United States
           Environmental Protection
           Agency
           Air And Radiation
           (6602J)
EPA 402-R-95-002
January 1995
&EPA
Criteria For The Certification And
Determination Of The Waste
Isolation Pilot Plant's Compliance
With 40 CFR Part 191
Background Information
Document For Proposed
40 CFR Part 194

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 BACKGROUND INFORMATION DOCUMENT
      FOR PROPOSED 40 CFR PART 194

  CRITERIA FOR THE CERTIFICATION AND
DETERMINATION OF THE WASTE ISOLATION
    PILOT PLANT'S COMPLIANCE WITH
            40 CFR PART 191
     U.S. Environmental Protection Agency
       Office of Radiation and Indoor Air
            401 M Street, S.W.
          Washington, D.C. 20460
              January, 1995

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                                       Contents
1.  Introduction  	1-1
       1.1    EPA Authorities for the Rulemaking	1-1
       1.2    History of the 40 CFR parts 191 and 194 Rulemakings	1-2
       1.3    The WIPP Land Withdrawal Act	1-8
             1.3.1  Promulgation of Final 40 CFR Part 191	1-9
             1.3.2  Test Phase Plan Review	1-9
             1.3.3  Retrieval Plan Review  	:	1-10
             1.3.4  Compliance  with the Radioactive Waste Disposal Standards  ....  1-10
             1.3.5  No-Migration Determination  	1-10
             1.3.6  Other EPA Activities	1-11
       1.4    Purpose and Scope of the Background Information Document  	1-12
       1.5    References  	1-13

2.  Waste Characterization	2-1
       2.1    Identification of TRU  Waste Characteristics Potentially Relevant to
             Compliance Assessment  	2-1
             2.1.1  Radionuclide Inventories	2-1
             2.1.2  Actinide Solubility  	2-2
             2.1.3  Gas  Generation  	2-2
       2.2    Programs and Methods	2-3
             2.2.1  DOE Management Structure  	2-4
             2.2.2  DOE WIPP  Waste Acceptance Criteria (WAC)	2-4
             2.2.3  Overview of Characterization Methods	2-5
       2.3    Status  of Waste Characterization for Compliance Assessment	2-10
             2.3.1  Inventory	2-11
             2.3.2  Actinide Solubility  	2-13
             2.3.3  Gas  Generation  	2-14
             2.3.4  Other Characteristics	2-16
       2.4    Efforts to Use Process Knowledge to Characterize TRU Waste  	2-17
             2.4.1  Definition of Process Knowledge	2-17
             2.4.2  Using  Process Knowledge for Waste Characterization	2-17
             2.4.3  Use of Process Knowledge for TRU Inventory  	2-19
             2.4.4  Evaluating the Use of Process Knowledge	2-20
       2.5    Current Assumptions  	2-22
       2.6    Regulatory Precedents for Waste Characterization   	2-23
             2.6.1  Resource Conservation  and  Recovery  Act (RCRA)	2-23
             2.6.2  Other Relevant Regulations  or Guidance	2-24
       2.7    References  	*	2-27
       Appendix 2A:      Summary of Waste Limiting Parameters for CH-TRU
                          Waste Addressed in WIPP  WAC   	2A-1
       Appendix 2B:       Proposed Methodology for Evaluating the Assignment of

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                         TRU Content Assignments Using Process Knowledge  . . . 2B-1
      Appendix 2C:       Goals of French HLW Waste Characterization Under
                         Rule iii.2.F	2C-1

3. Uncertainty and "Reasonable Expectation"	3-1
      3.1.   Introduction	3-1
             3.1.1  Background	3-1
             3.1.2  General  Approach to Evaluating Compliance  	3-2
             3.1.3  Outline of Chapter 3	3-6
      3.2    Probability of Compliance	3-6
             3.2.1  Review of the Probabilistic Requirements of 40 CFR part 191 .... 3-6
             3.2.2  Statistical Interpretation of the Requirements of 40 CFR part 191 . . 3-9
             3.2.3  Use of Expert and Peer Review for Determining Level of
                   Confidence	3-10
             3.2.4  Use of Statistical Methods for Determining Compliance	3-11
             3.2.5  Use of Sampling Methods	3-15
             3.2.6  Conditional Probabilities of Compliance  	3-17
             3.2.7  Unconditional Probability of Compliance with the Containment
                   Requirements  	3-21
      3.3    Comparison fof Alternative  Criteria for Compliance	3-22
             3.3.1  Advantages and Disadvantages of Alternative Compliance
                   Criteria Using a Central Point Measure  	3-22
             3.3.2  Advantages and Disadvantages of Alternative Compliance
                   Criteria using Percentiles	3-28
      3.4    Other Regulatory Considerations	3-31
             3.4.1  Environmental Protection Agency	3-31
             3.4.2  Nuclear Regulatory Commission	3-32
             3.4.3  Department of Energy	3-35
             3.4.4  Non-U.S. Disposal Systems	3-35
      3.5    Conclusions	3-41
             3.5.1  Essential Role of Expert/Peer Review	3-42
             3.5.2  Selection of a Statistical Criterion for Compliance	3-43
      3.6    References  	3-46

4. Quality Assurance Programs   	r .4-1
      4.1    Introduction	4-1
             4.1.1  Purpose	4-1
             4.1.2  Scope	4-1
             4.1.3  Organization	4-1
             4.1.4  Summary   	4-2
      4.2    Background	4_2
             4.2.1  40  CFR part 191, Subparts B and C  	4-2
             4.2.2  Quality  Assurance Programs at the WIPP	4-3
      4.3    Quality Assurance Requirements and Guidance Pertaining to Data
                                          ii

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            Quality	4-3
            4.3.1  General	4-4
            4.3.2  Summary of DOE/WTPP Requirements	4-5
            4.3.3  Summary of EPA Requirements	4-14
            4.3.4  Summary of NRC Requirements	4-18
            4.3.5  ANSI/ASQC E4	4-26
      4.4   Summary  	4-36
            4.4.1  EPA QA Requirements  	4-36
            4.4.2  Specifying NRC QA Requirements for the WIPP  	4-36
            4.4.3  Validation of Older Data and Models	4-37
      4.5 References   	4-40

APPENDIX 4A DOE Waste Isolation Pilot Project QA Data Requirements  	4A-1

                         I. Organization and Responsibilities	4A-1

A.  DOE Headquarters	4A-1
      A.I   EM-1, Office of Environmental Restoration and Waste Management .  . . 4A-1
      A.2   EM-30, Office of Waste Operations	4A-2

B.  DOE Field  Operations	4A-3
      B.I   WPIO, WIPP Project Integration Office  	4A-3
            B.I.I        WPSO, WIPP Project Site Office	4A-3
            B.I.2        SNL, Sandia National Laboratories	4A-4
      B.2   Albuquerque Field Office (AL)	4A-4

C  Waste Generators	4A-4

                               n. QA Requirements  	4A-5

D.  DOE WIPP Project QA Documents and Requirements	4A-5
      D. 1   DOE  HEADQUARTERS   	4A-5
            D.I.I        DOE Order 5700.6C (DOE91)  	4A-5
            D.I.2        EM-342 Quality Management Plan  (QMP) (DOE91a) .  . . 4A-6
      D.2   DOE  Field Operations  	4A-6
            D.2.1        WIPP Project Integration  Office Plan for the WIPP
                         Quality Assurance Program (DOE92a)   	4A-6
            D.2.2        WPIO QA Program Plan  for the WIPP Experimental-
                         Waste Characterization Program  (DOE92)  	4A-7
            D.2.3        WPIO Waste Characterization Program Plan for the
                         WIPP (DOE92b)	4A-8
      D.3   SANDIA NATIONAL LABORATORIES  	4A-9
            D.3.1        WIPP QA Program Description (SNL/QAPD)(SNL92b)  .  . 4A-9
            D.3.2        Preliminary Performance  Assessment for the Waste
                                       111

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                        Isolation Pilot Plant, December 1992, Volume 2:
                        Technical Basis (SNL92) ..................... 4A~9
            D.3.3       Preliminary Performance Assessment for the Waste
                        Isolation Pilot Plant, December 1992, Volume 1: Third
                        Comparison with 40CFR191, Subpart B (SNL92a)  ....  4A-10
            D.3.4       WIPP QA Procedure No. QAP 2-2, Qualification and
                        Training Program (SNL92c) ..................  4A'n
            D.3.5       WIPP QA Procedure No. QAP 2-3, Qualification of SNL
                        Personnel Performing Leak Testing Activities (SNL92d)   4A-11
            D.3.6       WIPP QA Procedure No. QAP 6-1, Document Control
                        Procedure (SNL92e) .......................  4A-n
            D.3.7       WIPP QA Procedure No. QAP 16-1, Trend Analysis
                        Program ,n,NL91)  ................. -,  ......  4A"12
            D.3.8       WIPP QA Procedure No. QAP 17-1, QA Records
                        Requirements (SNL92f) ....................  4A-12
            D.3.9       WIPP QA Procedure No. QAP 17-3, Records Inventory
                        and Disposition Schedule (SNL90) ..............  4A-12
            D.3.10      WIPP QA Procedure No. QAP 18-1, QA Audit
                        Requirements (SNL92g)  ....................  4A-12
            D.3.11      WIPP QA Procedure No. QAP 19-1, WIPP Computer
                        Software Requirements (SNL93f) ...............  4A-13
            D.3.12      WIPP Procedure No. PAP01, Definitions for and
                        Structure of Performance Assessment Procedures
                        (SNL93)  .............................. 4A-13
            D.3.13      WIPP Procedure No. PAP02, Computer Software
                        Supporting Performance Assessments of the Waste
                        Isolation Pilot Plant (SNL93a) ................. 4A-13
            D.3.14      WIPP Procedure No. PAP03, "Parameter Selection
                        Quality Assurance Procedures (SNL93b)  ..........  4 A- 14
            D.3.15      WIPP Procedure No. PAP04, Analysis Quality
                        Assurance Procedures (SNL93c)  ...............  4 A- 14
            D.3.16      WIPP Procedure No. PAP05, Report Review Quality
                        Assurance Procedures (SNL93d)  ............... 4 A- 14
            D.3.17      WIPP Procedure No. PAP06, Use of Expert Judgement
                        Panel Quality Assurance Procedures (SNL93e)   ......  4A-15
            D.3.18      WIPP Active Procedures List (SNL93g)   ..........  4A-15
      APPENDIX 4B EPA QA Data Requirements  ..................... 4B-1
      APPENDDC 4C NRC QA Requkements Pertaining to Data ........  : . . . . 4C-1
      APPENDIX 4D Comparison Matrices of Quality Assurance Program
            Requkements and Guidance with ANSI/ASQC E4  ..........
5.  Issues for the Selection and Development of Models and Computer Codes            5-1
      5.1   Introduction ...........................                  s_i
      5.2   Compliance Assessment Modeling Objectives  .......       ....... 
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       5.3    Code-related Issues   	5-5
             5.3.1  Source Code Availability  	5-5
             5.3.2  History of Use  	5-6
             5.3.3  Quality Assurance  	5-6
             5.3.4  Hardware Requirements	5-13
             5.3.5  Mathematical Solution Methodology  	5-13
             5.3.6  Code Dimensionality	5-15
       5.4    Model Application	5-17
       5.5    References  	5-21

6.  Passive Institutional Controls	6-1
       6.1    Introduction	6-1
             6.1.1  Regulatory Background   	6-2
             6.1.2  General Background	6-3
       6.2    Permanent Markers	6-6
             6.2.1  Archeological Analogues  	6-7
             6.2.2  NRC Studies	  . 6-64
             6.2.3  NASA Studies	6-64
             6.2.4  NEA/OECD Studies	6-64
             6.2.5  DOE Studies	6-65
             6.2.6  No Marker Strategy  	6-78
       6.3    Public Records and Archives  	6-79
             6.3.1  Regulations	6-80
             6.3.2  Historical Perspective on Use and Survivability of Records  ....  6-80
             6.3.3  Survivability of Land Ownership Records	6-83
             6.3.4  Contemporary Examples of Lost Government Records  	6-91
             6.3.5  Format for Records   	6-97
       6.4    Government Ownership and Regulations  	6-98
             6.4.1  General Comments	6-98
             6.4.2  WIPP Land Withdrawal Act  	6-99
       6.5    Other Methods of Preserving Disposal System Knowledge  	6-100
             6.5.1  Subsurface Markers   	6-101
             6.5.2  Protective Barriers  	6-102
       6.6    References  	6-104
       Appendix 6A:       Federal Register Notice Identifying WIPP Land
                          Withdrawal Area	6A-1
       Appendix 6B:       Letter to U.S. Archivist Transmitting WIPP Land
                          Withdrawal Information   	6B-1

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                                        Tables

                                                                                 Page

2-1    WIPP WAC Parameters Relevant to Compliance Assessment	2-6
2-2    Waste Characterization Capabilities of TRU Waste Generators	2-8
3-1    Measures of the Central Point	3-24
3-2    Measures of Spread of Dispersion	3-26
3-3    Numerical Measures of Compliance  	3-27
3-4    Regulatory Status and Approach to Safety in Foreign
       Geologic Repositories	3-37
6-1    Isolation Times Prior to Drilling in the WIPP Site Area  	6-69
6-2    Probabilities of Marker System Persisting  Team A   	6-71
6-3    Consensus Probabilities of Marker System
       Persisting  Team B  	6-71
6-4    Probability of Correct Interpretation of Marker
       Message Intrusion by Mineral Exploration	6-74
                                         VI

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                                      Figures

                                                                               Page

2B-1  Example of the Use of Visual Examination (SC&A) and
      Process Knowledge (PK) to Assign Content Codes to
      Waste Containers	2B-6

2B-2  Sample Classification Error Matrix for Evaluating
      Accuracy of Process Knowledge Waste Content Code Assignments  	2B-7

2B-3  Classification Error Matrix of Counts for
      Waste Code Assignment	2B-8

2B-4  Classification Error Matrix of Proportions for
      Waste Content Code Assignments	2B-9
  t
2B-5  Classification Error Matrix of Proportions for
      Waste Content Code Assignments	2B-10

2B-6  Classification Error Matrix of Counts for Waste
      Content Code Assignments	2B-11

3-1    Ten Hypothetical LHS CCDFs, with Maximum  	3-19

3-2    Mean, 90th Percentile, and Median Curves
      from Set of 10 LHS CCDFs	3-20

6-1    Human Interference Logic Flow	:	6-5

6-2    ONWI conceptual Design of Site Markers for
      Geologic Repository	 6-67
                                         Vll

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                                     1.  Introduction

The U.S. Environmental Protection Agency (EPA) is responsible for developing and issuing
environmental standards and criteria to ensure that the public and environment are protected
from potential radiation impacts.  With these  objectives in mind, EPA is proposing criteria
for certifying compliance with the disposal standards in 40 CFR part 191, Environmental
Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and
Transuranic Radioactive Wastes.  The Agency will use these criteria in ascertaining whether
or not the Waste Isolation Pilot Plant (WIPP) complies with the disposal  standards in 40 CFR
part 191.

1.1    EPA Authorities for the Rulemaking

These  criteria are being developed pursuant to the Agency's authorities under the Waste
Isolation Pilot Plant Land Withdrawal Act (WIPP LWA) (Pub. L.  102-579).  The WEPP
LWA requires the Agency  to develop criteria to be used in certifying whether the WIPP
complies with the 40 CFR  part 191  disposal standards. 40 CFR part  191 was, in turn,
developed pursuant to the Agency's authorities under the Atomic Energy Act (AEA) of 1954,
as amended, and Reorganization Plan No. 3 of 1970 (NI70).  The basic authority under the
AEA,  as transferred to the  EPA by  the Reorganization Plan of 1970, includes the mandate to
establish:

       generally applicable environmental standards for the protection of the general
       environment from radioactive materials.  As used herein, standards mean
       limits on radiation exposures or levels, or concentrations or quantities of
       radioactive material, in the general environment outside the boundaries of
       locations under the control of persons  possessing or using radioactive
       materials.

The Nuclear Waste Policy Act (NWPA) of 1982 establishes formal procedures for evaluating
and  selecting sites for geologic repositories, including procedures for the interaction of State
and  Federal Governments;  reiterates the existing responsibilities of the Federal agencies
involved in the national program; and provides a timetable for several key milestones to be
met  by the Federal agencies carrying out the program.  As part of this national program, the
EPA, pursuant to its authorities under other provisions of law, is required to "by rule,
promulgate generally applicable standards for the protection of the general environment from
off-site releases from radioactive  material in repositories. "(NWPA83)

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 In December 1987, Congress enacted the Nuclear Waste Policy Amendments Act
 (NWPA87).  The 1987 Amendments Act redirected the nuclear waste program to consider
 Yucca Mountain, Jocated in Nevada, as the site for the nation's first high-level waste and
 spent nuclear fuel repository and to phase out activities at all other potential sites.  If Yucca
 Mountain is found to be suitable, the President is to submit a recommendation to Congress to
 develop a repository at the site. The Secretary of Energy is also required to inform Congress
 and the State of Nevada if the site characterization activities indicate that Yucca Mountain is
 unsuitable.  The Amendments Act prohibits the Department of Energy from conducting site-
 specific activities for a second repository unless authorized by Congress.  Finally, the Act
 established a commission to study the need and feasibility of a monitored retrievable storage
 facility as a complement to the nation's nuclear waste management program.  This
 commission submitted a report to Congress outlining its recommendations on November 1,
 1989 ;;RMRS89).

 Enacted in October 1992, the Waste Isolation Pilot Plant Land Withdrawal Act (WIPP LWA)
 reinstates the 1985 disposal  standards, except sections  191.15 and 191.16. The WIPP LWA
 directs EPA to issue final disposal standards and specifies that such regulations shall not be
 applicable to the characterization, licensing, construction, operation, or closure of any site
 required to be characterized under section 113(a) of the NWPA (Public Law 97-425).  Final
 disposal standards were issued by EPA on December 20,  1993, FR 58 66398-66416.

 1.2    History of the 40 CFR parts 191 and 194 Rulemakings

 Since the inception of the nuclear age in the 1940s, the Federal Government has assumed
 ultimate responsibility for the care and disposal of high-level radioactive wastes regardless of
 whether they are produced by commercial or national defense activities.   In 1949, the Atomic
 Energy Commission (AEC)  initiated research and development work aimed at developing
 systems for the conversion of high-level liquid wastes into a stable form.  Then, in 1955, at
the request of the AEC, a National Academy of Sciences - National Research Council (NAS-
NRC) Advisory Committee was established to consider the disposal of high-level radioactive
wastes within the United States. Its report (NAS57), issued in 1957,  recommended that:

       1.     The AEC continue to develop processes for the solidification of high-
             level radioactive  liquid wastes, and

      2.     Naturally occurring salt formations are the most promising medium for

                                         1-2

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             the long-term isolation of these solidified wastes.

Project Salt Vault^ conducted from 1965  to 1967 by the AEC in an abandoned salt mine near
Lyons, Kansas, was initiated to demonstrate the safety and feasibility of handling and storing
solid wastes in salt formations  (MC70).

In 1968, the AEC again asked  the NAS-NRC to establish a Committee on Radioactive Waste
Management (CRWM) to advise the AEC concerning its long-range radioactive waste
management plans and to evaluate the feasibility of disposing of solidified radioactive wastes
in bedded salt.  The CRWM convened a  panel to discuss the disposal of radioactive wastes in
salt mines. Based on  the recommendations of the panel, the CRWM concluded that bedded
salt is satisfactory for  the disposal of radioactive wastes (NAS70).

In 1970, the AEC announced the tentative selection of a site at Lyons, Kansas, for the
establishment of a national radioactive waste repository (AEC70).  During the next two
years, however,  in-depth site studies raised several questions concerning the safe plugging of
old exploratory wells and proposed expanded salt mining activities. These questions and
growing public opposition to the Lyons site prompted the AEC in  late 1971 to pursue
alternatives (DO72).

In 1976, the Federal Government intensified its program to develop and demonstrate a
permanent disposal method  for high-level radioactive wastes.  The Office of Management and
Budget (OMB) established an interagency task force on commercial wastes in March of that
year.  The OMB interagency task force defined the responsibility of each Federal agency
involved in high-level  waste management, including the preparation of environmental
standards  for high-level wastes by the EPA (LY76, EN77a, EN77b).

A status report on the management of commercial radioactive nuclear wastes, published in
May 1976 by the President's Federal Energy Resources Council (FERC),  emphasized the
need for coordination  of administration policies and programs relating to energy.  The FERC
established a nuclear subcommittee to coordinate Federal nuclear policy and programs to
assure an  integrated government effort.  This report called for an accelerated comprehensive
government radioactive waste program plan and recommended the formation of an
interagency task  force to coordinate activities among the responsible Federal agencies. The
EPA was  given the responsibility of establishing general environmental  standards governing
waste disposal activities (FERC76).

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In 1976, President Ford issued a major policy statement on nuclear waste.  As part of his
comprehensive statement, he announced new steps to assure that the United States would
have facilities for'the long-term management of nuclear waste from commercial power
plants.  The President's actions were based on the findings of the OMB interagency task
force formed in March 1976.  He announced  that the experts had concluded that the most
practical method for disposing  of high-level radioactive wastes is in geologic repositories
located in stable formations deep underground.  EPA's responsibilities included issuing
general environmental standards governing nuclear waste facility releases to the biosphere
above natural background radiation levels (FO76). These standards were to place a
numerical limit on long-term radiation  releases outside the boundary of the repository.

In December 1976, the EPA announced its intent to develop environmental radiation
protection criteria for radioactive wastes to assure the protection of public health and the
general environment (EPA76).  These efforts  resulted in a series of radioactive waste
disposal workshops, held in 1977 and 1978 (EPA77a, EPA77b, EPA78a, EPA78b).

In 1978, President Carter established the Interagency Review Group (IRQ) to recommend an
administrative policy for addressing the long-term management of nuclear waste and
programs that would support the policy.  The IRQ report re-emphasized EPA's role in
developing generally applicable standards for the disposal of high-level wastes, spent nuclear
fuel, and transuranic wastes (DOE79).  In a message to Congress on February 12, 1980, the
President outlined the content of a comprehensive national radioactive waste management
program  based on the IRG recommendations.  The message called for an interim strategy for
disposal of high-level and transuranic wastes that would rely on mined geologic repositories.
The message repeated that the EPA was responsible for creating general criteria and
numerical standards for nuclear waste management activities (CA80).

In November 1978, the EPA published proposed "Criteria for Radioactive Wastes," which
were intended as Federal Guidance for storage and disposal of all forms of radioactive wastes
(EPA78c).  In March 1981, however, the EPA withdrew the proposed criteria because the
many different types of radioactive wastes made the issuance of generic disposal guidance too
problematic (EPA81).

In 1982,  under the authority of the Atomic Energy Act of 1954, the EPA proposed a set of
standards under 40 CFR Part 191, "Environmental Standards for the Management and
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Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes" (EPA82).
Shortly  after the publication of the EPA's proposed rule, Congress passed the Nuclear Waste
Policy Act of 1982 (Public Law 97-425), wherein the EPA was to "...promulgate generally
applicable standards for the protection of the general environment from off-site releases from
radioactive material in repositories..." not later than January 1984 (NWPA83).

After the first comment period on the proposed rule ended on May 2, 1983, the EPA held
two public hearings on the proposed  standards-one in Washington, D.C., on May 12-14,
1983, and one in Denver, CO, on May 19-21, 1983-and during a second public comment
period requested post-hearing comments (EPA83a, EPA83b).  More than 200 comment
letters were received during these two comment periods, and 13 oral statements were made at
the public hearings. Responses to comments received from the public were subsequently
published  and released in August 1985 (EPA85a).

In parallel with its public review and comment effort, the Agency conducted an independent
scientific review of the technical basis for the proposed 40 CFR Part 191 standards through a
special Subcommittee of the Agency's Science Advisory Board (SAB).  The Subcommittee
held nine public meetings from January 18, 1983, through  September 21, 1983, and later
prepared and released a final report on February 17, 1984  (EPA83c, SAB84).  Although the
SAB review found that the Agency's  analyses in support of the proposed standards were
comprehensive and scientifically competent, the report contained several recommendations
for improvement.  The report was publicly released on May 8, 1984, and the public was
encouraged to comment on the findings and recommendations (EPA84).  Responses to the
SAB report were subsequently presented and released in August 1985 (EPA85b).

On February 8, 1985,  the Natural Resources Defense Council, the Environmental Defense
Fund, the  Environmental Policy Institute, the Sierra Club,  and the Snake River Alliance
brought suit against the Agency and the Administrator because they had failed to comply
with the January 7,  1984, deadline mandated by the NWPA for promulgation of the
standards.  A consent order was negotiated with the plaintiffs that required the standards to
be promulgated on or before August  15, 1985.  The EPA issued the final rule under 40 CFR
part 191 on that date (EPA85c, EPA85d, EPA85e).

