recertification Application for the Waste Isolation Pilot Plant (March). DOE/WIPP-2009-3424. Carlsbad, NM: Carlsbad Field Office.



## 3.0 Records

The following QA records, generated through implementation of this procedure, shall be prepared and submitted to the WIPP Records Center in accordance with NP 17-1 (Records):

QA Record

• FEPs Assessment Analysis Report

• Document Review Comment form per NP 6-1

• Revised BFL (if warranted)



## 4.0 Appendices

Not Applicable

2 Records package 549146 has been established to contain a ll FEPs analyses conducted since the submittal of the Compliance Recertification App lication – 2009. The contents will be used to consolidate and update the FEPs baseline prior to the third Compliance Recert ification Application scheduled for completion in 2014.Performing FEPs Baseline Impact Assessments for SP 9-4 Planned or Unplanned Changes Revision 2 Corporate Notice

NOTICE: This document 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, nor any of their contractors, subcontract ors, or their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness or any informati on, apparatus, product or process disclosed, or represents that its use would not infringe privately owned rights. Re ference herein to any specific commercial product, process or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government, any agency thereof or any of t heir contractors or s ubcontractors. The views and opinions expressed herein do not necessa rily state or reflect those of the United States Government, any agency thereof or any of their contractors.

This document was authored by Sandia Cor poration under Contract No. DE-AC04-94AL85000 with the United States Department of Energy’s National Nuclear Secu rity Administration. Parties are allowed to download copies at no cost for in ternal use within your organization only provided that any copies made are true and accurate. Copies must include a statement acknowledging Sandia Corporation's authorship of the subject matter.