SP 9-4 

Revision 2 

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© 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 represent 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 the 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 assessments 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 

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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. 
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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 purposes of this procedure, the Performance 

Assessment (PA) Manager is responsible for communicating 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 identification 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 

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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 all FEPs analyses conducted since the submittal of 

the Compliance Recertification Application – 2009. The contents will be used to consolidate and update the 

FEPs baseline prior to the third Compliance Recertification Application scheduled for completion in 2014. 
Performing FEPs Baseline Impact Assessments for SP 9-4 

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Corporate Notice 

NOTICE: This document was prepared as an account of work sponsored by an agency of the 

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This document was authored by Sandia Corporation under Contract No. DE-AC04-94AL85000 

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