The EPA  standards were divided into two main sections, Subparts A and B. Subpart A
addressed  the management and storage of waste.  For any  disposal facility operated by the
                                         1-5

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Department, of Energy and not regulated by the Nuclear Regulatory Commission or by
Agreement States, under Subpart A of the standard, the exposure limits to any member of the
general public were 25 millirem (mrem) to the whole body and 75 mrem to any critical
organ.  For facilities regulated by the Nuclear Regulatory Commission or Agreement States,
the standards  adopt the annual dose limits given in 40 CFR Part 190, the environmental
standards for  the uranium fuel cycle:  25 mrem to the whole body, 75 mrem to the thyroid,
and 25 mrem  to the critical organ.

Subpart B imposed limits on the release of radioactive materials into the environment
following closure of the repository.  The key provisions of Subpart B were:

       •      Limits on cumulative releases of radioactive materials  into the
             environment over 10,000 years;

       •      Assurance requirements to compensate for uncertainties in achieving the
             desired level of protection;

       •      Individual exposure limits based on the consumption of groundwater
             and any other potential exposure pathways for 1,000 years after
             disposal; and

       •      Ground-water protection requirements in  terms of allowable
             radionuclide concentrations and associated doses for 1,000 years  after
             disposal.

Sections 191.15 and 191.16 of Subpart B limited the annual dose to any member of the
general public to 25 mrem to the whole body and 75 mrem to any critical organ.  The
groundwater concentration for beta or gamma emitters was limited to the equivalent yearly
whole body or organ dose  of 4 mrem. The allowable water  concentration for alpha emitters
(including radium-226 and radium-228, but excluding radon) was 15 picocuries/liter.  For
radium-226 and radium-228 alone, the concentration limit was 5 picocuries/liter.  Appendix
A of the standards provided cumulative release limits for radionuclides.

In March 1986, five environmental groups led by the Natural Resources Defense Council and
four States filed petitions for a review of 40 CFR Part  191 (USC87).  These  suits were
consolidated and argued in the U.S. Court of Appeals for the First Circuit in Boston.  The
main challenges concerned:
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       1.     Violation of the Safe Drinking Water Act (SDWA) underground
             injection requirements;

       2.     Inadequate notice and comment opportunity on the ground-water
             protection requirements; and

       3.     Arbitrary standards, not supported in the record or not adequately
             explained.

In July  1987, the Court rendered its opinion and noted three findings against the Agency and
two favorable judgments.  The Court's action resulted in the remand of the standards.  The
Court began by looking at the definition of "underground injection," which is  the "subsurface
emplacement of fluids by well injection."  A "well" is defined by the SDWA and the EPA as
a shaft "bored,  drilled, or driven where the depth is greater than the largest surface
dimension."  A "fluid" is a material or substance that flows or moves whether in a semi-
solid, sludge, gas, or any other form or state."  In the view of the Court, the  method
envisioned by DOE for disposal of radioactive wastes in underground repositories might fit
both of the latter definitions and would "likely constitute an underground injection under the
SDWA."  Under the SDWA, the Agency is required to assure that underground sources of
drinking water will not be endangered by any underground injection. With regard to such
potential endangerment, the Court  supported part, but not all,  of the Agency's approach.

A dichotomy appeared when endangerment was considered inside the "controlled area"
versus beyond the controlled area (i.e., in the accessible environment).  Inside the controlled
area,  the Court ruled that endangerment of groundwater was permitted. Therefore, the
EPA's approach of using the geological formation as part of the containment was valid.
However, outside the controlled area where endangerment would not be permitted, the Court
found that Section 191.15 as promulgated would endanger drinking water supplies.  In the
context of the SDWA, "endangerment" occurs when doses are higher than that allowed by
the Primary Drinking Water Regulations.  Section  191.15 permits an annual dose of 25
mrem to the whole body and 75 mrem to any critical organ from all pathways.  On the other
hand, the  regulations under the SDWA allow  only  4 mrem doses from drinking water.  The
Court recognized that less than 4 mrem may result from the groundwater pathway; however,
it rejected this possibility because the Agency stated  that radioactivity may eventually be
released into the groundwater system  near the repository which could result in substantially
higher doses. Therefore, the Court decided that a large fraction  of the 25 mrem could be
received through  the groundwater exposure pathway.  Accordingly,  the Court found that the
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high-level waste standards should have been consistent with the SDWA, or the Agency
should have explained that a different standard was adopted and then justified its position.

The Court also noted that the Agency was not necessarily incorrect in promulgating the
proposed standards, but the Agency never acknowledged the interrelationship of the SDWA
and HLW rules nor did it adequately explain the divergence between them.  The Court also
supported the petitioner's argument that the Agency arbitrarily selected the 1,000-year limit
for individual protection requirements (Section 191.15) under undisturbed performance.  The
Court indicated that the 1,000-year criterion is not inherently flawed, but the administrative
record and the Agency's explanations did not adequately support this choice.  The criterion
was remanded for reconsideration and a more thorough explanation for its basis. Finally, the
Court found that the Agency did not provide sufficient opportunity for notice and comments
on  Section 191.16 (Ground-water Protection Requirements) since that section was added  to
Subpart B after the standards were proposed. This section was remanded for a  second round
of notice and comments.

In August 1987, the Justice Department asked the First Circuit Court to reinstate all of 40
CFR Part 191  except for Sections 191.15 and 191.16, which were originally found defective.
The Natural Resources Defense Council filed an opposing opinion. The Court then issued  an
Amended Decree that reinstated Subpart  A, but continued the remand of Subpart B.

On October  30, 1992, the President signed the WIPP LWA.  This Act reinstates Subpart B
of 40 CFR Part 191, except Sections 191.15 and 191.16, and requires the Administrator to
issue final disposal standards.  The reinstatement of these regulations does not apply to the
characterization, licensing, construction,  operation, or closure of any site required to be
characterized under the NWPA Section 113(a) of Public Law 97-425. On December 20,
1993 EPA issued amendments to 49 CFR part 191. The amended standards  represent  the
Agency's response to the above legislation and to the issues raised by the court pertaining to
individual and ground-water requirements.  In so doing, EPA did not revisit  any of the
regulations reinstated by the
WIPP LWA.

1.3    The WIPP Land Withdrawal Act

The WIPP LWA provides major new authority to EPA and requires significant additional
efforts.  It sets out a series of tasks that must be completed before DOE can  bring  waste to

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the WIPP to use in any tests requiring actual transuranic wastes (the test phase), as well as
requirements for the emplacement of waste (the disposal phase) and requirements for the
phase beginning with the end of the disposal phase and ending when all shafts at the WIPP
have been back-filled and sealed (the decommissioning phase.)  The test phase tasks include
promulgation of the final standard, review of the test plan, review of the retrieval plan, and a
final determination that the Secretary has complied with the terms and conditions of the final
No-Migration Determination(EPA90).  The disposal phase tasks include the requirement for
EPA to issue criteria for certification of compliance with 40 CFR Part 191 and to review the
DOE application for certification (GA93).  These tasks are summarized below.

1.3.1  Promulgation of Final 40 CFR  Part 191

The WIPP LWA calls for EPA to promulgate final 40 CFR part 191  standards.  Because of
the congressional action reinstating certain provisions of the rule as it was promulgated in
1985, and the very short promulgation time allowed, the Agency addressed only the two
areas that the court found questionable, i.e., individual and ground-water protection
standards.  The final rule was promulgated by EPA on December 20, 1993, and the
individual and ground-water protection standards are codified in Subparts B and C,
respectively (EPA93).

1.3.2 Test Phase Plan Review

The LWA requires DOE to submit a WIPP test phase plan to the EPA within 7 months of
the enactment of the law. In this  plan, DOE must describe those experiments that it plans to
conduct at the WIPP,  especially those  involving the use of actual transuranic waste. The law
requires EPA to review  and approve or disapprove the plan, by rule,  within 10 months of
enactment. The Act further specifies that the criterion to be used by  EPA in evaluating the
plan is whether the experiments will provide data that are directly relevant to a certification
of compliance with the radioactive waste disposal regulations or to compliance with the Solid
Waste Disposal Act.   On October 21,  1993 DOE announced that they would not proceed
with tests with radioactive wastes  at WIPP.  Information required to develop a compliance
application would be obtained through experiments conducted in laboratories.
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 1.3.3 Retrieval Plan Review

 The DOE is also required to submit to the EPA within 7 months of enactment a retrieval
 plan. In this plan, the Department must explain how it will retrieve all the transuranic waste
 from the WIPP if health and safety problems emerge during the test phase, or if the WIPP
 site cannot meet the applicable standards.  The EPA was to review and approve or
 disapprove this plan in the same rulemaking where it considered the test plan.

 1.3.4 Compliance with the Radioactive Waste Disposal Standards

 Having actual implementation/enforcement authority over a DOE radioactive waste disposal
 activity is a new role for EPA.  The law requires the EPA to certify, by rule, that the WIPP
 site will comply with the radioactive waste disposal standards before DOE can emplace any
 waste for disposal.  To make this determination, the EPA must first promulgate criteria for
 such certification of compliance.  These compliance criteria will be codified as 40 CFR part
 194.

 The DOE must submit an application for disposal within 7 years of first emplacement of
 waste for the test phase.  The  EPA then has 1 year to review the application and make a
 determination.  If the EPA has not come to a positive decision on certification after 10 years
 from first emplacement of waste for  the test phase, the DOE must implement the retrieval
plan. If there is a test phase, the EPA may extend the 10-year process for not more than 2
years if it determines that more time is necessary to complete the rulemaking.

The DOE must also submit documentation of continued compliance with the final disposal
regulations not later than 5 years after the initial receipt of transuranic waste for disposal at
the WIPP.  The EPA then has 6 months to review the documentation and make a re-
determination of compliance.  This documentation and re-determination process must then be
reinitiated every five years thereafter until the end of the decommissioning phase.

 1.3.5 No-Migration Determination

Much of the waste proposed for disposal in the WIPP is mixed waste, i.e., waste that is
subject to both the Atomic Energy Act and the Resource Conservation and Recovery Act
(RCRA).  Such waste must meet provisions of both laws. Before transuranic waste can be
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brought to the WIPP for test phase activities, the EPA must determine that the provisions and
conditions of the RCRA no-migration determination have been met.  A conditional no-
migration determination for the test phase was granted by EPA on November 14,  1990.  This
conditional determination must be amended and formal approval granted before disposal of
radioactive waste can begin.


1.3.6 Other EPA Activities


The EPA is required by the LWA to perform several other activities.  There are other LWA
EPA responsibilities including but not necessarily limited to those described below.


       •     DOE must consult with the Agency on a study of remote-handled waste, to
             evaluate  the impact of these wastes, as compared to just the contact-handled
             waste, on the performance assessment.

       •     Every 2  years, the DOE must submit a test phase performance report giving
             the Department's latest evaluation of the site characterization and the WIPP's
             potential performance.  EPA must review  and comment on these reports within
              120 days.

       •     Every 2  years after enactment, the DOE must prepare documentation that it is
             complying  with all applicable environmental statutes, including 40 CFR 191
             Subpart A, RCRA, the Clean Air Act, the Solid Waste Disposal Act, the Safe
             Drinking Water Act, the Toxic Substances Control Act, and the
             Comprehensive Environmental Response,  Compensation, and Liability Act
             (CERCLA, or Superfund).  The EPA, or State if applicable, must make a
             determination within 6 months after receipt of the documentation as to whether
             the DOE is complying.

       •     Not later than September 30,  1993, and every year thereafter, the EPA must
             report to Congress on the status of and resources required for fulfillment of its
             responsibilities under the WIPP LWA.

       •     Five years  after first disposal of waste at WIPP and every five years thereafter
             until the  end of the decommissioning phase,  DOE shall submit to the Agency
             for review  and approval documentation that WIPP remains in compliance with
             40 CFR  191 Subpart B and C. After receiving a submission,  EPA  must
             determine whether or not the WIPP continues to be in compliance with the
             final disposal regulations.  The Agency shall make this determination within 6
             months after receipt of documentation.
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1.4    Purpose and Scope of the Background Information Document


This document provides the necessary background information, technical analyses, and
justifications in support of the proposed criteria for certifying and determining compliance
with 40 CFR part 191, Environmental Standards for the Management and Disposal of Spent
Nuclear Fuel and High-Level and Transuranic Radioactive Wastes.


The scope of this Background Information Document includes evaluation of five broad issues
considered by the EPA in developing the proposed compliance criteria. This material is
arranged as shown in the following descriptions of the chapters:


       •     Chapter 2   A review of the DOE TRU waste characterization program,
             including the use of process knowledge, a*d options for waste characterization.

       •     Chapter 3   A discussion of a finding of "reasonable expectation"  of
             compliance as required in 40 CFR part 191. Options considered in defining
             "reasonable expectation" are presented  and evaluated.

       •     Chapter 4 - An assessment of criteria for evaluating and ensuring  the
             soundness of the  DOE Quality Assurance (QA) program as it relates to site
             characterization,  data gathering,  data analysis, and data modeling at WIPP.
             DOE, EPA, NRC,  and other QA guidance are examined.

       •     Chapter 5  A discussion of criteria  options for assuring the use of appropriate
             models in the WIPP compliance  assessment.
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                                         1.5  References
AEC70

CA80


DOE79


DO72
EN77a
EN77b
EPA76
EPA77a
EPA77b
EPA78a
Atomic Energy Commission Press Release No. N-102, dated June 17, 1970.

The White House, President J. Carter, The President's Program on
Radioactive Waste Management, Fact Sheet,  February 12, 1980.

Department of Energy, Report to the President by the Interagency Review
Group on Nuclear Waste Management, Report No. TID-29442, March 1979.

Doub, W.O., U.S. Atomic Energy Commission Commissioner, Statement
before the Science, Research and Development Subcommittee for the
Committee on Science and Astronautics, U.S. House of Representatives, U.S.
Congress,  Washington, D.C., May 11 and 30, 1972.

English, T.D., et al., An Analysis of the Back End of the Nuclear Fuel Cycle
with Emphasis on High-Level Waste Management, JPL Publication 77-59,
Volumes I and n, Jet Propulsion Laboratory, Pasadena, California, August 12,
1977.

English, T.D., et al., An Analysis of the Technical Status of High-Level
Radioactive Waste and Spent Fuel Management Systems, JPL Publication 77-
69 v Jet Propulsion Laboratory, Pasadena, California, December 1, 1977.

Environmental Protection Agency, Environmental Protection Standards for
High-Level Wastes - Advance Notice of Proposed Rulemaking, Federal
Register, 41  FR 53363, December 6, 1976, August 1985.

Environmental Protection Agency, Proceedings: A Workshop on Issues
Pertinent to the Development of Environmental Protection Criteria for
Radioactive Wastes, Reston, Virginia, February 3-5,  1977, Office of Radiation
Programs, Report ORP/SCD-77-1, Washington, D.C., 1977.

Environmental Protection Agency, Proceedings: A Workshop on Policies  and
Technical Issues Pertinent to the Development of Environmental Protection
Criteria for Radioactive Wastes,  Albuquerque, New  Mexico, April 12-17,
1977, Office of Radiation Programs, Report ORP/SCD-77-2, Washington,
D.C.,  1977.

Environmental Protection Agency, Background Report - Consideration of
Environmental Protection Criteria for Radioactive Wastes, Office of Radiation
Programs, Washington,  D.C., February 1978.
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EPA78b      Environmental Protection Agency, Proceedings of a Public Forum on
             Environmental Protection Criteria for Radioactive Wastes, Denver, Colorado,
             March 30 - April 1, 1978, Office of Radiation Programs, Report ORP/SCD-
             78-2, Washington, D.C., May 1978.

EPA78c      Environmental Protection Agency, Recommendations for Federal Guidance,
             Criteria for Radioactive Wastes, Federal Register, 43 FR 53262-53268,
             November 15, 1978.

EPA81       Environmental Protection Agency, Withdrawal of Proposed Regulations,
             Federal Register, 46 FR 17567, March 19, 1981.

EPA82       Environmental Protection Agency, Proposed Rule, Environmental Standards
             for the Management and Disposal of Spent Nuclear Fuel, High-Level and
             Transuranic  Radioactive Wastes, Federal Register, 47 FR 58196-58206,
             December 29, 1982.

EPA83a      Environmental Protection Agency, Environmental Standards for the
             Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic
             Radioactive Wastes, Notice of Public Hearings, Federal Register, 48 FR
             13444-13446, March 31, 1983.

EPA83b      Environmental Protection Agency, Environmental Standards for the
             Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic
             Radioactive Wastes, Requests for Post-Hearings Comments, Federal Register,
             48 FR 23666, May 26, 1983.

EPA83c      Environmental Protection Agency, Science Advisory Board Open Meeting:
             High-Level Radioactive Waste Disposal Subcommittee, Federal Register,
             48 FR 509, January 5, 1983.

EPA84       Environmental Protection Agency, Environmental Standards for the
             Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic
             Radioactive Wastes, Notice of Availability, Federal Register, 49 FR 19604-
             19606, May 8,  1984.

EPA85a      Environmental Protection Agency, High-Level and Transuranic Radioactive
             Wastes - Response to Comments  for Final Rule, Volume I, Office of
             Radiation Programs, EPA 520/1-85-024-1, Washington, D.C., August  1985.

EPA85b      Environmental Protection Agency, High-Level and Transuranic Radioactive
             Wastes   Response to Comments for Final Rule, Volume n, Office of
             Radiation Programs, EPA 520/1-85-024-2, Washington, D.C., August  1985.
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EPA85c      Environmental Protection Agency, High-Level and Transuranic Radioactive
             Wastes - Background Information Document for Final Rule, Office of
             Radiation Programs, EPA 520/1-85-023, Washington, D.C., August 1985.

EPA85d      Environmental Protection Agency, Final Regulatory Impact Analysis  40 CFR
             Part 191: Environmental Standards for the Management and Disposal of Spent
             Nuclear Fuel, High-Level and Transuranic Radioactive Wastes, Office of
             Radiation Programs, EPA 520/1-85-027, Washington, D.C., August 1985.

EPA85e      Environmental Protection Agency, 40 CFR Part 191, Environmental Standards
             for the Management and Disposal of Spent Nuclear Fuel, High-Level and
             Transuranic Radioactive Wastes; Final Rule, 50 FR 38066-38089.  September
             19, 1985.

EPA93       Environmental Protection Agency, Environmental Radiation Protection
             Standards for the Management and Disposal of Spent Nuclear Fuel, High-level
             and Transuranic Wastes, Federal Register, 58 FR 66398-66416. December 20,
             1993.

FERC76      Federal Energy Resources Council, Management of Commercial Radioactive
             Nuclear Wastes - A Status Report, May 10, 1976.

FO76        The White House, President G. Ford, The President's Nuclear Waste
             Management Plan, Fact Sheet, October 28, 1976.

GA93        Galpin, Floyd L., Weinstock, L.G., and Gruhlke, J.M., New Directions for
             EPA's High-Level Waste Standards, Proceedings of the 1993 International
             High-Level Waste Conference, Las Vegas, Nevada, April 26-30, 1993.

LY76        Memorandum from J.T. Lynn, OMB to R. Train, EPA; R. Peterson, CEQ; R.
             Seamans, ERDA, and W. Anders, NRC; March 25, 1976,  Concerning the
             Establishment of an Interagency Task Force on Commercial Nuclear Wastes.

MC70        McClain, W.C., and R.L. Bradshaw, Status of Investigations of Salt
             Formations for Disposal of Highly Radioactive Power-Reactor Wastes,
             Nuclear Safety,  11 (2): 130-141, March-April 1970.

NAS57       National Academy of Sciences -. National Research  Council, Disposal of
             Radioactive Wastes on Land, Publication 519, Washington, DC,  1957.

NAS70       National Academy of Sciences - National Research  Council, Committee on
             Radioactive Waste Management, Disposal of Solid Radioactive Wastes in
             Bedded Salt Deposits, Washington, D.C., November -1970.
                                        1-15

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NI70         The White House, President R. Nixon, Reorganization Plan No. 3 of 1970,
             Federal Register, 35 FR 15623-15626, October 6, 1970.

NWPA83     Nuclear Waste Policy Act of 1982, Public Law 97-425, January 7, 1983.

NWPA87     Nuclear Waste Policy Amendments Act of 1987, Public Law 100-203,
             December 22,  1987.

RMRS89     Nuclear Waste: Is There A Need For Federal Interim Storage? Report of the
             Monitored Retrievable Storage Review Commission, November 1, 1989.

SAB84       Report on the Review of Proposed Environmental Standards for the
             Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic
             Radioactive Wastes (40 CFR Part 191), High-Level Radioactive Waste
             Disposal Subcommittee, Science Advisory Board, U.S. EPA, Washington,
             D.C., January  1984.

USC87       United States Court of Appeals for the First. Circuit, Natural Resources
             Defense Council, Inc., et al., vs United States Environmental Protection
             Agency,  Docket No.: 85-1915, 86-1097,  86-1098, Amended Decree,
             September 23,  1987.
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                                2.  Waste Characterization

2.1    Identification of TRU Waste Characteristics Potentially Relevant to Compliance
       Assessment

One of the cornerstones of the WIPP compliance assessment is the set of assumptions about
the character of the waste proposed to be emplaced in the disposal system.  Many of the
potential pathways for radioactive releases from the disposal system may be directly affected
by the radiological, chemical and physical composition of the waste.  The following is a
summary of the categories of key waste characteristics from the 1992 WIPP compliance
assessment (SNL92).

2.1.1  Radionuclide Inventories

The TRU waste radionuclide inventory is a fundamental variable for compliance assessment.
It is the quantity of radionuclides potentially available for release to the accessible
environment.  Data on radionuclide composition (fractional  abundance of each radionuclide)
are necessary because differences in  solubility, mobility, and half-life determine the fraction
of the inventory of a radionuclide that reaches the accessible environment in a given
scenario.  The uranium radionuclides (U-233 and U-234) provide a good example of the
significance of radionuclide composition in analyzing radionuclide migration to the accessible
environment.  In the 1992 compliance assessment, U-233 and U-234 were estimated to
comprise about 0.06 percent of the initial inventory, yet they accounted for several percent of
the projected discharge to the accessible environment. Accurate determination of the
uranium  inventory is thus very important even though its quantity  is minor compared to that
of the plutonium and americium radionuclides.

If the radionuclide inventory includes fissile  material, criticality may be a concern.
Criticality is a self sustaining nuclear fission chain reaction  in a material such as uranium or
plutonium generating enormous quantities of energy.  A system cannot become critical unless
the fissile material is very densely packed.  For criticality to occur in the WIPP, fissile
material  would have to move to  a common point.  Neither the possible phenomena which
might cause this agglomeration nor the effect of such a chain reaction  far from the accessible
environment have been thoroughly evaluated to. date.
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Another inventory-related consideration is thermal power.  Thermal power is the generation
of heat by the spontaneous decay of radioactive material; a different process than nuclear
fission.  Unlike criticality, the density of the radioactive material is not directly relevant to
its thermal power.  It is currently addressed in the WIPP analyses only as a transportation
criterion. Its significance to compliance assessment is unknown.

2.1.2  Actinide Solubility

Actinide solubility in the Castile or Salado brines that may be in contact with the waste is
generally thought to be one of the most important parameters for calculating releases to the
accessible environment.

Solubility is poorly understood, and there is considerable uncertainty in estimating the
solubility of plutonium, americium, and uranium in unmodified waste forms. In addition to
pure solubility  (where solid material is dissolved in the liquid) which can be affected by brine
salinity, pH, Eh,  and the presence of chelating agents and other chemical constituents,  there
are concerns and  greater uncertainty about the possible concentrations of colloidal dispersions
(very fine particles in the 0.001 to 0.1 /*m diameter range that can be suspended in the
liquid).  Ongoing laboratory experiments  sponsored by  DOE on actinide solubility may or
may not be able to narrow the estimated range for actinide solubility under disposal
conditions.

2.1.3  Gas Generation

Volatile organic compounds (VOCs) present in TRU waste can vaporize after disposal  in a
disposal system and create a potential  problem for compliance.  Gases other than VOCs are
also expected to be generated in  the waste from corrosion, microbial activity, and radiolysis.
These processes are expected to produce  gases in much greater quantities than VOCs present
in the waste and are a principal concern in compliance  assessment.

One concern related to generated gases is the  combined effect on waste storage room closure
and brine inflow.   The resulting pressure  from significant gas generation could retard the
rates of both room closure and brine inflow.  In the absence of any gas generation there
would be no retardation of room closure  rates or brine  inflow by gas pressure. However,
the  precise values of room closure and brine inflow  rates in the presence or absence of gas
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pressure from gas generation are unknown.

An analysis of the combined effect of room closure and brine inflow is an analysis of which
occurs first.  If complete closure occurs before brine inflow, the enclosed space's very low
permeability and porosity would effectively minimize any future brine inflow and mixing
with waste.  The amount of contaminated brine that would be available for release by human-
initiated processes and events would thus be minimal.  Conversely, if brine inflow occurs
before complete room closure, there could be significant mixing of disposal system contents
with brine, providing a significant amount of contaminated brine available for release by
human-initiated processes and events.

Another concern regarding  gas generation is the effect on the geologic integrity of the
disposal system.  If the gas pressure within the disposal system were to exceed lithostatic
pressure, the amount of room void space could actually expand, or fracturing could be
induced in anhydrite marker beds above or below the rooms.  The fractures could provide
significant new pathways for the migration of radionuclides to the accessible environment.

At this stage of compliance assessment  there are  too many unknowns regarding the effects of
gas generation to reach supportable conclusions; the net effect is indeterminate.  Significant
gas generation could have either a positive or negative effect on disposal system
performance.

Waste characteristics will affect gas generation rates and processes.  The amount of gas
generated by corrosion is directly related to the quantity and  type.of metals present in waste
and waste containers, the surface area of the waste,  and available moisture. The amount of
gas generation by microbial activity is related to the amount  of available moisture and
cellulosic material (e.g., paper, cloth, and wood). Radiolytic gas generation quantities are a
function of the amounts of alpha radioactivity, moisture, and cellulosic material.  Future
studies may show that minimization of liquids is necessary to reduce gas generation from
microbial degradation and corrosion. It appears that initial liquid saturation in  the waste may
be an important parameter because of its effect on gas generation.

2.2    Programs and Methods

The adequacy of the waste  characterization program depends upon its  ability to demonstrate
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that the waste which goes into the disposal system conforms to the assumptions of the
compliance assessment.

This section presents an overview of the DOE management structure and waste
characterization program, followed by a discussion of the ability of the current system to
assess the waste parameters.

2.2.1 DOE Management Structure

The Office of Environmental Restoration and Waste Management is responsible for the
overall management of waste management within DOE. Direct management respon.vbility
for storage,  treatment and disposal of TRU waste falls under EM-30, Office of Waste
Management.  Other DOE offices with responsibilities for waste characterization under EM-
30 include:

       EM-32  Office of Waste Operations
       EM-35 - Office of Technical Support
       EM-34  Office of Waste Management Projects
       DOE/CAO  Carlsbad Area Office
       DOE Site Offices

The WIPP Quality Assurance Program  Plan delineates areas of responsibility among EM-30
offices.

The Waste Acceptance Certification Committee (WACC) is responsible for developing the
WIPP Waste Acceptance Criteria (WAC) and verifying the certification of TRU waste at the
generator/storage facilities for compliance with the WAC through  audits and surveillance.
However, instead of being incorporated in the waste characterization process prospectively
(as  it occurs at the TRU waste generators), this function is used as an auditing tool
retrospectively (to certify waste that has already been generated).  The TRU waste generator
sites differ in their approach to waste characterization.

2.2.2 DOE WIPP Waste Acceptance Criteria (WAC)

The Department of Energy has developed criteria for the characterization  of waste used in
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the WIPP experimental waste program.  The relationship between the Waste Characterization
Program Plan (WCPP) for WTPP Experimental Waste, the test requirements, the Quality
Assurance Program Plan for the WIPP Experimental Waste Characterization Program, and
the generator and/or storage site Quality Assurance Project Plans (QAPjPs) is identified in
Revision 4 of the WIPP Waste Acceptance Criteria (WAC) Document (WTPP-DOE-069) of
December 1991. The WCPP summarizes the waste characterization requirements for the
bin-scale and alcove tests that were designed to evaluate gas generation rate and gas
generation potential under e \pected disposal system conditions using TRU waste. The
proposed bin-scale  and alcu. e tests have since been canceled.

The Department of Energy published the first WIPP Waste Acceptance Criteria  (WAC)
Document (WEPP-DOE-069) in 1980.  The waste acceptance criteria  in that document were
developed to ensure the safety of all operations at the WEPP. The document was intended to
provide: (1) criteria for use in project design; (2) documentation of the technical justification
for the WAC; and  (3) quantitative guidelines to be used by waste generators.  The criteria do
not specifically  stipulate whether further waste treatment or processing will be required, but
DOE recognized that this decision will have to be made in the future.

Revision 4 of the WAC (DOE91) included additional criteria relevant to waste transportation
and to  regulatory requirements for hazardous  waste in order to provide a single,
comprehensive document for all parties involved  with thง  shipment and handling of WIPP
waste.   In Table 3-1 of Revision 4, DOE listed the WAC  limiting parameters and the source
for these parameters; this information appears as  Appendix 2A to this section.  The
parameters from Table 3-1 of Revision 4 that are relevant to compliance assessment (CA) are
listed here in Table 2-1.

2.2.3  Overview of Characterization Methods

The controlling document for TRU waste characterization is the  Waste  Characterization
Program Plan for the  Waste Isolation Pilot Plant, Revision 2.0 (WCP92).  According to this
document, TRU waste characterization refers  to the sampling and analysis of TRU waste
and/or the examination of TRU waste generation documentation  and associated records to
demonstrate compliance with the requirements of the WIPP Waste Acceptance Criteria
(WIPP WAC).  The WIPP WAC. were developed to consolidate  the waste requirements of
the regulations governing the WIPP: DOE Order 5820.2A, 10 CFR part 61, 40 CFR part
                                         2-5

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                                    TABLE 2-1
              WIPP WAC Parameters Relevant to Compliance Assessment
    Parameters
                         Relevance
Waste Containers
Not currently relevant; results of corrosion studies may require
future changes to non-corroding types of container material.
Immobilization
Criterion set primarily to limit air dispersion; relevant to CA
because it can reduce mobility in storage room brine or in
drilling mud.
Liquids
Criterion set to minimize release during container handling and
corrosion; relevant to CA because moisture in waste disposal
room increases gas generation and radionuclide leaching.
Compressed Gases
Criterion set for personnel safety and container integrity;
relevant to CA as a contributor to gas concentration in disposal
room.
Activity in Curies
Lower limit defines TRU, upper limit for RH-TRU precludes
HLW disposal; important information needed for CA inventory.
Nuclear Criticality
Transportation and disposal system criterion; important to CA
because of potential post-closure incidents and requirements for
radionuclide analysis.
Pu-239 Equivalent
Activity
Operational safety and long-term criterion; important to CA
because of direct drilling scenario.
Thermal Power
Transportation criterion; useful to CA because a determination
of thermal power requires radionuclide analyses which could be
used to determine radionuclide inventory.
Gas Generation
A number of waste characteristics have an impact on gas
generation. Potentially very important to CA and currently
being studied intensively.
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268, 40 CFR parts 264/265 and 40 CFR part 191. The criteria have waste classification
units of "waste types" or "waste groups" that form the basis for the characterization
requirements.  Table 3-2 in WCP 92 presents a comprehensive summary of the waste
characterization requirements.

The TRU Waste Characterization Program consists of the following six activities:  real-time
radiography, radioassay, headspace sampling and analysis, waste sampling and analysis,
visual examination, and use of process knowledge. The first five techniques are summarized
in this section below, and process knowledge is discussed in section 2.5.

Ten TRU generators currently perform some waste characterization activities on site: Idaho
National Engineering Laboratory, Oak Ridge National Laboratory, the Rocky Flats Plant,
Savannah River Site, Hanford, Los Alamos National  Laboratory, the Nevada Test Site,
Lawrence Livermore National Laboratory, Argonne National Laboratory East, and the
Mound -Plant.  These sites  have a mix of equipment required to perform the techniques listed
above, as indicated in Table 2-2. In general, facilities that  routinely manage or produce
plutonium have radioassay  facilities for the purpose of nuclear accountability which are also
used for waste characterization.  According to the Waste Characterization Program Plan,
TRU generator sites will be required to have full waste characterization capabilities in  the
future.

2.2.3.1  Radioassay.  Radioassay consists of measurement techniques used to determine the
radionuclide content of a waste container. Currently, TRU waste generators use Passive
Active Neutron (PAN) Counting and Segmented Gamma Scan  (SGS) counting as their  main
radiometric  systems.1 PAN is used to identify and quantify the odd- and even-numbered
isotopes  of plutonium by measuring their neutron emission both spontaneously in the passive
mode and in response to bombardment within the detector,  the active mode.  SGS measures
the photon emission of a waste container using a standard intrinsic germanium type of  photon
detection system. A container is divided into a number of segments and each is measured
independently. The data are interpreted by computers to provide a more complete assay of
the photon emitting radionuclides.  The DOE is now  developing a performance demonstration
program for both of these radioassay techniques.  Program  participants will receive a
    'Two other radiometric techniques are used for radioassay: Pulse Neutron Coincidence Counting
(PNCC) and gamma determinations ujing a simple intrinsic germanium type photon detection system
without segments.  Other methods are under development.

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                              Table 2-2
        Waste Characterization Capabilities of TRU Waste Generators
          TRU Generator Site
Current Waste Characterization
          Capabilities
Oak Ridge National Laboratory (ORNL)

Hanford (HANF)

Idaho National Engineering Laboratory
(INEL)

Argonne Nat'.onal Laboratory-
East
(ANL-E)

Savannah River Site (SRS)

Rocky Rats Plant (RFP)

Los Alamos National Laboratory (LANL)

Lawrence Livermore National Laboratory
(LLNL)

Nevada Test Site (NTS)

Mound Plant (MOUND)
    RTR  RA  VE  SA'HG2

        RTR  RA  VE

      RTR  RA  HG VE


            RAHG



      RTR  RAHG3VE

      RTR  RA  HG VE

        RTR  RAHG3

         RA VEHG2


            RAVE

            RAVE
            RTR   = Real Time Radiography
            RA    = Radioassay, Passive-Active Neutron, Gamma Counting
            VE    = Visual Examination
            HG    = Headspace Gas Sampling and Analysis
            SA    = Solidified Sampling and Analysis

1A laboratory for chemical analysis of TRU sludges will be operational at ORNL by
June 1994.
2Expected to have this capability by mid-1994.
3Expected to have this capability by late 1994.
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"standard" waste drum with a known activity concentration.  Each participant will analyze
the drum and report the results to the program coordinator for scoring. Participants will be
considered qualified to perform this type of analysis if they achieve an acceptable score.
Participation will be mandatory for all TRU waste generators sending waste to the WIPP.

2.2.3.2 Real-Time Radiography.  Real-Time Radiography (RTR) is a nondestructive, non-
intrusive examination technique used to examine the contents of a waste container.  It uses
x-rays and a video system to allow an operator to view the container's contents real-time. Its
primary use is to examine and verify the physical form of the waste and to ascertain that a
container complies with the specifications of a content code or other requirement regarding
physical form.  While it is generally effective, certain materials,  particularly lead liners,
cannot be penetrated by x-rays and render RTR ineffective when they are present in a waste
container.  Historically, RTR has been performed manually, which is tedious and labor
intensive.  However,  DOE is investigating the feasibility of digitizing the  current analog RTR
information and hopes to realize sufficient gains  in efficiency to allow installation of an
automated  system at ENEL and possibly at other  sites. There is no formal certification or
accreditation process for RTR operators that conforms with current industry practices.

2.2.3.3 Headspace Sampling and Analysis.  Headspace sampling and analysis  is the
determination of the chemical composition and concentration of flammable gases, volatile
organic compounds, and other gases contained in the void volumes of waste  containers.
These compounds are determined by gas chromatography and/or gas chromatography-mass
spectrometry.  Sampling within a waste container can occur in three areas: the innermost
layer of confinement; the bags used to line waste drums;  and under the drum lid, outside  of
any bags lining the drum.   The 3-year-old WIPP Performance Demonstration Program for
Headspace Gas Analysis is detailed in DOE92.   This program is  similar to the one described
under Radioassay, in  section 2.2.3.1, and its intended use is to qualify DOE TRU generators
to perform these analytical techniques.

2.2.3.4 Waste Sampling and Analysis.  Solidified waste  sampling and analysis is the
determination of hazardous constituents  in solidified waste forms using modified laboratory
procedures. This technique is currently in the development stage.  A laboratory for analysis
of TRU sludges is being prepared at Oak Ridge  National  Laboratory.  The procedures to  be
used are based on Test Methods for Evaluating Solid Waste (SW846): Physical/Chemical
Methods (SW86) and  were modified by  Los Alamos National Laboratory  for this purpose.
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 The DOE intends to perform a minimum of solidified waste sampling and analysis, using it
 to verify waste characterization performed by process knowledge and nondestructive assays.

 2.2.3.5 Visual Examination.  Visual Examination is the examination of the contents of a
 waste container by physical removal, examination, and  sorting for the purpose of establishing
 or verifying that the correct waste codes have been assigned.  In this time-consuming, hands-
 on process, the contents of a drum are unpacked, examined, segregated if necessary, and
 repackaged.  It is often performed remotely using manipulators in facilities (e.g. hot cells)
 designed for the examination of fuel assemblies or other items heavily contaminated with
 penetrating gamma radiation.  Nine TRU generators have modified facilities used for this
 purpose (see Table 2-2).  Argonne National Laboratory-West  has recently completed a waste
 characterization chamber designed for visual examination of waste containers. The DOE
 considers visual examination to be a means of s erifying assumptions made using process
 knowledge, e.g., correct  waste code assignment and absence of non-conforming items
 (residual liquids, compressed gases, etc.).  For future generated waste,  visual examination
 would occur prospectively.  That is, the waste would be sorted and the contents of each
 drum would be recorded  before the drum is filled, precluding  the need to open a sealed drum
 to check compliance at a later date.  For retrievably stored waste, DOE plans to perform
 retrospective visual examination of an unspecified percent of older waste drums as required,
 presumably by selecting those drums with insufficient process  knowledge, inadequate real
 time radiography, etc.

 2.2.3.6 Process Knowledge.  Each of the above techniques is intended to complement the
 waste characterization data generated using process knowledge, discussed in section 2.4.
 The DOE intends to  use process knowledge as the primary characterization tool for newly
 generated waste. The DOE anticipates that retrievably stored waste will require more
 frequent analysis by  all techniques to demonstrate compliance  with the WIPP WAC,
presumably due to the lack of reliable documentation on older waste.
2.3    Status of Waste Characterization for Compliance Assessment

The system currently in place assesses the waste parameters discussed in sections 2.3.1
through 2.3.4.
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2.3.1 Inventory

If the activity of each radionuclide in the waste were determined it could be used in the
compliance assessment. Most of this information is currently obtained in conjunction with
the four WAC inventory characteristics of specific activity, criticality, plutonium equivalent
curie, and thermal power.  Because the characterization of existing waste is still in progress,
the radionuclide inventory remains uncertain.  The radionuclide inventory of to-be-generated
waste, which is expected to comprise two thirds of the projected contents of the WIPP, is
unknown.

Current radioassay procedures are capable of providing the necessary radionuclide
composition. However, the data package  certification required by the WAC requires only the
reporting of total  alpha curies,2 the Plutonium Equivalent Curies (PE-Ci) total, the Fissile
Gram Equivalents (FGE),  and the thermal power for containers with over 0.1 watt/ft2.  All
of these criteria provide some information on radionuclide inventory, but they are not
sufficient to fully describe the radionuclide inventory.  For example, the quantity of U-233, a
trace radionuclide in WIPP waste that is very important to compliance assessment
calculations, cannot be determined accurately from  these data.

At present, the radionuclide inventories used in compliance assessment are  derived using the
site-specific averages included in Integrated Data Base for 1991: U.S. Spent Fuel and
Radioactive Waste Inventories, Projections and Characteristics (EDB91), referred to as the
DDE. Reporting practices among the generator sites are not uniform (e.g.,  there are
differences in rounding and data reduction), this non-uniformity may not be important when
projecting future waste volumes or disposal system  capacity.  However, uncertainties created
by this non-uniformity may not be acceptable in a compliance assessment-based waste
characterization program.  In the past, radionuclide inventory data were not linked with the
waste characterization program.

The DOE plans to use a system of Performance-Based Waste Acceptance Criteria for WIPP
waste, to replace  reliance on  the IDE.  Information to  feed this system will be gathered in
the same manner  as was done for the IDE and  the U.S. Department  of Energy Interim Mixed
1 Although total alpha curies arc not listed in Attachment 2-2 (i.e., Table 3-1) ofWIPP-DOE-069, Rev. 4.0, they
are specified on page 3-57 as part of the data package.

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 Waste Inventory Report: Waste Streams, Treatment Capacities and Technologies, (IMW93),
 or the IMWIR, using data calls to the waste generators (data calls are the mechanisms
 whereby DOE personnel responsible for compiling TRU inventory data contact site personnel
 at each generator on a regular basis for the purpose of obtaining current information pertinent
 to TRU inventory, e.g., waste volumes, radioactivity). However, data to be collected for
 WIPP will be categorized differently upon collection.  Categories  specific to the WIPP called
 WIPP Waste Profiles will be developed based on a waste's proposed treatment.  These
 profiles will be used to develop a baseline inventory report (BIR) that will address three
 categories of TRU waste:  existing inventory, existing process line waste, and projected
 waste from environmental restoration/decommissioning activities.  The BIR is intended to
 provide information relative to the target levels for materials that the DOE will establish for
 those materials intended for disposal at WIPP.

 Information used to ensure  compliance with the criticality criterion of less  than 200 Fissile
 Gram Equivalents (FGE) per 55 gallon drum is obtained initially from the information
 supplied by each TRU waste generator. This information is obtained by the generator on-
 site, using some combination of process knowledge and the radioassay techniques described
 in section 2.2.3.  Each drum is assayed using direct measurements (PAN and SGS) to
 confirm the initial drum classification regarding criticality, Pu-239 activity, and thermal
 power.

 Activity in curies is currently determined by the nine TRU generators listed in Table 2-2,
 using the radioassay techniques described in section 2.2.3.1.   The operations and equipment
 at each site vary, and there is no requirement to standardize the equipment or procedures
 used.

 TRU waste is produced as a direct result of some types of material processing.  Typically,
 this waste is accumulated at different points in the process over  some time period (short  or
 long), collected in some type of receptacle  (1-gallon paint can, 5-gallon can, 30-gallon drum,
 etc.) which is then combined with other similar or dissimilar receptacles and packed in a
 larger container.  The largest container is usually a 55-gallon  drum, with various liners and
 inner packages.  At one or more points in this process, a receptacle containing waste is
assayed radiometrically, using portable survey instruments or  the radioassay techniques
described in Section 2.2.3.   The purpose of the assay  is to determine a concentration for one
or more radionuclides within the container.  Because this concentration is used for multiple
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purposes, among them the calculation of the waste's specific activity, PE curies, etc., this
measurement is very important.  However, this determination is often based on an external
radiation reading (j8, 7, or neutron) taken with portable survey equipment which is then
converted to a radionuclide concentration on the basis of certain assumptions about the waste,
e.g., a known isotopic distribution (weapons grade Pu), the presence/absence  of U-235 or
Pu-238, etc.  Inspection of the data collection efforts at the TRU generator  sites reveals two
potential areas of concern affecting data used to calculate radionuclide inventory, PE curies,
thermal power, specific activity, criticality, and the data package requirements.

The first area of concern is that the attention to detail and level of documentation appropriate
for a measurement taken with portable survey equipment  may not be adequate for the
determination of a radionuclide concentration that is required for the purpose of waste
characterization.  Practices vary among generators,  and the uncertainty associated with each
type of measurement can vary considerably, yet data are treated as if they were comparable.
For example, generators assay waste containers at different parts of the waste generation
process: upon first accumulation (i.e.,  "bagging out" waste for removal from  hot cell or
processing line); after combination with other waste from the same process  in a small
container (i.e., 1-gallon paint can, "ice cream carton," etc.); upon combination  of a small
collection of waste from one process with those from a different process in  a larger container
(i.e., 30-gallon drum); or upon final assembly of each waste container (i.e., 55-gallon drum).

The second problem is that the assumptions used as a basis for the correction  factors may be
questionable because of reliance on old, poorly  documented, or incorrectly performed
calibrations or efficiency/conversion factors; changes in waste generator processes, container
size and  shape; and failure to  consider radioactive decay/ingrowth of progeny.

2.3.2  Actinide Solubility

Estimates of solubilities range over 13 orders of magnitude. The mean and median
plutonium values used in the 1992 Preliminary Performance Assessment (which were
obtained by expert elicitation) are over three orders of magnitude less than values being
generated in an ongoing laboratory study, according to information reported in the SNL
WIPP Technical Progress Report for Month Ending September 30, 1992 (SNL92a).  These
higher laboratory values, if found to be representative of  waste forms, could potentially
result in problems in meeting  the containment requirements.
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The solubility of an element in a brine is a function of many factors, each subject to
significant uncertainty.  Important factors include concentration of anions, solution pH and
Eh.  Also, the amount of brine contact with the transuranic radionuclides will affect the total
amount of radioactivity in solution.  As discussed previously in Section 2.1.3, the quantity of
brine present at  any time is also subject to considerable uncertainty.

The current DOE waste characterization program does not completely address actinide
solubility for TRU waste. The data used in the 1991 and 1992 compliance assessments
indicate that the solubility of important actinide species (Am, Pu, Np, Th, U) has a wide
range of uncertainty, depending on the presence of other chemical species (e.g., buffers,
chelating  agents, etc.) and oxidation state.  These chemical and physical parameters are not
directly addressed in the TRU waste characterization program.

Solubility and leachability are not characteristics that could be  given WAC limiting
parameters because there is no apparent way of estimating the  solubility in individual waste
containers under disposal system conditions.  Average solubility/teachability values for
categories of waste may be obtained eventually from laboratory studies.  The value of the
solubility/leachability and its  uncertainty can be affected by waste form modification.
Leachability can be reduced by using dense waste forms with a high pH, low organic
content, and low surface area.  Engineered barriers that reduce the amount of brine available
for leaching could also be beneficial.

2.3.3  Gas Generation

DOE's WAC do not contain any compliance assessment criteria related to gas generation,
although data currently being obtained  (e.g., weight, content code, percent organic material,
and alpha curies) may be adequate to predict gas generation in individual waste  containers.
In considering gas generation, it may be useful to examine:  (1) if gas generation is critical,
(2) if deleterious effects can be controlled by load management or waste form modification,
and (3) if gas generation is predictable for individual waste containers.

Gas generation is a complex parameter described by three general types of chemical
reactions, each of which depends on several physical and/or chemical factors (see section
2.1.3).  While experimental data describing these dependencies are incomplete,  ranges of
possible gas generation rates  have been estimated using various assumptions regarding
disposal system conditions (e.g., inundated or humid conditions, etc.), and other factors.
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It is possible that data currently required for waste characterization (e.g., waste weight,
content code, organic material composition, etc.) could be used in conjunction with other
direct measurements to predict gas generation.  However, until the importance of this
parameter is established, it is premature to modify the waste characterization program  to
address gas generation.

The residual liquid content of the waste may be important to its gas generation
characteristics.  Table 3-1 of the WIPP WAC notes that, as a guideline, residual liquid in
well-drained containers  should be restricted to approximately one volume percent of the
internal container, with  the aggregate amount of residual liquid less than one volume percent
of the external container.  The residual liquid limit could be implemented in three ways:

       •     Upon assembly of the drum by personnel at the waste generator site;

       •     By real time radiography performed on site by  waste generators during the
             drum  characterization process;

       •     During physical examination of a container (present plans are to do this only
             on one percent of containers)

While the combination of these three techniques appears adequate to meet the residual  liquid
criterion, the use of one technique alone may not  suffice.  For example, RTR has not been
demonstrated to be a fail-safe method for detecting containers of liquids within a waste drum.
In January 1993, a full  8-ounce can of adhesive was missed by an operator conducting RTR
at INEL, and later discovered during the visual examination of the drum contents.  RTR
detects movement of liquids within a container; therefore a completely full container could be
missed.

Compressed gases initially placed in the disposal system probably constitute a negligible
quantity relative to the amount of gas expected to be  generated in the disposal system through
other mechanisms as discussed in section 2.1.3.  At present, the WIPP WAC forbids
acceptance of any compressed gases.  This criterion  would incidentally benefit compliance
assessment by improving waste container integrity during the  years directly following
disposal.  The presence of compressed gases in waste shipments would be determined using
process knowledge, RTR and visual examination in the same manner used to detect residual
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 liquids, described above.

 2.3.4  Other Characteristics

 2.3.4.1  Immobilization. The WAC now requires immobilization to limit paniculate material
 < 10 /mi in size to < 1 % and paniculate material < 200 /*m in size to < 15 % by weight.
 The current limit was set to minimize dispersion in air during waste shipment and handling,
 but it should also be beneficial in decreasing mobility of waste by, among other things,
 increasing  shear strength.

 Immobilization is identified as a requirement in the WIPP WAC and is addressed in the
 Waste Characterization Program Plan through the use of codes for specific categories ("waste
 type" and "waste group").

 2.3.4.2  Porosity.  DOE's compliance assessment currently uses average values from the
 IDE for types of material in waste containers and an  average porosity for each waste type
 derived from average container weights for each material type.  These average values are
 then used to develop curves for porosity versus crushing stress.  A container-specific porosity
 value could be calculated using data required in the data package certification, i.e., content
 code indicating the material type and container weight, but this is not presently done.

 The WAC  could require  a calculated value of the porosity of each waste container on the
 data package certification.  These values should be used to the extent possible to determine
 the average initial porosity  used in the current compliance assessment procedure. If load
 management is required in the future and initial porosity is found to be an important
parameter,  the data could be used directly to determine the mix of containers in a waste
 storage  room.

Porosity is  addressed through the use of categories described in section 2.2.3.

2.3.4.3   Pyrophoric and Explosive Content.  In accordance with RCRA and transportation
requirements, no non-radionuclide pyrophorics are permitted.  Radionuclides in pyrophoric
form are limited to < 1 % by weight in each waste package.
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2.4    Efforts to Use Process Knowledge to Characterize TRU Waste

2.4.1  Definition of Process Knowledge

The DOE defines process knowledge as the knowledge of processes and material that
generate a given waste, including all associated administrative and quality control records
pertinent to the waste-generating process.  There is no DOE uniform definition of process
knowledge common to all TRU waste generators, nor is there guidance regarding its use for
this or other applications.

2.4.2  Using Process  Knowledge for Waste Characterization

One idea under consideration by DOE for waste characterization is to qualify or certify
individual waste streams by developing a waste stream profile. Process knowledge would be
used as one tool among many to develop the profile.  Important aspects  of the profile
approach include:

       •      How is a waste stream  defined in this context?

       •      To what extent is this profile verified by empirical  sampling and analysis, and
              how  often?

       •      Would  multiple profiles be  required for complex waste streams?

       •      How responsive to process  changes is the profile?

       •      Would  requalification of each stream be required on a regular basis, or would
              the initial qualification be valid as long as the process  was shown to be stable?

       •      Are there elements of different waste streams at a site that are  similar enough
              to allow their combination for characterization purposes?

       •      Since this is a site-specific process, can the profile  from a process or
              equivalent waste stream at one site be applied to a  similar process at another
              site?
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       •      How would the uncertainty associated with each part of the profile
             development process be quantified?

       •      How would each stream's profile be determined?  Would it be determined by
             using average concentration values of specific constituents, or by establishing a
             range of acceptable concentrations?

       •      How would one reconcile a waste stream's profile with an out-of-specification
             analysis of a specific drum originating in the stream?

       •      What protocol would be required when a waste stream was fo ,nd to be outside
             of the profile?

Waste stream qualification assumes that the waste-generating process is a formal, well
defined, and controlled process accompanied by sufficient documentation, and that the
required documentation is available and amenable to direct inspection. Examples of the
forms the documentation could take are:

       •      material inventories and balance sheets

       •      control of documents/process control diagrams

       •      quality assurance records
             •      chain of custody records
             •      records of training/indoctrination
             •      internal audits or QA surveillance records
             •      external audits/inspections
             •      compliance assessments

       •      environmental and/or process monitoring data
             •      effluent monitoring
             •      quality control checks
             •      verification analyses of process waste

       •      vendor supplied  assays/supply records

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             training records/certifications

             records of shipment/material transfers

             health  and safety surveys

             interviews with experienced personnel/historical information

             hazardous waste manifests and generator management forms
It should be noted that much of the waste for which DOE uses process knowledge as the
main waste characterization tool originates from non-routine types of activities that are not
typically understood to be controlled processes, with feed materials, intermediate products,
outputs, etc.  For example, waste from unscheduled maintenance and the cleanup of
contaminated spills do not result from a controlled, predictable course of events with well-
defined feed materials, intermediate and end products of known purity as would be present
for a production or manufacturing line. Process knowledge would appear to be a poor
choice as a waste characterization tool for these and other similar types of waste.

2.4.3   Use of Process Knowledge for TRU Inventory

Currently, two DOE documents detail the inventory of TRU waste:

•      Integrated Data Base for 1992:  U.S. Spent Fuel and Radioactive Waste Inventories,
       Projections, and  Characteristics, DOE/RW-0006, Rev. 8, October 1992 (IDB91)

•      U.S. Department of Energy Interim Mixed Waste Streams,  Treatment Capacities and
       Technologies, DOE/NBM-1100, April 1993 0MW93)

Together, these documents are currently considered the best source for information on
DOE's inventory of TRU (and other) waste.  Process knowledge was used to generate much
of the information in these two documents.  In addition, process knowledge was also the
basis for calculating waste volumes and other data in both reports. Process knowledge
should be used with caution for these reasons:
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       •     Uncertainty estimates associated with process knowledge data and their
             application are not provided; and

       •     DOE generators of TRU waste exhibit great diversity with respect to waste
             generation and handling.

2.4.4  Evaluating the Use of Process Knowledge

While the use of process knowledge as a predictive tool has not been fully evaluated, DOE
did conduct a 2-year investigation of the correlation between process knowledge and
empirical sampling and analysis. This study was completed in  1985 and involved a total of
242  containers of TRU waste, which ranged  from new (6 months old) to older waste (12
years old in 1983).  Of these,  199 drums and 10 boxes were generated at  the Rocky Flats
Plant and 33 drums were generated at Los Alamos National Laboratory.  All containers were
initially shipped to the Idaho National Engineering Laboratory (INEL), where they were
assayed nondestructively using RTR. The study's objective was to collect information on gas
generation, evaluate various venting devices, examine waste for compliance with the WIPP-
WAC and evaluate the adequacy of nondestructive examination as a certification technique.
The two volume document TRU Sampling Program: Volume I—Waste Sampling and Volume
II—Gas Generation Studies (EGG85) describes the study in detail and provides the
investigation's results, which are summarized below and in Appendix 2B.

The waste containers had initially been "characterized" at the generator facility  (RFP or
LANL) by the assignment of a Waste Content Code3 (See Appendix A to EGG-WM-6503)
prior to shipment to INEL.  At INEL, each drum was examined using real-time radiography
and radioassay by passive-active neutron counting (see section 2.2.3.1) and the results were
recorded. The drums were then shipped to the Rocky Flats Plant where each was completely
dismantled within a hot cell for visual examination, as described in section 2.2.3.5.  The
contents were emptied, weighed, and analyzed by radioassay when appropriate and  all results
recorded.

This study's main purpose was to determine  the adequacy of RTR as a nondestructive
characterization technique.  However, it also provides an opportunity to evaluate the use of
    3  The Waste Content Codes used for this study were developed prior to TRUCON Codes.  TRUCON
Codes were intended to include all aspects of waste covered by the Waste Content Codes.

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process knowledge as a predictive tool. By comparing the content code assigned by the
generator using process knowledge against the "proper" content code assigned after complete
hands-on examination of the waste container (the equivalent of sampling & analysis), process
knowledge can be evaluated as a tool for assigning the correct content code.  Toward this
end, the data from this investigation  were analyzed statistically (see Appendix 2B) and the
results are discussed below.

The Kappa statistic was used to evaluate how well process knowledge was able to classify
waste by content code compared to how well the codes would be expected to have been
assigned by chance alone.  In summary, process knowledge assigned content codes much
better than would be expected by chance alone, indicating that for these waste containers,
process knowledge was effective as a predictive  tool for waste classification.

However, three  caveats should be noted.

First, the waste  containers used in the study were not statistically selected and therefore not
necessarily representative of TRU waste, limiting the study's  applicability.

Second, production and waste handling practices, documentation protocols, assay methods,
etc, vary among TRU generators.  Because of the lack of established, auditable, uniform
criteria for waste characterization for all TRU generators, questions exist regarding this
study's applicability.  Caution must be exercised in applying conclusions to TRU waste
generators or specific waste streams  other than those used in this study.

Third, this analysis provides information on the ability of process knowledge to assign a
content code; no conclusions can be  drawn about the ability of process knowledge to provide
other important, detailed information (e.g., isotopic distribution, amount of free liquids, gas
generation rates).  This is particularly true for retrievably stored, older waste, where existing
information is sparse.

The 1985 INEL study discussed here is the only documented  evaluation of the use of process
knowledge available at this time. However, additional information exists at INEL, Hanford,
Oak Ridge National Laboratory, and the Savannah River Plant,  all of whom have been
attempting to verify waste content codes assigned by process knowledge using the other
techniques described in section 2.2.3.  At INEL alone, DOE  has performed a real-time
radiography and radioassay on approximately 30,000 drums of waste to date, some
percentage of which  have also been visually examined.  The DOE has not released this

                                          2-21

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information, so it is not known what level of documentation exists for these examinations or
if other formal comparisons have been made.  This information could be very useful to a
more comprehensive evaluation of the use of process knowledge as a predictive tool.
2.5    Current Assumptions

The initial projections of waste type, isotopic composition, rate of production, total volume,
and other key factors for potential WIPP-destined waste were based on assumptions regarding
DOE's continued production of nuclear weapons and associated support functions.  Since
DOE's mis ;on has shifted from production to environmental restoration, these projections
require scrutiny. It was assumed that the Rocky Flats Plant, Hanford, and the Savannah
River Site would continue in the production mode and generate waste characteristic of the
weapons production process.  In the "shut-down" mode, the waste types and their
corresponding activities will be different.

An important difference is in the kind and volume of waste. Decontamination and
decommissioning (D&D) activities typically create larger volumes of waste with much
smaller activity concentrations.  These materials are not expected to be TRU due to the lower
limit of 100 nCi/gram for TRU waste.  However, since plutonium production is no longer
part of DOE's mission, there is reduced economic incentive to recycle waste containing
plutonium concentrations above the economic discard limit (EDL).  Additionally, it is unclear
whether the EDL will increase, causing materials that were scheduled for plutonium recovery
to be considered waste, e.g., the residues currently in storage at the Rocky Flats Plant. It is
not clear that DOE has addressed the impact of these factors in its waste projections.

It is assumed that the buried TRU waste generated prior to  1970 are not destined for the
WIPP. Their retrieval and repackaging would result in large volumes of both low-level
waste and TRU waste, due to the waste's large soil component. If this waste is intended for
the WIPP, disposal system capacity could be a significant problem.

Future DOE activities may involve U.S. acquisition of special  nuclear material (SNM) from
foreign sources.  Should this occur, it could result in the generation of waste intended for the
WIPP. Since the total volume and activity for WIPP RH waste is limited, it is unlikely that
SNM from foreign sources would have  an impact on the type and amount of waste that may
be emplaced in the WIPP.
                                         2-22

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2.6    Regulatory Precedents for Waste Characterization

2.6.1  Resource Conservation and Recovery Act (RCRA)

The RCRA hazardous waste identifications are provided in 40 CFR part 261, Subparts B, C
(characteristic waste) and D (listed waste). A hazardous waste determination for
characteristic waste is made either by testing the waste through approved analytical methods
or by applying generator knowledge of the waste and process stream (see 40 CFR Sections
262.11, 264.13, 265.13,'and 268.7). "Applying generator knowledge" is comparable to
DOE's intended use of process knowledge.  Generator knowledge consists of the following:

       •      Process knowledge, defined as detailed information on waste obtained  from
              existing pubb'shed or documented  waste  analysis data or studies conducted on
              hazardous waste generated from processes similar to that which generated the
              waste in question;

       •      Waste analysis data obtained from the facilities generating the waste;

       •      A generator's records of analyses  performed prior to the effective date of
              RCRA.

Generators can use "acceptable knowledge" for hazardous  waste determination to  meet the
waste  analysis requirements in  whole or part (EPA 92). The user must ensure that the
information is based on valid analytical techniques and that any studies used are current and
representative of the process in question.

The EPA requires transportation, storage, and disposal facilities  (TSDF) that accept waste
from generators to perform independent corroborative testing (i.e., periodic detailed physical
and chemical analyses) for the purpose of ensuring waste compliance. While these facilities
may rely on information provided by the waste generators or treaters, EPA states in  55 FR
22669 that this "testing  requirement is not superseded by the ability of the facility to rely on
information supplied by the generator or treater."

The EPA also allows the use of abbreviated waste analyses,  often called "fingerprint
analysis," to verify that a waste matches its expected characteristics.  These are typically
used for waste that is handled frequently and has previously  been characterized  by complete
                                          2-23

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sampling and analysis.  The provisions for the use of acceptable knowledge are:

       •     hazardous constituents in wastes from specific processes are well documented,

       ซ     wastes discarded are unused commercial chemical products, reagents or
             chemicals of known physical and chemical constituents,

       •     physical nature of the waste does not lend itself to taking a laboratory sample.

2.6.2 Other Relevant Regulations or Guidance

There is no specific guidance regarding waste characterization from the U.S. Nuclear
Regulatory Commission (USNRC), ftreign waste repositories, or commercial facilities.
Relevant regulations and/or guidance are summarized below.
USNRC
       10 CFR part 61.55(a)(8), "Licensing Requirements for Land Disposal of Radioactive
       Waste," addresses the use of "scaling factors."  This allows for the indirect
       determination of radionuclide components by relating the "inferred concentration of
       one radionuclide to another that is measured, or radionuclide material accountability,
       if there is reasonable assurance that the indirect methods can be correlated with actual
       measurements."

       The US NRC document Technical Position on  Waste Form, (Revision 1), January
       1991, Appendix A, V. Waste Characterization (NRC91) describes the use of a
       Process Control Program (PCP), as it applies to the processing and packaging of low-
       level radioactive waste.  A PCP is used to "describe the envelope within which
      processing and packaging" of waste "will be accomplished to provide reasonable
       assurance  of compliance" with waste acceptance criteria.  This allows a waste
       generator to develop a "profile" for a waste form preparation process,-for the purpose
      of qualifying the process.  Verification analysis is required, and changes and/or
      deviations must be approved using an NRC-specified protocol.
                                         2-24

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France

•     Has a waste category similar to TRU, ("alpha contaminated waste").

•     Is required to prepare a report to Parliament in 15 years regarding,  among other
      things, the "partitioning and transmutation of actinides,"

•     Plans to bury long-lived alpha waste from fuel cycle activities in deep geologic
      formation.

•     Requires waste generators to characterize waste and establish a "record of
      specification for each family of packages" with specific characterization goals (see
      Appendix 2C).
Sweden
       The Swedish Nuclear Power Inspectorate has established "Qualitative Acceptance
       Criteria for Waste Packages to Be Disposed of in The SFR-1" (SFR is Sweden's
       planned disposal system for low and intermediate level waste).

       The criteria address the following:
       •General handling and  management
       •Radiological properties
              • Radionuclide inventory
              • Surface dose rate and dose rate at a certain distance
              • Surface contamination
              •Internal radiation
              • Homogeneity
       •Chemical properties
              • Composition and structure
              • Homogeneity
              • Content of free liquid
              • Corrosion
              • Gas formation
              • Combustibility and fire resistance
                                         2-25

-------
       • Chemical reactivity
       • Retention properties
•Mechanical properties
       • Mechanical strength against external loads
       •Mechanical stability
                                  2-26

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                                        2.7  References

DOE91       Waste Acceptance Criteria for the Waste Isolation Pilot Plant, DOE/WCPP-
             069, December 1991.

DOE92       Performance Demonstration Program for the WTPP Experimental-Waste
             Characterization Program, DOE/WIPP 91-016, Revision 2, February 1992.

EGG85       TRU Sampling Program: Volume I--Waste Sampling and Volume n~Gas
             Generation Studies, EGG-WM-6503, September 1985.

EPA 92      Environmental Protection Agency, Waste Analysis at Facilities that Generate,
             Treat, Store, and Dispose of Hazardous Wastes, A Guidance Manual, Office
             of Solid Waste and Emergency Response, OSWER 9938.4-03, Washington,
             D.C., October 1992.

IDB91        Integrated Data Base for 1991: U.S. Spent Fuel and Radioactive Waste
             Inventories, Projections and Characteristics, DOE/RW-0006, Rev. 7.

IMW93      U.S.  Department of Energy Interim Mixed Waste Inventory Report: Waste
             Streams, Treatment Capacities and  Technologies, DOE/NMB-1100, April
             1993.

NRC91       Technical Position on Waste Form, (Revision 1), January  1991, Appendix A,
             V. Waste Characterization.

SNL92       Preliminary Performance Assessment for the Waste Isolation Pilot Plant,
             SAND92-0700, Sandia National Laboratories, December 1992.

SNL 92a     Sandia National Laboratories Waste Isolation Pilot Plant Technical Progress
             Report Month  Ending September 1992,  Sandia National Laboratories.

WCP92      Waste Characterization Program Plan for the Waste Isolation Pilot Plant,
             DOE/WIPP 89-025, Revision 2.0, December 3, 1992.
                                       2-27

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SW86        Test Methods for Evaluating Solid Waste (SW846): Physical/Chemical
             Methods, Third Edition and Revision, 1986.
                                       2-28

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Appendix 2A:       Summary of Waste Limiting Parameters for CH-TRU Waste Addressed
                  in WIPP WAC
                                    2A-1

-------
                                                                           WIPP-DOE-069
                                                                              Revision 4.0
                                                                            December 1991
                                      TABLE 3-1
             SUMMARY OF WAC LIMITING PARAMETERS FOR CH-TRU WASTE
WASTE CONTAINER REQUIREMENTS/CRITERIA
CRITERION/
REQUIREMENT
AND SECTION
                 LIMITING PARAMETER(S)
SOURCE(S)
OF LIMIT(S)
Waste
Containers
3.2.1
   Containers shall be noncombustible and meet DOT Type A
   packaging requirements.

   Current TRUPACT-II requirements limit acceptable
   containers to 55-gallon drums, standard waste boxes
   (SWBs), or SWB overpack of 55-gallon drums or test bins.
     1
Waste Package
Size
3.2.2
   Current TRUPACT-II limits are 55-gallon drums in two
   seven-packs, or two SWBs.
Waste Package
Handling
3.2.3
   All packages shall be configured as specified in the
   TRUPACT-II SARP (see 3.2.2 above).
WASTE FORM REQUIREMENTS/CRITERIA
Immobilization
3.3.1
   Waste materials shall be immobilized if > 1 % by weight is
   paniculate material <  10 microns in diameter, or if >15%
   by weight is paniculate material  < 200 microns in
   diameter.
Liquids
3.3.2
   Only residual liquids; as a guideline, residual liquid in
   well-drained internal containers to be restricted to
   approximately 1 volume % of the internal container;
   aggregate amount of residual liquid < 1 volume % of
   external container.
Pyrophoric
Materials
3.3.3
   No non-radionuclide pyrophorics permitted.  Radionuclides
  .in pyrophoric form are limited to < 1 % by weight in each
   waste package.
    2,3
Explosives and
Compressed
Gases
3.3.4
• No explosives (49 CFR Part 173, Subpart C) are permitted.

• No compressed gases are permitted.
   1,2,3

     2
TRU Mixed
Wastes
3.3.5
  TRU wastes shall contain no hazardous wastes unless they
  exist as co-contaminants with transuranics.

  Waste generators must determine if their waste is regulated
  by RCRA, and meet the requirements in the WIPP RCRA
  Part A and Pan B Permit Applications.
      1

-------
                                                                           WIPP-DOE-069
                                                                             Revision 4.0
                                                                           December 1991
                                  TABLE 3-1 (CONT.)
             SUMMARY OF WAC LIMITING PARAMETERS FOR CH-TRU WASTE
WASTE FORM REQUIREMENTS/CRITERIA (Continued)
 CRITERION/
 REQUIREMENT
 AND SECTION
                 LIMITING PARAMETER(S)
SOURCE(S)
OF LIMIT(S)
TRU Mixed
Wastes (Cont.)
3.3.5
   Generators must document procedures for sampling,
   analytical protocols, QA/QC guidelines, and other
   information called for in 40 CFR i 264.13 and 265.13 in a
   site-specific QAPjP.

   Characteristic ignitable (D001), corrosive (D002), and
   reactive (D003) wastes are not acceptable at WIPP.

   Any waste container sent to WIPP or loaded into a bin
   destined for WIPP must meet the two times  (2X) the
   maximum comparability requirement for 5 nonflammable
   VOCs as specified in the NMD.

   Any waste container sent to WIPP must meet the ten times
   (10X) the average comparability requirement for 3
   nonflammable VOCs as specified in the NMD.

   Sludges shall be analyzed for  total VOCs and toxic metals
   specified in the.NMD.
                                                                             1,2,3


                                                                               3
Specific
Activity of
Waste
3.3.6
   Waste shall be greater than 100 nanocuries of TRU per
   gram of waste, exclusive of added shielding, rigid liners,
   and the waste containers, including alpha contaminated
   wastes handled as TRU under DOE Order 5820.2A.
WASTE PACKAGE REQUIREMENTS/CRITERIA
Waste Package
Weight
3.4.1
•  Current waste package limits are 1000 Ibs per 55-gallon
   drum, or 4000 Ibs per SWB.

•  TRUPACT-II payload is limited to 7265 Ibs.

•  TRUPACT-II is limited to 19,250 Ibs total gross weight,
   with a total shipment GVW of 80,000 Ibs.
                                                                               2

                                                                               2

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                                                                         WIPP-DOE-069
                                                                           Reviiion 4.0
                                                                         December 1991
                                 TABLE 3-1 (CONT.)
            SUMMARY OF WAC LIMITING PARAMETERS FOR CH-TRU WASTE
WASTE PACKAGE REQUIREMENTS/CRITERIA (Continued)
CRITERION/
REQUIREMENT
AND SECTION
                LIMITING PARAMETER(S)
SOURCE(S)
OF LIMIT(S)
Nuclear
Criticality
(Pu-239 FGE)
3.4.2
• Accepted package limits, including two times the error, are:
  -  < 200g/55-gallon drum
 - -  < 325g/SWB

• The sum of the FGE of all packages in a TRUPACT-II
  payload shall be < 325g.
Pu-239
Equivalent
Activity
3.4.3
• Waste packages shall not exceed 1000 Ci of Pu-239
  equivalent activity (PE-Ci).
Surface Dose
Rate
3.4.4
•  Drums or SWBs shall not exceed 200 mrem/hr surface
   reading, or 10 mrem/hr at 2 m.

•  Shielded containers are allowed for ALARA purposes only.

•  Neutron contributions of > 20 mrem/hr shall be separately
   documented.

•  External dose rates on the loaded TRUPACT-II shall not
   exceed 200 mrem/hr surface, or 10 mrem/hr at 2 m.
    1.2


     2

     1
Removable
Surface
Contamination
3.4.5
• Removable package surface contamination shall not be
  >50 pCi/100 cm2 alpha, and not >450 pCi/100 cm2
  beta/gamma.
Thermal Power
3.4.6
• Thermal (wattage) limits for individual waste packages,
  including the error, are contained in the TRUPACT-II SARP.

• TRUPACT-II load limits are contained in the TRUPACT-II
  SARP.

• TRUPACT-II design limit is 40 watts.
                                                                             2


                                                                             2

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                                                                           WIPP-DOE-069
                                                                              Revision 4.0
                                                                           December 1991
                                  TABLE 3-1 (CONT.)
            SUMMARY OF WAC LIMITING PARAMETERS FOR CH-TRU WASTE
WASTE PACKAGE REQUIREMENTS/CRITERIA (Continued)
CRITERION/
REQUIREMENT
AND SECTION
                LIMITING PARAMETERS(S)
SOURCE(S)
OF LIMIT(S)
Gas Generation
3.4.7
•  All confinement layers, such as bags, shall be closed only
   by a twist-and-tape or fold-and-tape method.

•  No sealed containers > 1 gallon may be in the waste.

•  The maximum number of confinement layers shall be
   known.

•  Waste packages emplaced in WIPP during the experimental
   period shall not exceed 50% of the lower explosive limit in
   any layer of confinement for hydrogen and methane.

•  Total flammable  VOCs are limited to 500 ppm in the
   headspace gas of waste packages.

•  If total flammable VOCs are >500 ppm in headspace, a
   flame test must be performed prior to emplacement in the
   WIPP.

•  If total flammable VOCs are >500 ppm in headspace, a Le
   Chatelier calculation is necessary.

•  All chemicals/materials > 1 % by weight must be evaluated
   for compatibility within the waste form and with
   TRUPACT-II materials of construction.

•  Trace chemicals  ซ1 weight % limit) must total < 5% by
   weight of the waste in any package.

•  Chemicals/materials present in concentrations greater than
   one weight percent, shall conform to the allowable
   chemicals in each waste material type.

•  Real-time radiography or equivalent examination.

•  Visual characterization of solid waste for 10 waste material
   categories listed  in QAPP.

•  Analysis of sludges for ph and major cations and anions
   listed in SNL Bin-Scale Test Plan.

•  Total alpha activity of waste on a container basis using
   methodology listed in QAPP.
                                                                               2

                                                                               2
                                                                               2


                                                                               3



                                                                               3


                                                                               2



                                                                               2


                                                                               2



                                                                               4

                                                                               4

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                                                                                 Revision 4.0
                                                                               December 1991
TABLE 3-1 (CONT.)
SUMMARY OF WAC LIMITING PARAMETERS FOR CH-TRU WASTE
WASTE PACKAGE-REQUIREMENTS/CRITERIA (Continued)
CRITERION/
REQUIREMENT
AND SECTION
Gas Generation
3.4.7 
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Appendix 2B:        Proposed Methodology for Evaluating the Assignment of TRU Content
                    Assignments Using Process Knowledge

Introduction

An important part of the waste characterization process for transuranic waste  (TRU) intended
for shipment and interment at the Waste Isolation Pilot Plant (WIPP) is the assignment of a
waste code to a specified category. Historically, this has been done by the waste generator
using various forms of information, i.e., records, process flow diagrams, historical data, etc.
For the purposes of this evaluation, this prospective assignment of a content code or waste
category  using existing information in the absence of empirical analysis is called Process
Knowledge (PK). The DOE has proposed using PK as an important part of the waste
characterization program for WIPP TRU waste, hopefully to replace more traditional avenues
such as sampling and analysis.  The accuracy of the PK code assignments is evaluated here
using the results of a 1988 DOE study which compared the assignment of Waste Content
Codes using PK to assignments  made by a hands-on, visual examination of each container.
This study is described in TRU WASTE SAMPLING PROGRAM: VOLUME I-WASTE
CHARACTERIZATION, EGG-WM-6503,  September 1985.

This attachment proposes a methodology for the application of a standard statistical test, the
Kappa Statistic, to evaluate the accuracy of the PK assignments of content codes to TRU
waste containers for the WIPP using a numerical score that ranges from 0 to  100 % accuracy
in classification ability.  The scoring methodology proposed here to quantify the accuracy of
the PK content code assignments may be applied to PK code assignments for  a single  .
sampled  container or to a collection of sampled containers.

Proposed Methodology

Under the proposed approach, the accuracy of using process  knowledge to predict the correct
content code for TRU waste  containers is evaluated by comparing the agreement between the
content code assigned on the basis of PK against the  "proper code" assigned on the basis of a
hands-on inspection (S&A).  The degree of agreement between the content code assigned  by
PK and the code assigned by S&A will serve as a measure of the accuracy of the PK waste
characterizations. Measures  of the degree of agreement can  be constructed for an individual
container or for a collection of waste containers.
                                         2B-1

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Estimates of the degree of agreement for verifying the accuracy of the PK waste
characterizations are based on the use of the Kappa4'5 coefficient as a measure of
agreement.  The Kappa coefficient compares the observed degree of agreement to the level of
agreement expected to occur by chance alone.  A coefficient of zero (0 %) is obtained if the
observed degree of agreement between the S&A and PK content codes is equal to that
expected by chance.  A coefficient of 1 (100 %) is obtained if there is perfect agreement
between the S&A and PK code assignments.  Estimates  of the standard error of estimates of
Kappa have been derived based on large sample properties of the estimator.

Examle Using Hpothetical Data
       2B-1 shows a hypothetical comparison of PK and S&A content code assignments for a
 single container.  For the PK method, a Yes (Y) or No (N) is recorded if the container
 contents conform to the requirements of the specific content code.  For the S&A method, a
 Yes (or No) is recorded based on whether the visual inspection indicated that the container
 conforms to the content code requirements.  The code assignment for a single container is
 described by the two columns of Yes and No responses in Figure 2B-1.  It is likely that these
 two waste characterizations will differ in one or more rows (content codes) for many or all
 of the sampled containers.  The Kappa coefficient provides a numerical measure of the
 degree of agreement between the two classifications.

 The statistical literature contains a variety of measures  of agreement between observed and
 predicted rates of occurrence. Most measures of agreement are based on the tableau shown
 in Figure 2B-2, which displays a cross-tabulation of the PK predictions versus observed S&A
 results.  The main body of the table is referred to as the sample classification error matrix,
 with agreement between the S&A and PK characterizations shown on the heavy-bordered
 diagonal, and disagreement between the two methods shown off the diagonal. The counts in
 the main body of the table have been divided by the total number of content codes to create a
 matrix of proportions, which add to 1.  The row and column  totals shown in the figure are
 used to calculate the degree of expected agreement due to  chance alone.
    4Fleiss, J.L., Statistical Methods for Rates and Proportions, 2nd. Ed., Chapter 12, Wylie & Sons, New
York, 1981.

   5Rosenfield, G., Fitzpatrick-LJns, C., "A Coefficient of Agreement as a Measure of Thematic
Classification Accuracy," Photogrammetric Engineering and Remote Sensing, Vol. 52, No. 2, February 1986.

                                         2B-2

-------
The upper-left entry in the table, Pn, shows the proportion of codes that were determined to
be present in the container using both methods. The lower-right entry,  P22, shows the
proportion of codes that were determined not to be present in the container under both
methods.  The sum of these two diagonal terms yields the total proportion of codes correctly
classified by  the PK method. The upper-right entry, P12, shows the proportion of codes
determined to be present using S&A, but not present using PK.  Similarly, the lower-left
entry P2j shows  the proportion of codes determined  to be present using PK, but not present
using S&A.  The sum of the two off-diagonal terms yields the total proportion of codes
incorrectly classified by the PK method.  The sum of all four entries in the table is 1.0
(100  %).

The coefficient of agreement, Kappa, is determined  by calculating  P0, the observed
proportion of codes with agreement between PK and S&A, by summing the diagonal terms
of the matrix:

             PO = Pn  + ?22                                       (1)

The expected degree of agreement that should  occur by chance alone is also calculated by
assuming that the PK characterizations have no statistical relation to the S&A
characterizations:

             Pe = aA  + bB                                       (2)

The coefficient of agreement is defined as

             Kappa = (P0-Pe)/(l-Pc),                                (3)

which is between zero and unity (100 % agreement  or 1.0) for all  samples  in which P0
exceeds Pe.

Fleis  notes that values of Kappa less than 0.40 (40 %) indicate poor agreement between the
two characterization methods, values between 0.40 and 0.75  (40 % to 75 %) indicate fair
agreement, and values over 0.75 (75 %) indicate good agreement of the two characterizations
methods.  If  all  waste containers are categorized correctly by the PK method,  there are no
off-diagonal entries.  In this case, the value of Kappa is the maximum value of 1.00.
Negative values of Kappa indicate that correct characterization  occurs at a rate less than that
expected by chance alone.

                                          2B-3

-------
Example Using TRU Waste Container Data

The upper matrix'of Figure 2B-3 shows the counts for each cell of the classification matrix
for the data contained in Tables '21 - 34 of EGG-WM-6503. The heavily bordered diagonal
cell of the matrix indicates agreement between PK and S&A. The cells off the diagonal
indicate that disagreement occurred in  35 cases:

•      18 cases where S&A determined a code was present and PK did not
•      17 cases where PK indicated a  code was present and S&A did not

The matrix of Figure 2B-4 shows  the proportions obtained by dividing each cell in the upper
matrix by 7904, the total nunber of possible waste code assignments for these containers.
The percent of correctly classified codes, obtained by summing the two diagonal cells of this
matrix, is 0.0240 + 0.9714 = 0.9956 (99.56 %) =  P0.

To evaluate how much better this  is than would occur by chance alone, the expected
proportion of correct classifications are shown in the matrix of Figure 2B-5. Each cell (i,j)
in this matrix was obtained by multiplying the corresponding row i total proportion by the
column j total proportion from the lower matrix in Figure 2B-3.  The sum of the diagonal
terms in this matrix is 0.0007 + 0.9479  = 0.9486 (94.86 %) = Pe

The raw score of P0 = 99.56 % correct classifications must be compared with Pe = 94.86 %
correct classifications that would be obtained by chance alone. The most improvement that
can be obtained over chance is 1 - 0.9486  = 0.0514 (5.14  %).  The PK approach obtained
only a portion of this total possible improvement, 0.9956 - 0.9486 = 0.0470 (4.7 %
improvement out of a possible 5.14 %  improvement).  Thus Kappa = 0.0470/0.0514 =
0.9144, and the standard error of this estimate is 0.0112, as discussed below.  Hence, in this
example,  PK obtained Kappa = 91 % of the total possible improvement.  Using the scoring
advice by Fleis noted above, this example rates a good classification, much better than
expected by chance alone.

The matrix of Figure 2B-6 provides another interpretation of the Kappa statistic. This matrix
was obtained by multiplying the expected proportions in the lower matrix by 7904 to obtain
estimates of the number expected in each cell of the matrix. By chance alone, 7499 codes
would be correctly classified out of 7904; 407 would be classified incorrectly.  The PK
method correctly classified 7,869 codes, 370 more than would be expected to occur by

                                         2B-4

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chance alone.  These 370 represent 91 % of the 407 that would be missed by chance. If all
407 that would be missed by chance were correctly classified by the P-K method, its score
would be 407/407, or 100 %.

Estimates of the  sampling error associated with estimates of Kappa are a function of N, the
number of waste codes that were considered times the number of containers, and the row and
column totals shown in Figure 2B-2.  The sampling error (SE)  of Kappa is given by:

                                 (Pe + Pe2 - U)1/2
              SE (Kappa) =       	                (4)
                                    (1-PJ N1/2

where
              U =  aA(a+A) + bB(b+B)                            (5)

The standard error of the estimated Kappa value is quite small  due to the large sample size
for this exercise.
                                         2B-5

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            1
            2
            3
            4
            5
            6
            7
            8
            9
            10
            11
            12
Waste
Content
Code
328
330
336
337
900
970
320
480
481
440
441
442
PK Result

-
-
-
X

-
-

-
-
-
S&A
Result
-
X
-
-
X
-
-
-
-
-
-
-
PK / S&A
Agreement
Code
N/N
N/Y
N/N
N/N
Y/Y
N/N
N/N
N/N
N/N
N/N
N/N
N/N
Notes:  x  Waste form matches content code description
          waste form does not match content code description
Figure 2B-1. Example of the Use of Visual Examination (S&A) and Process
             Knowledge  (PK) to Assign Content Codes to Waste Containers
                                  2B-6

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    PROCESS KNOWLEDGE
          RESULT
        Waste Form Fits
         Content Code


      Waste Form Does Not
        Fit Content Code
                                     VISUAL EXAMINATION
                                         (S&A) RESULT
YES
NO
           YES
           PII
                       NO
 ROW
TOTALS
                                a
COLUMN
TOTALS
                                                   B
                               1.00
Figure 2B-2.  Sample Classification Error Matrix for Evaluating Accuracy of
             Process Knowledge Waste Content Code Assignments
                                2B-7

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    PROCESS KNOWLEDGE
          RESULT
         Waste Form
       Fits Content Code


     Waste Form Does Not
       Fit Content Code
                                        SAMPLING AND
                                       ANALYSIS RESULT
 ROW
TOTALS
Figure 2B-3.  Classification Error Matrix of Counts for Waste Code Assignment
                                 2B-8

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                EXPECTED PROPORTIONS MATRIX
               FOR CONTENT CODE ASSIGNMENTS
                                     SAMPLING AND
                                    ANALYSIS RESULT
    PROCESS KNOWLEDGE
          RESULT
        Waste Form
       Fits Content Code


     Waste Form Does Not
       Fit Content Code
 ROW
TOTALS
Figure 2B-4.  Classification Error Matrix of Proportions for Waste Content Code
            Assignments
                              2B-9

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                                        SAMPLING AND
                                       ANALYSIS RESULT
ROCESS KNOWLEDGE
RESULT
Waste Form Fits
Content Code YES
Waste Form Does Not
Fit Content Code NO
COLUMN
TOTALS

YES
0.0007
^-^^—

NO
0.0256
ROW
TOTALS
0.0260
0.0257 1 09479 1 0.9740
0.0264
0.9736
1.0000
Figure 2B-5.  Classification Error Matrix of Proportions for Waste Content Code
             Assignments
                                2B-10

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                                          SAMPLING AND
                                        ANALYSIS RESULT
    PROCESS KNOWLEDGE
           RESULT
        Waste Form Fits
         Content Code


      Waste Form Does Not
        Fit Content Code


YES
NO
COLUMN
TOTALS

YES
6
^mmmm^m
204

209

NO
203
[•••••"•^
7493

7695
ROW
TOTALS
208
7696

7904
Figure 2B-6.  Classification Error Matrix of Counts for Waste Content Code
             Assignments
                                 2B-11

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Appendix 2C:       Goals of French HLW Waste Characterization Under Rule iii.l.F6

As required by Rule DI.2.f. each producer of waste destined for the deep geologic disposal
system must characterize its waste to establish a record of specifications for each family of
packages.  Such  evaluations have the following goals:

       to determine the radioactive characteristics of the waste packages,  especially long-
       lived and volatile radionuclides;

       to determine the chemical contents of the waste packages, especially to verify that
       they do not contain compounds that could increase radionuclide solubility;

       to know the nature and quantities of gaseous products associated with radiolysis,
       corrosion, and alteration of the package from irradiation or the effects of
       microorganisms;

       to evaluate the physical characteristics of the waste packages, including density,
       homogeneity, water content,  thermal  capacity, and mechanical and temperature
       characteristics; and

       to identify the properties of the packages, especially those associated with their initial
       ability to contain radioactivity, including leach rate in ground water, mechanical
       stability,  effects  of chemical  interactions, thermal effects, radiation effects and effects
       of microorganisms.

Additionally, the long-term behavior of waste must be studied  to determine in particular the
rate of degradation as a function of  time, the nature of the degradation products, and the
interactions between these products and the contained radionuclides. The studies must
determine the chemically stable  forms of radionuclides in the existing local conditions (pH,
Eh,  etc.) as well as the  relation between their solubility and the characteristics of the host
environment.  The goal of these studies is both to allow the evaluation of the containment
capability of the waste package  and  to estimate the influence of the waste package on the
containment capabilities of other barriers.
    6 Rule No. HI.2.f, June 10, 1991, "Definition of objectives to be met during the study phase, and of the
       work for final storage of radioactive waste in deep geologic formations, in order to assure safety after the
       period of using the facility."

                                           2C-1

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                       3.  Uncertainty and "Reasonable Expectation"

3.1.   Introduction

3.1.1 Background

Geologic disposal of radioactive waste in repositories is an unprecedented engineering
project.  As stated in EPA's 40 CFR part 191 disposal standards, "Because of the long time
period involved and the nature of the processes and events of interest, there will inevitably be
substantial uncertainties in projecting disposal system performance.  Proof of the future
performance of a disposal system is not to be had in the ordinary sense of the word in
situations that deal with much shorter time frames."

Several physical processes take place both in series and in parallel over the design life of the
WIPP.  Because of uncertainty propagation, a calculation based on worst case values for each
input parameter across all processes  would yield design values beyond reason.  This is only
one dimension of the uncertainty issue.  A paper presented by Zuidema of Switzerland's
National Cooperative for the Storage of Radioactive Waste (NAGRA) at a 1991 NEA
workshop on criteria for HLW disposal identified four  sources of uncertainty in disposal
system safety  analysis:

       •      uncertainty  in scenarios;

       •      uncertainty  in conceptual models;

       •      parameter uncertainty; and

       •      parameter variability.

Recognizing these uncertainties,  the disposal standards  state that there should be "a
reasonable expectation ...  that compliance ... will be achieved." This phrase represents a
general principal for due consideration of (1) the uncertainties involved in projecting disposal
system performance for 10,000 years, and (2) the entire record submitted to the
Administrator.

The goal of the WIPP  compliance assessment is to develop predictions of the distributions of
the cumulative release, doses to  individuals, and radionuclide concentrations in ground water
over 10 000 years at the WIPP disposal site (SNL 92, HEL 93a). These distributions are
functions that  indicate the probability of exceeding various levels of three parameters:

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cumulative releases, doses to individuals and ground-water concentrations.  Ideally, a single
function for each parameter would be formed by combining distributions resulting from all
possible scenarios, after considering all uncertainties in scenarios, in conceptual models, in
parameter uncertainty, and in parameter variability over the 10,000-year regulatory horizon
mandated in 40 CFR part 191.

Certain physical parameters may remain unchanged over 10,000 years, but changes, for
example, in geology and climate, must  be forecast. Among the scenarios of interest is the
number of times humans will inadvertently intrude into the disposal system in search of
resources.  EPA's concern in compliance assessment is all human-initiated processes and
events.  The DOE has developed a human intrusion scenario (SNL 93a, HEL 93b) with sub-
scenarios including two different intrusions:  the first is a penetration of the disposal system
and a brine pocket below the disposal system which allows brine to enter the disposal
system; the second is the interception of the disposal system without hitting a brine pocket.
Both events result in the release of the radionuclides to the accessible environment from the
cuttings associated with drilling operations.

The predictions generated by the WIPP compliance assessment model for a variety of human-
initiated processes  and events are made conditionally:   if scenario A occurs and the model
parameters are assigned  certain values,  then the model predicts the distribution of releases
under a specific  set of assumptions.  The predictions are made using very elaborate computer
codes requiring many input parameters  to define the scenarios and their implications.  These
input parameters may be based on actual data or on expert judgments.

To date, most work on DOE's compliance assessment has been to refine  the details of the
conditional evaluations, conducted for a few specific scenarios of particular concern.  Many
low- probability  scenarios have not been considered due to a screening  process that  selects
only "significant" scenarios.  For these selected significant scenarios, the model generates a
conditional distribution for the summed normalized release for each set of input parameters
run through the model.  The input parameters have been assigned uncertainty distributions.
The scenarios  have been assigned probabilities, although the uncertainty in these assigned
scenario probabilities (such as by assuming uncertainty distributions or  rate parameters) has
not been quantified to date in the scenario screening process.

3.1.2  General Approach to Evaluating  Compliance

This section summarizes available regulatory approaches for dealing with uncertainty.  The
                                          3-2

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following describes a common situation in the application of statistical methods to
environmental control problems. The random variable R denotes the  cumulative release of
radionuclides frorn a disposal system, while a fixed numerical limit (L) is selected as the
maximum allowable release for the disposal system.  Unless there is a strict upper bound on
its distribution, the random release cannot be proved to satisfy a specific mathematical
constraint of the form "R is less than L."  At best, if the probability distribution of the
release is known exactly, then the probability that the release is less than the regulatory limit
may be calculated from the distribution.  This probability is denoted by  the notation Pr{ R <
L }, which is read as the "probability that R is less than L."

For most regulatory applications, it is sufficient to require that the probability of the release
being less than the regulatory limit is large. Probability values near 100 percent would be
necessary to ensure that compliance is almost always obtained.  Let the  symbol P denote this
high level of probability. Under this interpretation, the regulatory requirement would be
written  as

                                    Pr{ R < L }  >  P

An equivalent statement of the regulatory requirement is that  the P* percentile of the
distribution of R be less than the regulatory limit L.  Let Rp denote the P* percentile of the
distribution of R.  Using percentiles, the regulatory requirement may  be written as
                                         RP < L

Under either of these equivalent interpretations of the requirements in 40 CFR section
191.13(a), there would be at least a probability P that the random release is less than the
regulatory limit.  In this case of a known distribution for the  release,  all that remains is to
select the appropriate value of the required probability (P), and the appropriate value for the
release  limit (L).

If this were an enforcement problem for a hypothetical nuclear plant,  the distribution of the
release  could be determined by going to the site  and measuring radionuclide releases from
the stack.  From these observations,  collected over time, the distribution of the random
release  could be estimated, leading to a compliance determination based on data and standard
statistical procedures.

In this example, the need to estimate the distribution of the release from sample values
results in a sampling error for the estimated probability that the release is less than the
                                           3-3

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regulatory limit.  If the percentile interpretation is used, there will be sampling error in
estimating the P* percentile of the distribution.  These sampling errors  should be considered
when comparing the estimated probability or percentile to the requirement.  A 90 or 95
percent confidence interval is often used for sample-based estimates of the probability or
percentile.  If the confidence interval lies entirely below the required value, the power plant
is determined to be in compliance at the appropriate level of confidence.  If the resulting
confidence interval was too broad to reach a clear determination of compliance, more
observations  could be collected to reduce the confidence interval.

Confidence interval procedures are designed to be applied to samples of observations on the
random variable of interest. As more and more observations are collected,  more and more
information is gained about the distribution of the random variable, and the resulting
confidence intervals on the estimated probabilities and percentiles  become smaller and
smaller.

There is a fundamental difference between this well-known  procedure of collecting actual
observations  on a random variable and the process of making predictions of a random
variable.  As more and more predictions of a random variable are generated, there is no
guarantee that more information is generated about the true distribution for  a future
realization of the'random variable.

Unlike the simple nuclear plant example above, the subject  of analysis for the WIPP disposal
system is the distribution of cumulative releases of radionuclides to the accessible
environment  over a 10,000-year time frame.  Because the cumulative release for this site is a
future realization of a random variable, its prediction involves considerable  uncertainty.  At
best, estimates of the probabilities and/or percentiles  are required  to verify compliance.  Due
to the uncertainty intervals surrounding these estimates, there can  be no absolute assurance
that the probability statements contained in the regulations are satisfied.  At best, compliance
can be determined only to within a certain level of confidence.

Estimates derived from the WIPP compliance assessment modeling system will have errors of
prediction associated with each estimate produced by the  model.   However, unlike the
sampling problem referred to earlier, the "confidence intervals" for the estimates are not
necessarily reduced by running the model repeatedly, generating more and more predictions
based on the  same assumptions.  Rather, the WIPP performance assessment has attempted to
reduce the  "confidence intervals" or, more generally, the uncertainty interval surrounding the
estimated probabilities  and percentiles by running the model under a wide variety of
                                          3-4

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assumptions.

The current WIPP compliance assessment model addresses two sets of uncertainties:

       1) the uncertainties surrounding probability distributions selected for values of
       parameters used as WIPP compliance assessment model inputs;  and

       2) the uncertainties surrounding the definition, screening, and  quantification of
       possible future scenarios and their probabilities.

DOE has expanded its efforts to quantify uncertainty distributions for the input parameters,
thus reducing uncertainty due to the first type of assumptions.  Panels of experts have
addressed the probabilities of future scenarios in an attempt to reduce uncertainty regarding
the second type of assumptions.

In the nuclear plant example, there was a possibility of reducing the size of the confidence
intervals of estimates by collecting more observations at the site.  In the prediction problem,
only one method is available for reducing the uncertainty of the resulting estimates.  This
method involves quantifying the uncertainty associated with the assumptions on which the
forecast  is based.  The uncertainty surrounding model input parameters  may be estimated by
specifying probability distributions for these parameters based on the  best knowledge of the
disposal  system.  If the uncertainty distributions are  developed based  on observations of the
variability of physical parameters  measured at the WIPP site, then uncertainty intervals
surrounding these physical parameters can be reduced further by collecting more information
about the site, waste  characteristics, and their interactions.  This leads to a greater reduction
in uncertainty concerning the estimated probabilities and percentiles for the total release.
Thus,  uncertainty due to the first set of assumptions may be reduced by collecting more
information about the model input parameters.

The selection of possible future scenarios and the probabilities assigned to these scenarios in
the second set of assumptions involve a different type of uncertainty.  Some variables that
could conceptually be related to the scenario  uncertainty problem have been proposed. For
example, the option EPA is considering involves using current and historic drilling rates in
the area  to establish a suggested value for the frequency of human-initiated processes and
events over the next 10,000 years. The  collection of more data of this  type may improve
estimates of current drilling rates but does not reduce all  of the uncertainties involved with
long-term permanent  disposal.
                                           3-5

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Because of the difficult problem in evaluating scenario probabilities, DOE, until recently, has
concentrated on reducing the uncertainty of the conditional distribution of the projected
release, given that'a particular scenario occurs.  These scenario-specific analyses have been
the main thrust of the most recent compliance assessments, which concentrate particularly on
the human-intrusion scenario.  The selection of a specific scenario or set of scenarios for
analysis introduces an additional level of uncertainty in the determination of compliance.

In the 1992 compliance assessment, 70 random selections were made from  the input
parameter uncertainty distributions, and the model was run for each set to generate an
estimated distribution for the cumulative release. The eventual plan is to combine these sets
of scenario-specific distributions into a single, unconditional  distribution for the performance
of the site over the 10,000-year time period.  The step of reducing to a single curve was
suggested in the guidance for Appendix B to 40 CFR part 191. The use of probabilistic
input parameters and subjective expert panel opinion on scenario probabilities to determine
compliance with the regulatory requirements of 40 CFR part 191 entails a large degree of
uncertainty.  Because uncertainty surrounding the determination of compliance is inevitable,
at best only a high probability of compliance  with the regulatory requirements' can be
achieved.

3.1.3  Outline of Chapter 3

The following section presents a formalized concept of the probability of compliance.
Applications of the probability of compliance concept to a variety of compliance criteria are
discussed.  The alternative criteria for compliance are compared and the advantages and
disadvantages of each noted in Section 3.3. Section 3.4 reviews other regulatory examples
of concepts related to reasonable expectation.  Conclusions and recommendations are
presented in Section 3.5.

3.2    Probability of Compliance

3.2.1 Review of the Probabilistic Requirements of 40 CFR part 191

40 CFR section 191.13(a) contains the following regulatory requirements:

       Disposal systems for spent nuclear fuel or high-level or transuranic radioactive wastes
       shall be designed to provide a reasonable expectation, based upon performance

                                          3-6

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       assessments, that cumulative releases of radionuclides to the accessible environment
       for 10,000 years  after disposal from all significant processes and events that may
       affect the disposal system shall:

              (1)  Have a likelihood  of less than one chance in 10 of exceeding  the
              quantities  calculated according to Table 1  (Appendix A);  and

              (2)  Have a likelihood  of less than one chance in 1,000 of exceeding ten times
              the quantities calculated according to Table 1 (Appendix A).  [Italics added for
              emphasis.]

Table 1 of Appendix A of 40 CER part 191 defines a set of permissible release limits for the
isotopes of concern.  In  instructions accompanying this table,  guidelines are suggested for the
appropriate use of Table 1 quantities  in conducting a  compliance assessment.  For each
isotope, the ratio of the predicted cumulative release to the accessible environment over
10,000 years to the permissible  release limit listed in the table is to be calculated.  The ratio
thus obtained is often referred to as the "normalized release" for each isotope. The
normalized releases for all isotopes in the table are then  added together to form the sum of
the normalized releases.   For example, the  limit given in Table 1 for cumulative  releases of
each listed plutonium isotope to the accessible environment for 10,000 years after disposal is
100 curies per unit of waste  disposed of at the site.  If the estimated cumulative release over
10,000 years for the isotope  is  70 curies per unit of waste, the normalized release for this
isotope is calculated as 70/100  = 0.70.  The normalized release is  to be calculated in this
fashion for each isotope  in Table 1.

The sum of the normalized releases for all isotopes disposed of at the site is used for
evaluating the probabilistic requirements 1 and 2 in 40 CFR section 191.13(a) given above.
To satisfy 40 CFR 191 section  191.13(a)(l), there must  be a reasonable expectation that the
probability of the sum exceeding 1  is less than 10 percent.  To satisfy 40 CFR section
191.13(a)(2), there must be  a reasonable expectation that the probability of the sum
exceeding 10 is less than 0.1 percent.  In terms of percentiles, the  90th percentile of the
distribution of the summed normalized releases must be  less than 1, and the 99.9th  percentile
must be less than 10.  40 CFR section 191.13(a) requires that estimates be  made for two
upper percentiles of the distribution of releases and specifies upper limits on these
percentiles.

Due to the stochastic nature of the Poisson model selected for the number and timing of
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intrusions over the 10,00-year time period, the WIPP compliance assessment model outputs
for each run of the model are expressed as probability distributions.  To construct this
distribution, the model calculates the summed normalized release (termed simply the
"release" in this discussion) and its probability of occurrence for each intrusion sub-scenario.
The cumulative probability distribution for the release is obtained by sorting the estimated
releases for each sub-scenario in increasing order.  The ordered releases and their associated
probability values are then used to construct the cumulative probability  distribution, which is
a step function defined over the range of release values which are called the arguments of the
function.  The step function starts at zero for a release value of zero. At each estimated
value of the release, the function steps up by an amount equal to the associated probability of
the release.  The cumulative distribution function so defined is a  non-decreasing function
which cannot exceed the value of unity (1). The value of the function is equal to the
probability that the release is less than or equal to the value of the argument of the function.
The Complementary Cumulative Distribution Function (CCDF) is defined as the difference
between the cumulative distribution function and the value 1.  The probability and percentile
limits set forth in 40 CFR section 191.13(a)(l)&(2) and the reasonable expectation of
compliance concepts are described in terms of the CCDF of the summed normalized release
variable. The value of the CCDF function gives the probability that the release is greater
than the value of the argument.  The CCDF for the random variable R is  denoted by the
function

                                F( r )  = Pr{ R  >  r }.

The function F( r ) is always between 0 and 1,  and  can never increase as  r increases.  Using
the CCDF function, 40 CFR sections 191.13(a)(l) and (2) are commonly  written in statistical
terminology as:

       (1)   F(l)  < 0.1;  and
       (2)   F(10) < 0.001.

An equivalent statement of the regulatory  requirements written in terms of the 90* percentile
(denoted by  R9)  and the 99.9th percentile (denoted by  R^) as

       (1)   R9 < 1;  and

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       (2) .R^ < 10.

Because the summed normalized release is not only a random variable, but a random variable
with a distribution that can be predicted only with a considerable degree of uncertainty, only
estimates  of the probabilities and percentiles (i.e., the quantities written on the left side of the
four inequalities above) can be developed.  Each estimated probability and percentile will
have an error of estimation.  One interpretation of the concept of reasonable expectation is
that there must be reasonable evidence that all or most of the uncertainty intervals for the
estimated percentiles and probabilities will fall below the designated regulatory requirements.

3.2.2  Statistical Interpretation of the Requirements of 40 CFR part 191

As noted  in the introduction, a random variable with no  strict upper bound cannot be
"proved"  to satisfy a specific mathematical  constraint of the form R < L, where the limit L
is a specified  number.  This  situation is encountered often in the application of statistical
methods to environmental problems.  The random variable R denotes a random level of
emissions and the  fixed numerical limit L is the maximum allowable emission, for the
substance under consideration.   If the probability distribution  of the emission R is known
exactly, then an exact estimate of a percentile or a probability may be derived by calculus.
If this probability  is large (i.e., near  100 percent),  then it would be "almost always" true that
the emissions are less than the regulatory requirement.

The order of the inequality inside the probability statement may be reversed.  In  this case,
the probability that R exceeds L would be required to have a small value.  The requirement
then would be stated as

                                    Pr{R  >  L}  < Q,

where Q is a small probability value.  Using the CCDF  function notation, the regulatory
requirement is stated as

                                       F (L)  < Q.

The values Q! =0.1 (10 percent) or Q2 =  0.001 (0.1 percent) are used in 40 CFR section
191.13(a) at two different values of the radioactivity release, LI = 1 and L; = 10,
respectively.

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The required estimate of a probability or percentile can be calculated from the known
distribution and compared directly to the proscribed probability level.  This procedure
provides a simple "Yes"  or "No" answer for determining compliance with the probabilistic
requirements of 40 CFR part 191.

If the distribution of R is not known exactly, then the above approach is not sufficient to
define compliance with the regulatory requirements in a statistical framework. The estimated
probabilities or percentiles will have an associated uncertainty interval because the exact
distribution of R is unknown.  Hence, there will be uncertainty in determining if the
estimated probability is less than the target probability.  This uncertainty in determining
compliance could be addressed in two ways.  Careful review of the modeling procedures and
the record before the Agency by panels of expert reviewers could be used to increase the
level of confidence in the reported results.  Or, a statistical determination of compliance
could be made from  the reported results by conducting a hypothesis test at a specified level
of confidence.  These two approaches are  discussed in more detail in the  following sections.

3.2.3  Use of Expert and Peer Review for Determining Level of Confidence

The use of statistical methods  alone cannot assure that predicted releases of radionuclides to
the accessible environment from the WIPP disposal site will comply with the regulatory
requirements of 40 CFR part 191. This is clearly recognized in Appendix B to 40 CFR part 191:

       In making these various predictions, it will be appropriate for the  implementing
       agencies to make  use of rather complex computational models, analytical theories,  and
       prevalent expert judgment relevant  to the numerical predictions. Substantial
       uncertainties are likely to be encountered in making these predictions. In fact, sole
       reliance on these numerical predictions to determine compliance may not be
       appropriate;  the implementing agency may choose to supplement  such predictions
       with qualitative judgments as well.

From this perspective, a  compliance determination would be based on the entire record
before the Agency, including both qualitative and quantitative evaluations.  For each of the
quantitative requirements in the regulations, the determination of reasonable expectation may
be based on quantitative analyses as specified in the regulations,  supported by qualitative
judgment of the degree of confidence in the reported WIPP compliance assessment results.

A qualitative assessment  of the degree of confidence may be derived from the formal review

                                          3-10

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process.  The review process would comprise empirical testing of the model components, a
complete review of the documentation of the model, evaluation of all significant
uncertainties, and peer review involving assessment of the assumptions and findings reported
in the WTPP compliance application.

The testing of model components would include evaluation of the physical basis for the
model, verification  of the numerical accuracy of the calculations performed by the model,
validation of approximations made in the calculations, and review of the probability
distributions assigned to uncertain input variables.

Peer review of the compliance assessment would provide a basis for determining the
adequacy of the models used  for compliance evaluations.  Reviewers could develop and test
alternative approaches to the problem and look for unspecified assumptions that may not be
clear in the documentation.  The process  of validating model components is a dynamic one,
requiring modifications and refinements to the model as shortcomings are identified.  This
dynamic process often leads to a lack of documentation on the current status of the model.
Complete and up-to-date  documentation is an essential requirement for model quality
assurance (QA) and peer review.

The peer review process provides an additional level of confidence for the reported numerical
results of the compliance assessment process. However, the quantitative nature of the
requirements of. 40  CFR  section  191.13(a) implies that qualitative evaluation alone is not
sufficient for determining compliance.  In the following sections, quantitative measures of the
degree of confidence obtained by statistical procedures are reviewed.

3.2.4  Use of Statistical Methods for Determining Compliance

Many statistical methods  can  test  hypotheses about the distribution of R when the distribution
is not known exactly but  must be estimated.  The methods primarily differ according to the
assumptions made concerning the form of the unknown distribution.  These methods
generally are classified as parametric or non-parametric.

Parametric methods contain specific assumptions concerning the form of the probability
distribution for the  variable to be tested.  A particular .family of probability distributions,
indexed by one or more parameters, is selected as a general model for the observed data.
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Estimates of the parameters are made from the data to select from the family a specific
distribution to use for the hypothesis test. A typical parametric example is the use of the
family of normal or Gaussian distributions parameterized by a population mean and a
population variance which is the square of the standard deviation. The normal distribution
has the familiar "bell-curve" shape, being symmetric about the mean of the distribution.
Furthermore, the mean, median (or simply stated the middle value), and mode (that is,  the
most likely value) are represented by the same point of the distribution. Parametric methods
begin by estimating the unknown mean and variance parameters of the distribution using the
available data, denoted by Xls X2, ... XN, A typical estimator for the population mean  of the
normal distribution is the simple average:

                                     M = E Xj / N

A typical estimator for the population variance is the mean squared variation of each  data
point Xj from the estimated mean:

                               V  = E (Xj - M)2 / (N - 1)

The population standard deviation is estimated as the square root of the variance of the  data
samples.

Each  of the estimated parameters has an associated measure of sampling error. In the case
of the estimated mean, its sampling variance (V^ is estimated by dividing the population
variance by the sample size N:  VM  = V / N.  The standard error of the mean SE(M) is
calculated as  the square root of VM.  Thus, the standard error of the mean is smaller  than the
population standard deviation by a factor equal to the square root of sample size N.  As the
number of observations increases, the standard error of the estimated mean is reduced by a
predictable amount.  Estimates of the sample size required to reduce the standard  error of the
mean to specified levels may be derived based on this relationship.

Parametric models such as the normal distribution also are used for testing hypotheses.  A
typical parametric hypothesis test for the mean of the normal distribution would begin by
estimating the mean and the standard error of the mean using the procedures above.  If it is
necessary to determine if the mean is below a specified upper limit  (L), then the hypothesis
test is conducted by comparing the estimated mean to the limit L.  Because there  is sampling
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error associated with the estimated mean, the actual comparison is made using the upper
bound of the confidence interval for the estimated mean:

                                  M + k,SE(M)  < L,

where k, is selected to provide the appropriate a% confidence level for the test.

The lognormal distribution is often used as a parametric model for environmental quantities.
This distribution,  which is defined for positive variables only, is not symmetric, but highly
skewed to the right or left (If there is a long tail on the  right (left) side of the distribution
which extends up to large values of the variable then it is referred to as positively
(negatively) skewed).  The probability distribution for the lognormal is obtained by an
exponential transformation from a normal variable.  If the variable X has a normal
distribution, then  the transformed  variable Y = ex is said to have the lognormal distribution,
because the (natural) logarithms of Y values have a normal distribution. Applying the
exponential transformation to the mean of the normal distribution, which is also the median,
with probability of 0.5 below the  median and 0.5 above the median, yields an estimate of the
median of the lognormal distribution.

Parameter estimates for the lognormal distribution are typically derived by taking logarithms
of the lognormal observations (Y1; Y2, ..., YN), then applying the estimators defined above
for the mean and  variance of the normal distribution.  For example, the simple average of
the logarithms of the Yj values is  an estimate of the mean (and median) of the transformed
normal distribution.  The exponential function is then applied to the average  of the
logarithms to calculate an estimate of the median  of the  associated lognormal distribution.
This procedure often is described  as calculating the geometric mean of the lognormal
observations, which provides the same estimate for the median of the lognormal distribution.
Furthermore, f experts provide judgments on the  upper  and lower percentiles of the
distribution an estimate can be made for the variance of the lognormal  distribution.
Knowledge of these two parameters (the mean and variance) completely defines the
distribution.

Parametric hypothesis tests for the lognormal follow the same general procedures as for the
normal distribution.  Tests for the median of the lognormal distribution are simpler than for
the mean of the lognormal and  follow the same procedure as the test for the mean of a
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normal distribution.  The mean of the logarithms of the observations (plus a multiple of the
standard error) is compared to the logarithm of the regulatory limit L.  Tests for the mean of
the lognormal require more detailed calculations to determine the standard error of the
estimated mean.

The use of parametric methods is based on several assumptions.  The most important of these
is the selection of a particular family of distributions as a probability model for the data.
Generally, a large number  of observations is required to determine if this assumption is
correct.  However, even with a small number of observations, it may be obvious that certain
families of distributions may not be applicable.

Non-parametric statistical tests, by comparison, make minimal assumptions concerning the
specific probability distribution for the observed random variable.  The usual assumption that
the variable has a probability distribution with a defined mean and variance is very general.
In terms of modern statistics, non-parametric statistical tests of hypotheses are considered
"robust" with respect to assumptions made concerning the form of the distribution of R. The
results of a  robust statistical test will be affected less than a non-robust test if the actual
distribution  of the data departs from the assumed distribution.

Specifically for the case when the distribution of the normalized release is not known exactly,
40 CFR sections 191.13(a)(l) and (2) may be written as two statistical  hypotheses (Hj and
Hj) to be accepted or rejected by applying a statistical test. Using the CCDF approach,  these
hypotheses can be stated as:

             (1)  Hii  F( 1 )  < 0.1; and
             (2)  H2:  F( 10 )  < 0.001.

Or, in terms of percentiles, the regulatory requirements may be expressed as:

             (1)  Hj:  R9 < 1; and
             (2)  H2:  R-999 <  10.

More generally, a single hypothesis referred to  as the "joint null hypothesis" may be written
in terms of the  CCDFs as

             H0:  F(L.)  < Q,  fori = 1,2;
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or,  in terms of percentiles as

              H0: RH < 1^,  fori = 1,2;

with PJ, Q; and L; defined as above.  The joint null hypothesis is to be tested against all
alternatives.  If there is no sufficient statistical evidence to reject the null hypothesis, then the
null hypothesis is said to  be "accepted." Note that the statistical hypothesis testing procedure
does not "prove" that the null hypothesis is true; it states only that no sufficient statistical
evidence could be found to reject the null hypothesis.

Hypothesis tests concerning probability statements such as H0: F( L;) < Q or H0: RR < L;
when the distribution is not known with certainty are generally based on samples obtained
from the distribution of the random variable.  The  degree of "truth" obtained by applying
these hypothesis tests for probabilities or percentiles of predicted future realizations of the
random variable R is more difficult to quantify.  In this case, the "truth" of the results can be
assessed only probabilistically.  The probability of compliance with 40 CFR part 191 may be
estimated using simulation results to characterize the uncertainties involved in. estimating the
future distribution of the  random release.  To assess these uncertainties, it is necessary to
consider in more detail the modeling methods used to  predict the distribution of normalized
releases in the WIPP compliance assessment methodology.

3.2.5 Use of Sampling Methods

The compliance assessment modeling process applies two stages of analysis.  In the first
ซtoge, a set of scenarios is selected for evaluation.  Subjective probabilities are assigned to
 he scenarios.  In the 1992 compliance assessment, scenario probabilities are generated based
jn the results of expert panels, which addressed the likelihood of human-initiated processes
and events and the deterrent effect  of markers.  In the second stage of the analysis, the
compliance assessment model evaluates the summed normalized release for each scenario.
At this stage, specific values for the physical parameters of the model must be selected.
Rather than being assigned a single value, each important input parameter has been assigned
a probability distribution  that reflects the uncertainty in the value of the parameter. (These
distributions  have been assigned independently for each parameter.)  The model is run
repeatedly, using a Monte Carlo simulation approach to generate a  distribution of possible
values for the summed normalized  release.
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This approach is widely accepted, and is currently being followed by DOE for the WIPP
compliance assessment and both DOE and NRC for the Yucca Mountain compliance
assessments.  However, other sampling  strategies, generally known as  "importance sampling"
(WCJ 93) have non-equal p.  babilities in order to concentrate the samples in the region of
parameter space where the models have the greatest sensitivities to parameter variations.
The purpose of importance sampling is to increase sampling efficiency in order to reduce the
computational workload while minimizing the need for model oversimplification or reduced
coverage of the parameter space. Furthermore, 40 CFR part  191 requires only the
determination of two points on the CCDF at probabilities of 0.1 and 0.001.  The  rest of the
CCDF is not significant to determine these compliance points.  (That is not to say that only
two points are considered in the compliance determination; other information is not
discarded.  It is only after all information has been organized  into a CCDF that it reduces to
this two point test.  Because the CCDF  algorithm orders the scenarios  by calculated release,
the approach to the release limits is closest at these two points.) Techniques such as
importance sampling might be able to develop the compliance points with far fewer samples
than the Latin Hypercube Sampling (LHS) Monte Carlo technique selected by  DOE for
WIPP compliance assessment (SNL 85).

In the general Monte Carlo  approach, a single value for each input .parameter would be
sampled independently from the appropriate  distribution for the variable within each run of
the model. The LHS method is based on dividing the parameter distribution into  strata
which are intervals of equal probability.  An interval is selected, then a random sample is
drawn from the selected interval of the distribution.  The effect of the  LHS procedure is to
ensure a more uniform spread of sampled values over the entire range  of the parameter
distribution than might be obtained by simple Monte Carlo sampling. The LHS procedure
would be unnecessary if large sample sizes could be used for the Monte Carlo simulation.
Due to the complexity and sometimes costs of the computer models, only a relatively small
number of samples are used currently.  For small sample sizes, the LHS procedure provides
a more efficient sampling technique in comparison to alternatives.

Many types of probability distributions are used to describe the uncertainty in  the WIPP
compliance assessment model input parameters. Physical parameters used in the model are
assigned distributions based either on available data  or the subjective opinion of experts.
Some distributions, based on actual data, do not belong to a known family of distributions.
These distributions are constructed directly from the observed data by  forming the cumulative
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distribution function.  Other families of distributions selected for the model input parameters
typically include the beta, gamma, exponential, normal, lognormal, uniform, loguniform,
discrete uniform, binomial, and Poisson distributions.  The beta, uniform, and loguniform
distributions are appropriate for parameters that are assumed to lie in an interval between two
known endpoints.  The gamma, exponential, and  lognormal distributions are appropriate for
positive parameters with distributions which are skewed to the right, with a long tail
extending to higher values of the parameter. The first six families of probability
distributions are defined for variables that can take a continuous range of values.  The
discrete uniform, binomial, and Poisson distributions are appropriate for parameters that have
only integer values.


In summary, the WIPP compliance assessment modeling process may be described as a two-
step procedure:


       1.   A complete set of possible future scenarios, denoted by the set {SJ5 j = 1, ...,  J}, is
            developed conceptually with the understanding that all possible outcomes have
            been included.   The scenarios are then assigned probability distributions,  which
            must sum to 1 over all scenarios.  Although uncertainty in these scenario
            probabilities should be considered at  this stage, such consideration has not been
            noted in the compliance assessment reports through 1992.

       2.   At this stage, a  specified number of independent samples are selected  by  the
            LHS procedure  from the subjective uncertainty distributions assigned to the input
            parameters of the model.  The LHS procedure has been enhanced by R. Iman to
            minimize  spurious correlations among input variables. Specified pair-wise
            correlations can be contained in the analysis.  The model is then run for each
            LHS sample S,  generating N CCDFs for all scenario Sj. Using all scenarios j,
            and each list (or vector) of subjective distributions on model input parameters,  N
            distribution functions  are computationally generated (where N = number of
            sample vectors taken using the LHS procedure.) Not all scenarios were analyzed
            as commented in the 1992 compliance assessment.  For the scenarios  analyzed,
            each LHS model run generates a different  CCDF Fn for the distribution of the
            summed normalized release.

3.2.6  Conditional Probabilities of Compliance


It may be possible to reduce the set of N LHS CCDFs for each scenario to a single
probability distribution.  This reduction may be accomplished in two steps. First,  the set of
LHS curves for each scenario can be reduced to a single distribution for the normalized
                                         3-17

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release.  The resulting distribution would be conditional in the sense that the scenario would
be assumed to occur with a probability of 100 percent.  Second, the conditional distributions
for each scenario would then be weighted by the scenario probabilities and combined into a
single (unconditional) curve  for the WIPP site.  This approach was not applied since single
probability estimates were not used.  Instead, probability distributions were assumed by DOE
for the scenarios and a mean CCDF was  calculated for the collection of scenarios using a
sampling based approach.

Several methods have been proposed to reduce the set of LHS CCDFs to a single curve
involving all  scenarios (SNL 92, ESL 92).  The methods for reducing to a single CCDF
include using these aspects of the LHS CCDF values:

       1.  the mean which  is the simple arithmetic average (i.e. a vertical averaging of the
           generated CCDF curves;
       2.  the median which is the 50th percentile;
       3.  selected upper percentiles (those higher than the median);  or
       4.  selected order (or rank) statistics (e.g., the maximum which is the highest of the
           ordered observations, the second highest, etc.)

As stated, 40 CFR sections 191.13(a)(l) and (2) require that estimated releases be evaluated
at the two values of the summed normalized release:  R = LI  = 1 and R = 1^ =  10.
However, it is informative to generate the entire CCDF for the scenario in graphic form.
An example of the reduction of 10 LHS CCDFs to a single curve using the maximum of the
set of LHS CCDFs is shown in Figure 3-1.  The maximum curve (an example of alternative
4 above) is the solid line labeled A in the figure. The maximum curve, defined as a function
of the normalized release R,is also defined to have the highest value of the set of LHS CCDF
probabilities at each value of the release.

Figure 3-1  also includes a graphic representation of the requirements of 40 CFR sections
191.13(a)(l) and (2) indicated at the corners (1 and 2, respectively) of the step function (line
B) in the upper right corner  of the figure. The  regulations proscribe probabilities of release
in the region  above and to the right of this step  function.  In this example, the maximum
curve complies with 40 CFR section  191.13(a)(l) at R =  1 = 10ฐ, while it slightly exceeds
40 CFR  section 191.13(a)(2) at R =  10 = 101.

Although graphic represeritation of the entire curve helps in visualizing the curve reduction
procedures, the entire curve  need not be calculated to determine compliance in the strict
statistical interpretation of the regulations. Returning to the discussion of Figure 3-1, the

                                         3-18

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 oc
 A
 O
 0)
 CD
 ฃ
 O
 ฃ3
 CO
 O
 QL
 Maximum curve
 Requirements of 40 CFR 191
 1 =  40 CFR 191.13(a)(1)
 2 =  40 CFR 191.13(a)(2)
 Intersection points
         10H
10"
10-
10
10'z
10'1
10ฐ
101
                              Summed Normalized Releases, R
               Figure 3-1.  Ten Hypothetical LHS CCDFs, with Maximum

dotted line C marks the value of R = 1 = 10ฐ.  To complete the requirement, in 40 CFR
section 191.13(a)(l) a similar line could be drawn to mark the value of R = 10 = 101.  The
equivalent of reduction to a "single, curve" is obtained by applying one of the four methods
of curve reduction noted above to the set of point estimates shown by the large dots along
line C.  The set of 10 points along line C represent 10 independent estimates of the
probability that the normalized release exceeds 1. Although equivalent calculations may be
performed for the entire CCDF, only points on the curve noted in the figure need to be
considered in determining compliance. A similar process would be applied along the line R
= 10 = 101.  Both sets of point must be considered for the 40 CFR part 191.13(a)
compliance test.

Figure 3-2 shows  the mean (A), 90th percentile (B), and median (C) of a set of LHS  CCDFs.
The use of the mean was considered as the first alternative method for reducing to a single
CCDF, while the  median was the second alternative, and the 90th percentile is an arbitrarily
                                         3-19

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ฃC
 A
 1
 0>
"S
CC
 S
 D.
A =  Mean
B =  90th prcentile
C =  Median
        10"
   10
                   10'1     10ฐ     101
Summed Normalized Releases, R
    Figure 3-2.  Mean, 90th Percentile, and Median Curves from Set of 10 LHS CCDFs

selected example of the third alternative.  In Figure 3-2, all three reduced curves indicate
compliance with both 40 CFR sections 191.13(a)(l) and (2).  Note, however, that the mean
is below the median for small values of R, indicating an asymmetric (non-normal)
distribution. Also, it exceeds the 90th percentile at higher values of R.  At very high values
of R, the mean lies close to the maximum curve shown in Figure 3-1. Calculation of the
unconditional probability of compliance for all scenarios is based on the conditional
distribution of intersection point values for each scenario.  The range of the distribution of
these values reflects the range of uncertainty due to the model parameters for the scenario at
hand.  The mean, median, and percentiles of this distribution, and  the maximum, second
highest, etc., of the intersection point values, are all possible methods for reducing the  set of
N intersection points to a single point estimate.

Uncertainty in these point estimates should be considered in the assessment.  Hence,  the
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spread of the distribution of intersection points must also be quantified.  The combination of
the selected point estimate and an estimate of the spread of the distribution is required to
characterize the degree of confidence for the determination of compliance.

The following section addresses the derivation of the unconditional probability of compliance
from the collection of probabilities for all scenarios and subjective uncertainties  on input
parameter values.  The advantages and  disadvantages of the alternative criteria for
determining compliance are related to the advantages and  disadvantages of each  form of
curve reduction.  The advantages and disadvantages  of each form of curve reduction are
discussed in more detail  in Section 3.3.

3.2.7  Unconditional Probability of Compliance with the Containment Requirements

The probability of compliance may be estimated using one of the four curve reduction
methods noted in the preceding section.  The uncertainty reflected in  the multiple LHS
simulations performed for each  scenario and uncertain model parameter results in a
distribution of point estimates for each release magnitude.

Derivation of the -unconditional probability of compliance  requires use of the scenario
probabilities and simulation of the uncertainty in the scenario probabilities.  The use of
subjective methods to resolve scenario probabilities and their uncertainty has only just begun.
Recently, several expert  panels were  convened and assigned the task of estimating human
initiated process and event scenario probabilities.  The unconditional probability of
compliance cannot be estimated using the computational approach until uncertainty ranges
have been assigned to the scenario probabilities.

The uncertainty distribution for the scenario probabilities, when available, may be used to
simulate a set of N scenario-weighted estimates of the probability of exceeding the various
compliance release limits.  Again, this set of estimates will need to be reduced to a single
point estimate for the probability of compliance, and a measure of the uncertainty interval
will be needed for this estimate.  Formally, this would require a second application of the
four curve reduction methods discussed above.  However, it may be  sufficient simply to
display the resulting distribution of estimates of the probability of compliance graphically to
determine if the uncertainty interval is sufficiently high  (or low).
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3.3    Comparison of Alternative Criteria for Compliance

3.3.1  Advantages and Disadvantages of Alternative Compliance Criteria Using a Central
Point Measure

In section 3.2, a set of N point estimates for each scenario with parameter uncertainty was
developed for the probability or percentiles contained in the regulations by determining the
intersection of the N LHS CCDFs with the appropriate set of regulatory requirements.  This
set of N independent estimates for the percentiles RK and/or probabilities F( Lj) used in the
regulatory requirements determines the uncertainty distribution for each measure of
compliance.  These estimates must then be compared to the appropriate limiting value (L,
and/or Qj, respectively) stated in 40 CFR section 191J3(a).  Because a distribution of
estimates is produced by this procedure, it is desirabl? to reduce this set of estimates to a
single test statistic for determining compliance.

After observing N independent  samples from the LHS simulations, the probability of
compliance  may be determined  by a variety  of methods.  The simplest method is to estimate
a central point from the distribution of estimates. Alternative methods for determining a
central point are listed in Table 3-1, with a summary discussion of the merits and
disadvantages of each. The methods include the simple arithmetic mean (or "center of
gravity",) the weighted mean, and the median.

Alternative  1 in the list of curve reduction methods presented in the previous section suggests
taking the arithmetic average of the appropriate point estimates to use as the test statistic  for
comparing to the limit in requirement i. The use of a weighted mean is not necessary for
conditional analysis due to the equally likely nature of LHS samples.

Alternative 2 is a variation of alternative 1 to account for unequally weighted scenarios.

Alternative 3 uses the median f;j(.5) as the central point estimate for the test statistic. The
median is a  more robust point estimate, but  this point estimate will be smaller than the true
expected value (mean) if the distribution is skewed to the right (e.g., large values are
expected to  be more common than small values).

Regardless of the decision to use the mean or median as a central point individually, neither
test statistic for determining compliance would reflect the uncertainty indicated by the spread
of the distribution of estimates.  If the concept of reasonable expectation is interpreted to
indicate due consideration of uncertainty, then single point test statistics that are measures of

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                          Table 3-1.  Measures of the Central Point
             Measure
              Pros
              Cons
      Arithmetic Mean = M
•   The true expected value if
    probabilities are equal

•   Easy to calculate

•  Fair weight to low probability
   but catastrophic failures
•   Inappropriate for distributions
    highly skewed to right

•   Low robustness; one "outlier"
    can dramatically change result

•   If used as criterion, level of
    confidence is unknown
      Probability - Weighted
      Mean =
•   The true expected value if
    probabilities are not equal

•   Easy to calculate and explain

•   Fair weight to low probability
    but catastrophic failures
   Inappropriate for distributions
   highly skewed-to right

   Low robustness; one "outlier"
   can dramatically change result

   If used as criterion, level of
   confidence is unknown
      Median = MED =  f
                        .x
•   A true center:  there are 50%
    above and 50% below the
    median

•   Non-parametric:  no distribution
    shape is assumed

•   Known to be very robust; not
    affected by "outliers"

•   Easy to calculate for reasonably
    large sample sizes
•   Lower than expected value for
    distributions skewed to right

•   If used as criterion, level of
    confidence is unknown

•   Discounts low probability
    catastrophic failures,
    information is lost
the central point of the distribution of estimates are not adequate for determining compliance.
If the median is used as the central point, and the median is barely below the required limit,
then there is almost a 50%  chance that the regulatory limit would be exceeded. In this case,
evidence from the spread of the distribution dictates that the probability of compliance can be
no larger than 50%.  Furthermore, the level of assurance or confidence at which this rather
weak statement of compliance can be made is unknown because the uncertainty in  the
estimate of the median has not been considered.

To  reflect the uncertainty in the distribution of estimates, appropriate measures of  the spread
of the distribution are required.  Alternative estimators for the spread of the distribution of
estimates are listed in Table 3-2, with a summary of the advantages and disadvantages of
each estimator.  Estimates  of the spread of the distribution include the population standard
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                   Table 3-2.  Measures of Spread or Dispersion
        Measure
        Pros
    Cons
Population Standard
Deviation = Sigma
Maximum likelihood estimate
for variance of normal
distribution

Easy to calculate, even  for
weighted samples
Low robustness; one
"outlier" can
dramatically change
result

Inappropriate for
skew distributions
Mean Absolute Deviation
from Median = MAD
Non-parametric: no
distribution is assumed

Provides robust estimate of
population Sigma

Provides robust estimate of
Standard Error (SE) of
estimates of means and
percentiles obtained by
simulation method

Known to be very robust;
insensitive to "outliers"

Easy to calculate for
reasonably large sample sizes
Link to sample
variance depends on
distribution

Inappropriate for
skew distributions
Interquartile Range
IQR = f.75 - f^
Non-parametric:  no
distribution is assumed

Provides robust estimate of
population Sigma

Provides robust estimate of
Standard Error (SE) of
estimates of means and
percentiles obtained by
simulation method

Known to be very robust;
insensitive to "outliers"

Easy to calculate for
reasonably large  sample sizes
Link to sample
variance depends on
distribution
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deviation, the mean absolute deviation from the median (MAD), and the interquartile range
(IQR) which is the difference between the 75* and 25th percentiles.  The population standard
deviation, based on sums of squared deviations from the mean,  is less robust than the mean.
Small changes in values far from the median can have a large influence on this estimator.
The mean absolute deviation from the mean is more robust but is only appropriate for
symmetric distributions.  The interquartile range is more robust and appropriate for
asymmetric  distributions.

One test statistic for determining compliance is based on the mean and its standard error of
estimation.  The test statistic is defined as the upper end of the 95 % confidence interval for
the estimated mean.  Use of the upper confidence bound for the sample mean is one of the
statistical compliance criteria suggested by EPA for evaluating the attainment of soil clean-up
standards (EPA 89). The Nuclear Regulatory  Commission (NRC) has adopted the EPA
clean-up criterion in the guidance for determining compliance with the requirements for
license termination (NRC 92).  In these regulatory applications, actual measurements of
residual contamination after site clean-up are used for computing the sample mean and
standard error of the sample mean.

Note that the "confidence interval" found by this procedure provides an uncertainty range for
the estimate of the mean, not for the spread of the population values.  The mean plus a
multiple of the standard error of the mean can be used to form this uncertainty interval. The
advantages and disadvantages of this test statistic are shown in the first row of Table 3-3.
Determination of the appropriate value of the multiplier "k" to yield the desired confidence
level is based on the assumption of a Student-t distribution.  This assumption may be
inappropriate for asymmetric distributions.

A similar central point test statistic can be constructed for the median, i.e., the estimated
median plus a multiple of the standard error of the median.  Given that k is selected for 95 %
confidence,  if the upper bound  of the confidence interval  on the median is less than the limit
in the requirement,  there will be 95 % confidence that the conditional probability of
compliance is at least 50%. This is a weak statement concerning compliance, but the
probability of compliance can be improved by increasing  the percentile from the median at
0.50 to a higher level. Thus, the median is a  special case of the family of percentile
estimators and their associated test statistics, which are the subject of rows 2 through 6 of
Table 3-3. This family of test  statistics is discussed in the following section.
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                   Table 3-3.  Numerical Measures of Compliance
        Measure
        Pros
        Cons
Classical Confidence
Limit on Weighted Mean
UCL =
Classical upper bound for
the expected value

Standard Error (SE) reflects
uncertainty in estimate of
mean

k can be adjusted for desired
level of confidence

Easy to calculate, even for
weighted samples
May be inappropriate for
skewed distributions

Low robustness;  one
"outlier" can change result
dramatically

Uncertainty in the estimate of
SE is not addressed

Level of confidence is based
on the t-distribution
assumption
 * Percentile =  f
(Includes Median = f -J0)
Percentile p reflects
dispersion due to uncertainty
in parameters and
probabilities

Non-parametric: no
distribution is assumed

p can be adjusted to desired
probability point

Easy to calculate, even for
weighted samples
Extreme upper percentiles
require large sample sizes

Uncertainty in the estimate of
fp is not addressed
Classical Confidence
Limit on Upper Percentile

UCL, = f, +

kซSigma(fp)
Classical upper bound for an
upper percentile of the
population distribution

Percentile p reflects
dispersion due to uncertainty
in parameters and
probabilities

p can be adjusted to desired
probability point

Standard Error (SE) reflects
uncertainty in estimate of
percentile

k can be adjusted for desired
level of confidence
Extreme upper percentiles
require large sample sizes

Uncertainty in SE( fp )
estimate is not addressed

Level of confidence is based
on the t-distribution
assumption
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                                 Table 3-3 (Continued)
         Measure
                                           Pros
                                              Cons
Classical Tolerance Limit
on Upper Percentile
t =
         + k/Sigma
Tolerance limit addresses
uncertainty in estimation of
UCL

To account for uncertainty in
SE, k is adjusted higher

kj, can be found for desired
level of assurance for
percentile p

Relatively easy  to calculate,
even for weighted samples
Inappropriate for skewed
distributions

Low robustness;  one
"outlier" can dramatically
change result

Level of confidence is based
on the t-distribution
assumption
Non-parametric Tolerance
Limit on Upper Percentile
Maximum of N samples
                                    Non-parametric: no
                                    distribution is assumed

                                    Use of order statistics
                                    reflects uncertainty in
                                    parameters and probabilities

                                    Level of assurance requires
                                    no distribution assumption

                                    Maximum out of N provides
                                    a non-parametric upper
                                    tolerance limit for upper
                                    percentiles

                                    Easy to calculate
                                      Low robustness;  one
                                      "outlier" can dramatically
                                      change result

                                      Moderately large sample  size
                                      for acceptable tolerance
                                      levels

                                      Difficult to define tolerance
                                      limit if samples have unequal
                                      weights
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                                   Table 3-3  (Continued)
              Measure
       Pros
       Cons
       Non-parametric Tolerance
       Limit on Lpper Percent;

       f[j:N)=j'h highest
       of N samples
Non-parametric:  no
distribution is assumed

Use of order statistics
reflects uncertainty in
parameters and probabilities

Level of assurance requires
no distribution assumption

j* highest out of N provides
a robust non-parametric
upper tolerance limit for
upper percentiles

Higher robustness against
"outliers" as j increases to
median

Easy to calculate
Larger sample size for
acceptable tolerance values as
j increases

Difficult to define tolerance
limit if samples have unequal
weights
 3.3.2  Advantages and Disadvantages of Alternative Compliance Criteria using Percentiles

 A simple way to determine if the higher values of the distribution of intersection point values
 exceeds the regulatory requirements is to count the  number of conditional LHS values  which
 are higher than the limiting value.  The ratio of this number to N is an estimate of the
 proportion of LHS runs that are not in compliance.  Hence, the probability of compliance is
 1 minus this ratio. For example, if there are 100 LHS samples and 10 values exceed the
 limit, then an approximate estimate of the proportion of samples exceeding the limit is 10
 percent.  This indicates that the probability  of compliance is near 90 percent (if 100 points
 are adequate to describe the uncertainty distribution in the mean CCDFs.)

 A more formal  way to do this comparison is to specify that the p* percentile of the
 distribution of intersection point values is below the regulatory limit. This value, denoted by
 fp in row 2 of Table 3-3 was discussed under alternative 3 of Section 3.2.  The following
 statement may be made concerning this percentile:  If fp is less than the limit in the
requirement, then the probability of compliance will be at least as large as  p.  The level of
confidence for making this statement is unknown, since the sampling error  for the estimated
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percentile has not been addressed.  Additional advantages and disadvantages of the percentile
estimator are presented in row 2 of Table 3-3.

The test statistics in rows 3 through 6 of Table 3-3 are designed to provide a known level of
confidence that the estimated percentile is less than the limit in the requirement.  In row 3 of
Table 3-3, the classic 95% confidence interval for the p* percentile is formed by adding a
multiple of the standard error to the percentile estimate.  As for the confidence interval on
the mean in row  1, the multiplier k can be adjusted to provide a 95 % confidence interval.
The level of confidence thus obtained is based on the assumption of a t-distribution.

The classic tolerance interval test statistic shown in row 4 of Table 3-3 is related
conceptually to the confidence interval on the upper percentile discussed  in row  3.  Although
this test statistic utilizes the estimated mean and standard deviation of the population of
intersection points, it is applied as an upper tolerance limit for percentiles of the distribution.
Due to  the asymmetry of the distributions .encountered  here, the tabulated values for k,,
provide only a rough approximation of the true level of tolerance for the test.
The order  statistics of the sample of intersection points may be used to provide non-
parametric upper tolerance bounds for the percentiles of a distribution (GLI 78).  The use of
the maximum as  a test statistic is discussed in row 5 of Table  3-3.  For example, it may be
demonstrated  that the maximum value in a sample of 90 independent values from the same
distribution has at least a 99 % chance of being larger than the 95th percentile of the
distribution.  Thus, the maximum in a random sample of at least 90 observations is said to
provide a 99 % upper tolerance limit for the 95th percentile.  A simple proof proceeds as
follows.

By definition, the probability of exceeding the 95th percentile is 5%. If observations are
made independently, each has a 5%  chance of exceeding the 95th percentile.  As more and
more observations are collected, the chance that at least one of them will exceed the 95th
percentile increases with the number of observations. For a sufficiently  large sample, there
will be  a high probability that the maximum in the sample exceeds the 95th percentile.  For
example, this probability is calculated for N=90 observations by the formula

                              1 . .95* = i . .9590 =  0.9901.

Thus  there is  over a 99 % chance that the maximum of 90 independent observations will
exceed  the 95th percentile,  regardless of the distribution. If the maximum of the sample is
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lower than the requirement of 40 CFR section 191.13(a), then there is at least a 99% chance
that the 95th percentile of the distribution lies below the regulatory requirement. In statistical
terms, the maximum value in a random sample of size 90 provides a robust 99 % upper
tolerance bound for the 95* percentile of the distribution.

By a similar argument, the second  highest value in a random sample of at least 76
observations has at least a 90% chance of exceeding the 95th percentile.  And, the third
highest in a sample of at least 75 has a 75% probability of exceeding the 95th percentile of
the distribution. These test statistics based on the higher order statistics are discussed in row
6 of Table 3-3.

The advantage of using the order statistics of the estimates obtained from the intersection
points of the LHS CCDFs with the regulatory requirements is that no assumptions are
required concerning the specific form  for the distribution. The distribution need not be
symmetric.  Appropriate tolerance  bounds for any percentile may be found using the  order
statistics of the intersection points.   Non-parametric tolerance  limits for the upper percentiles
of the distribution do not require specification of the adjustable multiplier k;  hence, no
reliance on  tables based on the  t-distribution assumption are necessary.  For this test, the
sample size itself is the adjustable parameter.

The current LHS sample sizes used in the WIPP compliance assessment analyses are
sufficient to provide reasonable levels of assurance that the 95th percentile of the distribution
of estimates has been included in the analysis of compliance with each requirement of 40
CFR  section 191.13(a).  If a decision  is made to require that the 99th percentile of the
distribution of estimates is included in the analysis,  sample sizes much larger than those
currently used will be necessary to reach a reasonable level of assurance that the regulatory
requirements are satisfied.  For example, with the number of  variables  in the 1992
compliance  assessment at 50, an LHS  sample size of at least 298 for each scenario is
necessary  for a 95 % confidence that the 99th percentile of the  distribution is calculated.
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3.4    Other Regulatory Considerations


3.4.1  Environmental Protection Agency


3.4.1.1 40 CFR Part 268, Land Disposal Restrictions.  The Land Disposal Restrictions
identify hazardous waste that is restricted from land disposal and define those limited
circumstances under which an otherwise prohibited waste may continue to be land disposed.
Section 268.6 sets out requirements for exemption petitions which if granted allow land
disposal of a prohibited waste.  These petitions are generally referred to as "no migration
petitions."


The regulations require that the demonstration include the following components:


(1)    An identification of the specific waste and the specific unit for which the
       demonstration will be made;

(2)    A  waste analysis to describe chemical and physical characteristics  of the subject
       waste;

(3)    A  comprehensive characterization of the disposal unit site including an analysis of
       background air, soil, and  water quality;

(4)    A  monitoring plan to detect migration at the earliest practicable  time; and

(5)    Sufficient information to assure the (EPA) Administrator that the owner or operator of
       a land disposal unit receiving restricted waste(s) will comply with other applicable
       Federal, State,  and local laws.

Treatment of uncertainty is addressed  in Section  268.6(b)(5), which states:

       "An analysis must be performed to identify  and quantify any aspects of the
       demonstration that contribute significantly to uncertainty.  This analysis  must include
       an evaluation of the consequences of predictable future events, including, but not
       limited to, earthquakes, floods, severe storm events, droughts, or  other natural
       phenomena."

The EPA guidance manual offers further instruction on dealing with uncertainty (EPA92).
The manual states that a petitioner  must identify  and evaluate the impacts of predictable
future events that could contribute to or result in inadequate waste isolation, such as
earthquakes and resulting ground motion, floods  and droughts, severe storm events, climatic

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fluctuations, geologic activity, and likely human-induced processes and events which may
affect the isolation capability of the unit, such as disturbance of the hydrologic regime and
future land uses.

The manual notes that the level  of detail required in individual petitions will depend on site-
specific factors.  Neither the manual nor the regulations provide limits or assumed values for
any specific parameters such as  future populations, land use, or climatic changes.

3.4.1.2  40 CFR Part  148, Hazardous Waste Injection Restrictions (Underground Injection
Control). 40  CFR Part 148 codifies EPA's regulatory framework for implementing the 40
CFR Part 268 land disposal restrictions for hazardous waste that is disposed in Class I
injection wells.  Subpart C, Petition Standards and Procedures, sets out the requirements  for
seeking a "no migration" petition under these regulations.  Section 148.20 requires that the
petitioner demonstrate, with a reasonable degree  of certainty, that hazardous constituents  will
not migrate as long as the waste remains hazardous, by demonstrating either (1)  that the
injected fluids will not migrate within 10,000 years, or (2) that before the  injected fluids
migrate, they  will no longer be  hazardous because of attenuation, transformation, or
immobilization within  the injection zone.

Section 148.21 lists the information that must be submitted in support of a "no migration"
petition. It states:

       An analysis shall be performed to identify and assess aspects of the demonstration that
       contribute significantly to uncertainty. The petitioner shall conduct a sensitivity
       analysis to determine the effect that significant uncertainty may contribute to the
       demonstration.  The demonstration shall then be based on conservative assumptions
       identified in the analysis.


This section examines  both national and international regulatory requirements for parallels to.
the concept of "reasonable expectation."

3.4.2 Nuclear Regulatory Commission

U.S. Nuclear  Regulatory  Commission regulations for the disposal of high-level waste in
geologic repositories (10 CFR Part 60) also address long-term uncertainty  issues.  These
regulations require a finding that issuance of a license for such a geologic  disposal system

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will not constitute an unreasonable risk to the health and safety of the public.  Subpart E of
the regulation provides performance objectives, site criteria, and design criteria.


The general standard in 10 CFR Part  60 for judging whether the performance objectives and
criteria are met is "reasonable assurance."  10 CFR Section 60.101  (a)(2) of Subpart E
characterizes this general standard as  follows:


       While these performance objectives and criteria are  generally stated in unqualified
       terms, it is not expected that complete assurance that they will be met can be
       presented.  A reasonable assurance, on the basis of the record before the
       Commission, that the objectives and criteria will be  met is the general standard that is
       required.  For 60.112, and other portions of this subpart that impose objectives and
       criteria for disposal system performance over long times into the future, there will
       inevitably be greater uncertainties.   Proof of the future performance  of engineered
       barrier systems and the geologic setting over time periods of many hundreds or many
       thousands of years is not to be had in the ordinary sense of the word.  For such long-
       term objectives and criteria, what is required  is reasonable assurance, making
       allowance for the time period,  hazards, and uncertainties involved, that the outcome
       will be in conformance with those objectives and criteria.  Demonstration of
       compliance with such objectives and criteria will involve the use of data from
       accelerated tests and predictive models that are supported by such  measures as field
       and laboratory tests, monitoring data, and  natural analog studies.

10 CFR Section 60.112 requires that the disposal  system be designed to assure that releases
of radioactivity to the accessible environment conform to generally applicable EPA standards.
EPA has yet to define these standards for the proposed high-level waste repository at Yucca
Mountain.  Under Section  801 of the  Nuclear Waste Policy Act (enacted by the Congress in
late 1992), EPA is required to promulgate  standards  for Yucca Mountain taking into account
recommendations to be prepared by the National Academy  of Sciences (NAS).  NAS is
charged with completing studies on the following  topics by the end  of 1993:

       •     Whether a health-based standard based upon  doses to individual members of
             the public from releases to the accessible environment will provide a
             reasonable standard for protection of the health  and safety of the general
             public.

       •     Whether it is reasonable to assume that a system for post-closure oversight of
             the disposal  system can be developed, based  upon active institutional controls,
             that will prevent an unreasonable risk  of breaching the disposal system's
             engineered or geologic  barriers or increasing the exposure  of individual
              members of the public  to radiation  beyond allowable  limits.
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       •     Whether it is possible to make scientifically supportable predictions of the
             probability that the disposal system's engineered barriers will be breached as a
             result of human initiated processes and events over a period of 10,000 years.

Compliance assessment work on Yucca Mountain (SNL 93b) has not yet addressed the issue
of "reasonable assurance."  Consequently, there is little analogous work that could be applied
to defining what constitutes "reasonable expectation" at the WIPP nor is it likely that any
useful parallels can be drawn in the next several years.

In 10 CFR Part 60, the general standard for judging whether the performance objectives and
criteria  are met is  "reasonable  assurance," while 40 CFR part 191  uses the term "reasonable
expectation." L, its comments to EPA on the Advance Notice of Proposed Rulemaking
(ANPR) on compliance criteria for 40 CFR part 191, NRC urged the Agency to reexamine a
position taken in 1985 in 50 FR 38071 that "reasonable expectation" was different from
"reasonable assurance" (NRC 93a).7  It was NRC's view  that the terms were similar, and
the Commission suggested that EPA explain any differences in the rulemaking process.

In its comments on the ANPR, the NRC also noted the difficulty in attempting to apply
numerical standards (such as a specified confidence level) where data are insufficient to draw
rigorous statistical  conclusions. The NRC went on to say, "Because a specific  statistical test
cannot be applied,  a more general qualitative 'level of confidence'  should be the required
measure of compliance.  DOE should  be required to demonstrate (by a preponderance of the
evidence)  the required level of level of confidence ~ e.g., 'reasonable assurance' — in future
performance of the disposal facility."

In the development of a manual for determining compliance with license termination
requirements, NRC has suggested methods for comparing soil and surface measurements of
residual contamination to mandated clean-up standards (NRC 92).  One suggested method is
a comparison of the upper bound on the 95 % confidence  interval to the regulatory standard.
NRC notes that the comparison may have three possible outcomes:

       •     (1) If the sample mean exceeds the standard for clean-up, then the site is not in
             compliance and  further  cleaning is required.
   7 A similar standard - "reasonable degree of certainty" - exists in the RCRA regulations.  DOE recently
requested that EPA consider documenting in the 40 CFR 194 rulemaking that the terms were  equivalent for
demonstrating regulatory compliance for geologic repositories.  This standard requires the Agency to consider only
future events that could reasonably be predicted; proof beyond a reasonable doubt is not required.

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       •      (2) If the sample mean is lower than the clean-up standard, but the upper limit
              of the 95 % confidence interval for the mean is not below the standard, NRC
              offers two choices:  the site operator may make more measurements to reduce
              the width of the confidence interval; or the operator may decide to re-clean the
              site.

       •      (3) If the upper limit of the 95 % confidence interval for the mean is below the
              standard, then the site is considered to be in compliance at the 95 % confidence
              level.

3.4.3 Department of Energy

DOE also commented on the 40 CFR part 191 Compliance Criteria ANPR (DOE 93).  While
the Department advocated retaining the concept of "reasonable expectation," it took the
position "that additional attempts to specify a numerical or statistical test of compliance
would not be productive."  Rather, DOE argued that the degree of confidence should not be
predetermined; instead, it should be based on all considerations reflected in the record.  The
DOE position  was similar to that taken by the NRC.  Because there  are no statistical tests
appropriate to the kinds of information contained in the compliance assessment, EPA should
choose a "more general level of confidence" based on a  substantial understanding of the
disposal system and the surrounding environment and on peer review of the WIPP
compliance assessments.

3.4.4 Non-U.S. Disposal Systems

Substantial work on compliance assessment and treatment of uncertainty has been performed
in several countries.  These are primarily "total systems" studies, addressing more than just
numerical techniques.  For example, site selection issues are considered; i.e., one way of
reducing uncertainty is to consider sites that are easy to characterize as opposed to sites that
look good but are difficult to characterize.

However, finding useful parallels addressing the issue of "reasonable expectation" in
programs involving non-U.S. geologic repositories has not been possible because these
programs are not nearly as close to actual disposal as those in this country.  In 1990,.Pacific
Northwest Laboratory (PNL) investigators compared programs  on repositories for high-level
waste8 and spent fuel in eight countries including Belgium, Canada,  France, Germany,
   8 It should be emphasized that this report focused on high-level wastes, not TRU wastes.

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Japan, Sweden, Switzerland, and the United Kingdom (PNL 90).  Conclusions reached by
the PNL team include:

      •     The United States has one of the most developed disposal system concepts and
             one of the earliest scheduled disposal system startup dates.

      •     The United States has the most prescriptive regulations and performance
             requirements for the disposal system and its components.

      •     Most countries have established only general performance requirements  for
             repositories.

      •     Some countries do not believe that detailed performance requirements and
             regulations are required and do not plan to develop them.

      •     No disposal system  is scheduled for operation for at least 20 years.

      •     Only three countries have  selected the host rock for their disposal system.

Regulatory status and approach to safety  in each country surveyed by PNL are summarized
in Table 3-4.
             Table 3-4.  Regulatory Status and Approach to Safety in Foreign
                         Geologic Repositories
Country
Belgium
Canada
France
Germany
Japan
Sweden
Switzerland
United Kingdom
Disposal System
Performance Requirements
General only
General only
General only
General for total system
Not yet established
General for total system
Total system objectives
General only
Status of Regulations
Details to be developed
Under development
Under development
Regulations complete
Not yet established
Regulations complete
Regulations complete
Deferred for disposal
system
Approach to Proving Safety
Deterministic & stochastic
Deterministic & stochastic
Deterministic
Deterministic, conservative
Stochastic
Conservative, deterministic,
some stochastic
Conservative, deterministic
Conservative, deterministic
& stochastic, time-
dependent simulation
modeling
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3.4.4.1  Organization for Economic Co-operation and Development COECD) Nuclear Energy
Agency.  Several studies have been conducted in the last few years at the international level
on assessing the performance of high-level radioactive waste repositories and treating
uncertainty in compliance assessment.  For example, the status of compliance assessment
methodology development was reviewed at a Symposium on Safety Assessment of
Radioactive Waste Repositories, convened by the OECD Nuclear Energy Agency (NEA)
inParis in October 1989. NEA also held a 1987 symposium on "Uncertainty Analysis for
Performance Assessment of Radioactive Waste Disposal Systems" (Seattle, February 1987),
and published a methodology for scenario development ("Systematic Approaches to Scenario
Development") in 1992.  The various NEA working groups continue to focus much attention
on uncertainty of long-term modeling of disposal system behavior.

3.4.4.2 Canada.  The Atomic Energy  Control Board issued a regulatory policy statement
concerning long-term aspects of radioactive waste disposal in 1987, which provides, inter
alia, that individual risk from a waste disposal facility must not exceed 10"6 fatal cancers and
serious genetic  effects per year (AECB87). The policy statement includes guidance on how
to account  for the probabilities of various exposure scenarios when applying the basic
regulatory  requirements, stating that  such probabilities "should be assigned numerical values
either on the basis of relative frequency of occurrence or through best  estimates and
engineering judgements."  Specifically, it indicates that low-probability exposure scenarios
should be assigned values through best estimates and engineering judgments,  and that:

       the  assignment should be made using quantitative analytical techniques to assess as
       broad a base of expert opinion as reasonably possible.  The use of subjective
       probability is appropriate as long as the quantitative values assigned through best
       estimates and engineering judgements are consistent with the quantitative values of the
       actual relative frequencies in situations where more information is available.  The
       uncertainty of the probability  assigned should also be estimated.

Furthermore, the AECB policy statement indicates that calculations of individual risks should
be made by either of the following methods:

       •     using deterministic pathway analysis to calculate annual  individual dose, and
             applying a risk conversion factor of 2 x 10"2 per sievert; or

       •     using probabilistic analysis to determine a distribution of annual individual
             doses, calculating the arithmetic mean value of these doses, and applying a
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              risk conversion factor of 2 x 10"2 per sievert.

In the case of deterministic analysis, the AECB urges that analysts not be excessively
conservative, but instead make a balanced choice of assumptions to ensure that the
assessment describes reasonable situations covering the spectrum of exposure pathways and
assesses their impacts rationally.  In either the deterministic or probabilistic approach,  the
AECB indicates that sensitivity analyses should be conducted to investigate the effect of
changes in input assumptions and model parameters on the magnitude of the single dose
estimate (deterministic) or mean value of dose (probabilistic).

Since the  arithmetic mean of a dose distribution could potentially hide the significance of
values at the high end of the distribution, the AECB states that "it is judged acceptable to
allow 5%  of the estimated doses to exceed a dose of 1 mSv (100 mrem) per year to take
account of normal statistical variations which are inherent in the probabilistic assessment
process,"  and  that the general risk requirement of 10"* fatal cancers per year (which
corresponds to a dose of 0.05 mSv/year (5 mrem/year)) takes account of this since a 5%
chance of a dose of 1 mSv (100 mrem) corresponds to an average dose of 0.05 mSv (5
mrem).

3.4.4.3 France.  In June 1991, France's Directorate for the Safety of Nuclear Installations
(DSIN) issued Fundamental Safety Rule No. m.2.f on high-level and alpha waste  disposal
(FR91).  According to a  summary presented by Raimbault et al. (RA92), the rule  provides
that demonstration of safety be based on "deterministic evaluations of the radiological impact
for two types of envisaged situations:

       •      a reference situation which corresponds to the occurrence of very probable or
              certain events.

       •      hypothetical situations corresponding to occurrence of low probability events
             that may lead to preferential transfers."

Under the reference situation, individual doses should be _<. 0.25 mSv/year (25 mrem/year)
for long exposures associated with very probable or certain events.

The DSIN rule details procedures for conducting compliance assessment.  The rule requires
validation of numerical models; sensitivity analysis with respect to scenarios, models,
phenomena, and parameters;  and results expressed in terms of radiation exposures, with

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associated uncertainty bounds.

Based on the DSIN guidance, the Agence National pour la Gestion des Dechets Radioatifs
(ANDRA) has developed an iterative procedure consisting of the following principal steps in
the safety evaluation:

       •      identify all applicable radiological criteria

       •      select scenarios to be considered, with detailed radiological impact analysis.
              and associated sensitivity and uncertainty analysis

       •      develop a first generation of global safety models corresponding to the selected
              scenarios

       •      develop specific detailed models to consider, e.g., glass corrosion

       •      test and utilize sensitivity and uncertainty analysis techniques

       •      develop information on consequence uncertainties and identify the most
              important scenarios, phenomena, geosphere data, or concept parameters

       •      draw conclusions  on  concept constraints, and define the most important site
              data acquisition work.

Input from architectural  engineers and site investigators will be provided to the safety
assessment team, and vice  versa. According to Raimbault et al.,  at the  end of ANDRA's
planned underground laboratory  phase, this procedure should facilitate "a complete and
validated compliance assessment of the disposal system with maximum confidence"  and  "an
optimized and justified design and program of operation for the underground facility"
(RA92).

3.4.4.4 Sweden.  The Swedish  Nuclear Power Inspectorate (SKI) has indicated that it has
not established a specific policy  on  how uncertainty should be treated and has analyzed the
question on a case-by-case basis (AN93).  However, SKI indicated that  it will need to reach
more definite conclusions about  how to treat uncertainty at the time of licensing. SKI
considers over-reliance on  probabilistic assessments to be  inappropriate.  The Swedish
agency wants all countries  to agree on compliance assessment and uncertainty analysis
methodologies.  SKJ's principal  focus in reducing uncertainty is to gain as great an
understanding as possible of the physics and chemistry involved in the disposal system and to

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conduct research in key areas of remaining uncertainty.

The Swedish Nuclear Fuel and Waste Management Co. (8KB) addressed some of these
issues, including ambitious probabilistic assessments of ground-water flow in a 1991 report.
The report (SKB91) used stochastic modeling for hydrology, bringing in uncertainties in
conductivities and other parameters and treating them statistically.  However,  other types of
uncertainties are not treated  statistically, but rather by variation analysis and special runs of
the statistical model, e.g. with respect to fracture zones.  8KB does not want to choose a
compliance assessment method now but recognizes that when the time comes for evaluating
an actual site, the  company will have to choose an approach and defend its selection (PA93).

3.4.4.5 Switzerland. The Swiss, along with the Swedes and Finns, are skeptical of fully
probabilistic treatment of uncertainty. Although they do use probabilistic codes,  which
accept distributions of values for various parameters, they do not assign probabilities to
different values  and instead randomly select numbers assuming a flat distribution. They
emphasize  that they do not necessarily try  to predict disposal system performance as close to
the truth as possible, but rather to predict  that repositories are safe; tools that 'are known to
be wrong but that  are known to over-predict risks are considered acceptable (McC93).

A paper presented by Zuidema of Switzerland's National Cooperative for the Storage of
Radioactive Waste (NAGRA) at a 1991 NEA workshop on  criteria for HLW disposal
identified four sources of uncertainty in disposal system safety analysis:

       •      uncertainty in scenarios;

       •      uncertainty in conceptual models;

       •     parameter uncertainty; and

       •     parameter variability.

Zuidema indicated that compliance assessment tools can be  used to quantify different types of
uncertainty: for  scenario uncertainty, several alternative future evolutions must be analyzed;
for conceptual uncertainties,  several alternative conceptualizations must be considered; and
for parameter uncertainty, both probabilistic and deterministic models can  be used.

Zuidema also identifies disposal system siting and design considerations that are important in

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reducing uncertainty.  Factors to consider are the ease of exploring the geological
environment and predicting the evolution of the geological environment over time; and the
robustness of the disposal system, including simplicity of physical and chemical properties,
availability of large safety margins, and maximum redundancy of barriers.

Outside the United States, Germany has the most advanced program.  A candidate site for a
high-level waste disposal system has been chosen at Gorleben in Lower Saxony.  The
disposal system will be situated in a salt dome at a depth  of about 800 m.  Safety must be
demonstrated for 10,000  years, and the maximum allowable dose to the most exposed
member of the general public is limited to 30 mrem/y for unavoidable occurrences before
and after closure.  The assessments to demonstrate compliance are deterministic and are
characterized by PNL as  conservative and bounding. Conservative is taken to mean that
errors would be on the side of protectiveness of people and the environment.

Since the PNL survey, France has published Fundamental Safety Rule RFS-DI.2.f, which
defines safety objectives for compliance assessment of disposal system sites (HLW 92).  This
rule affirms the use of deterministic analyses for safety demonstration and offers no useful
parallels in addressing the "reasonable expectation" issue.

Canada has proposed that individual dose from a disposal system can be  calculated either
deterministically or probabilistically (CAN 90) and should be  limited to 0.05 mSv (5 mrem)
annually.  With probabilistic analysis, a frequency distribution is expected displaying both the
most probable dose and the maximum dose at the high-tail extremity of the curve. Use of
the arithmetic mean value of the distribution has been recommended as the predictor of the
consequences of a  scenario.  In dealing with high-consequence, low-probability events,
Canada has stated that "it is judged acceptable to allow 5 % of the estimated doses to exceed
a dose of 1 mSv (100 mrem) per year to take account of normal statistical  variations which
are inherent in the probabilistic assessment process."

3.5    Conclusions

There are several generic approaches which can be taken  simultaneously to minimize
uncertainty and achieve a "reasonable expectation"  of compliance with the  requirements of 40
CFR part 191.  Probably the most  important approach is to be sure that  maximum use is
made of experimental programs that can produce valuable data in time for  incorporation into
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the application for certification of compliance as required by the WIPP Land Withdrawal Act
(LWA).  Experimental programs should be constantly reviewed to see if modifications to the
existing experiments or new experiments will yield useful and timely data.  A second
approach is to evaluate thoroughly (with experiments if necessary) the benefits of using waste
form modifications and/or engineered barriers to reduce uncertainty in some parameters.
This evaluation should also consider the long-term degradation of the engineered alternatives
in the disposal system environment.  The third approach is the extensive use of peer review
panels of impartial scientists to evaluate data and conclusions on the distribution of values for
key individual parameters.  These key individual parameters may have been developed on the
basis of formal elicitations from expert panels or from exercise of investigator judgment.
Investigator judgement may involve either  interpretation of experimental  data or qualitative
selection of a value.  It is important that these peer review panels be selected to ensure true
independence and that they be conducted in an open and fully documented process.

3.5.1  Essential Role of Expert/Peer  Review

The criteria for evaluating compliance of the WIPP disposal site with the requirements of 40
CFR part 191  include both a qualitative evaluation of the compliance assessment and a
statistical approach based on evaluation of the multiple CCDFs generated by the compliance
assessment model using the LHS-Monte Carlo procedure.  Each portion of the determination
of compliance must evaluate the degree of uncertainty in the results of the compliance
assessment process.  Uncertainties that must be addressed include the selection of a
conceptual model for evaluating the likelihood of releases to the accessible  environment over
10,000 years, the selection of specific scenarios for evaluation, and uncertainties in the
assignment of numerical values for the probabilities of each scenario considered and the
physical parameters required by the model.

Although the uncertainty  surrounding the selection of values for the physical parameters in
the model is significant, it is likely that the subjective uncertainties surrounding the selection
of conceptual models and scenarios and their probabilities are an even greater source of
uncertainty in the final estimates of cumulative releases generated by the compliance
assessment model. These subjective  sources of uncertainty are not addressed as completely
in the LHS-Monte Carlo procedures as  are the physical parameters of the model.  Hence, a
determination based solely on statistical analysis of the compliance assessment model  LHS
results would not address all uncertainties.  Peer review of the conceptual models,
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approximations made in the computer implementation of the model, and the scenarios
selected for evaluation and their probabilities is thus an essential component in determining
compliance.  However, statistical methods also may be required to evaluate the uncertainties
addressed by the LHS procedures.

3.5.2 Selection of a Statistical Criterion for Compliance

Statistical procedures for evaluating compliance with 40 CFR part 191 are expected to add
few costs to the WIPP compliance assessment program.  Compared to the existing software,
the additional resources to develop software to perform the calculations required for
evaluating compliance using any of the alternative statistical compliance criteria will be
minor.

One  selection of a  statistical criterion for determining compliance may be based on a literal
interpretation of "reasonable expectation" to mean that the expected value  (the mean) should
form the basis of the criterion.  This interpretation would suggest that the  mean of the set of
N LHS  CCDFs generated by the compliance assessment model should be considered. The
CCDF obtained by taking the mean of the individual LHS CCDFs provides only a point
estimate for the mean.  If small LHS  sample sizes are used, the standard error of the
estimated mean CCDF curve would be relatively large.  The sampling error of the estimated
mean should be considered in making a comparison with the requirements of 40 CFR section
The use of the upper 90 % or 95 % confidence limit for the sample mean as a test criterion
was introduced in Section 3.3.2.  Use of the upper bound of the 95% confidence interval for
the sample mean has been suggested (EPA 89, NRC 92) as an appropriate method for
determining compliance with soil clean-up standards at decommissioned sites.  The
hypothesis test for this alternative is defined by the inequality

                              UCL = M + k SE(M)  < L

where the symbol UCL denotes the upper limit for the confidence interval for the sample
mean (M), and the symbol SE(M) denotes the  standard error of the sample mean, and L is
the appropriate regulatory limit specified in 40 CFR section 191.13(a).  The multiplier k may
be selected appropriately  to provide a 90 % or 95 % confidence level by reference to standard
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statistical tables on the t-distribution.  If the upper confidence limit for the mean is less than
the value required limit, a determination of compliance would be made.

The advantages and disadx. itages of the upper confidence limit for the sample mean were
summarized in row  1  of Table 3-3.  The advantages of this criterion are repeated here:

       •     The mean CCDF yields the true expected value.
       •     Use of  the upper bound for the confidence interval is a  standard statistical
             method.
       •     Use of  the standard error of the mean reflects uncertainty in the estimate of the
             mean.
       •     The multiplier k can be adjusted to obtain the desired level of confidence.
       •     The mean is easy to calculate, even for large samples.

The disadvantages of  using the upper confidence limit on the sample mean, also summarized
in Table 3-3, must be considered before selecting this criterion.

       •     This test may be inappropriate for skewed distributions.
       •     The test has low robustness; one "outlier" can change results dramatically.
       •     Uncertainty involved in estimating the standard error of the mean is  not
             addressed.
       •     The level of confidence for the test is based on the t-distribution assumption.

For distributions on positive variables which are skewed toward higher values, the mean will
often lie above the median of the distribution.  Use of the  mean in this case is comparable to
using a higher percentile than the median for determining compliance.  For highly  skewed
distributions, the mean may exceed the 90th percentile of the distribution. This results in a
test which is protective of the environment by increasing the likelihood of a non-compliance
test result.   Furthermore, the upper confidence limit for the mean will exceed the mean
itself, thus adding to the conservativeness  of the test procedure.  For small sample sizes, the
standard error of the mean will be larger, thus making the test even more protective.

The low robustness of the test also results in a more protective test for compliance.  If very
high "outliers" occur  in the sample values, the estimated value for the mean will be very
sensitive to these high sample values. The estimated value for the standard error of the mean
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may also be inflated by outliers.  The increases in the estimate.of the mean and its standard
error due to outliers tend to make the test more protective.  Larger sample sizes would
reduce the  impact of uncertainty due to the t-distribution assumption for selecting the
multiplier k.  For smaller sample sizes, the value of k indicated by the t-distribution may
provide only an approximation for the proper value of the multiplier to  obtain a true 90% or
95 % confidence interval for the mean.

It appears that the relatively lower robustness of the probability-weighted mean relative to the
median is a fundamental characteristic of the uncertainties of compliance assessment rather
than a flaw of that statistical method.  Outliers which lower the robustness of the statistical
test represent valid possibilities for large releases from the disposal system. These outliers
are the mathematical representation of the recurring  theme that "Proof of the future
performance of a disposal system is not to be had in the ordinary sense of the word..."

The statistical portion of the determination of compliance with 40 CFR part 191 could be
based on the sample mean.  The LHS sample sizes should be demonstrated operationally
(approximately 300 when 50 variables are considered) to improve (reduce the size of) the
confidence interval for the estimated mean.  The underlying principle would be to show
convergence of the mean.
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                                        3.6  References


AECB87     Atomic Energy Control Board, Regulatory Policy Statement,  "Regulatory
             Objectives, Requirements and Guidelines for the Disposal of Radioactive
             Wastes  Long-Term Aspects," Regulatory Document R-104,  June 5, 1987.

AN93        Andersson, J.,  Swedish Nuclear Power Inspectorate, personal correspondence,
             August 12, 1993.

CAN 90     "Regulatory Policy Statement," presented by K. Bragg, AECB, at NBA
             Workshop on Disposal of High-Level Radioactive Wastes:  Radiation
             Protection and  Safety Criteria, Paris, France, November 5-7,  1990.

DOE 93     DOE Comments on Advance Notice of Proposed Rulemaking for the
             Certification  of Compliance with 40 CFR Part 191 Disposal Regulations, in
             Letter to Michael H. Shapiro  (EPA) from Paul D. Grimm (DOE), ATTN:
             Docket A-92-56, March 31, 1993.

EPA 89      Methods for  Evaluating the Attainment of Clean-up Standards, Vol.  1, Soils
             and Soil Media, EPA 230/02-89-042, February 1989.

EPA92       "No Migration" Variances to the Hazardous Waste Land Disposal
             Prohibitions: A Guidance Manual for Petitioners. EPA530-R-92-023, US
             Environmental  Protection Agency, Office of Solid Waste, Washington, DC,
             July 1992.

ESL 92       Letter to John Davidson (EPA) from P.W. Eslinger (Battelle-PNL),
             February 11, 1992.

FR91        Direction de  la Surete des  Installations Nucleaires, Ministere  de 1'Industrie et
             du Commerce Exterieur, Fundamental Safety Rule No. JH.2.f,  "Definition of
             objectives to  be met during the study phase, and of the work  for final storage
             of radioactive waste in deep geologic  formations, in order to  assure safety
             after the period of using the facility," June  10, 1991.

GLI 78       "Breaking records and breaking boards," N. Glick, American Mathematical
             Monthly, Vol. 85, 1978, pp. 2-26.

HEL 93a     "Calculation  of reactor accident safety goals," J.C. Helton, and R.J. Breeding,
             Reliability Engineering and System Safety, Vol. 39, 1993, pp. 129-158.
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HEL 93b     "Drilling intrusion probabilities for use in performance assessment for
             radioactive waste disposal," J.C. Helton, Reliability Engineering and System
             Safety, Vol. 40,  1993, pp.  259-275.

HLW 92     "Methodology Developed by the French National Nuclear Waste Management
             Agency (ANDRA) for the Performance Assessment of a Deep Geological
             Repository," P. Raimbault, et al., in Proceedings of the Third International
             Conference on High-Level  Radioactive Waste Management, Las Vegas,
             Nevada, April 12-16, 1993.

McC93       McCombie, C., National Cooperative for the Storage of Radioactive Waste
             (NAGRA), personal correspondence, August 13, 1993.

NRC 92      Manual for Conducting Radiological Surveys in Support of License
             Termination, NUREG/CR-5849, draft  report for comment, June 1992.

NRC 93a     Letter to J.  William Gunter (EPA) from B.J. Youngblood (NRC),  March 22,
             1993.

PA93        Papp, T., Swedish Nuclear Fuel and Waste Management Co.  (SKB),  personal
             correspondence,  August 16, 1993.

PNL 90      "Comparison of Selected Foreign Plans and  Practices for Spent  Fuel and High-
             Level Waste Management," PNL-7293, Pacific Northwest Laboratory, April
             1990.

RA92        Raimbault, P. et al., Agence Nationale pour la Gestion des Dechets
             Radioactifs  (ANDRA),  "Methodology  Developed by the French National
             Nuclear Waste Management Agency (ANDRA) for the Performance
             Assessment of a Deep Geological Repository," proceedings of the Third
             International High Level Radioactive Waste  Management Conference, Las
             Vegas,  Nevada,  April 1992, pp. 510-516.

SKB91       SKB91:  Final Disposal of Spent Nuclear Fuel, Importance of the Bedrock for
             Safety.  SKB Technical Report  92-20,  May  1992.

SNL 85      A Comparison of Uncertainty and Sensitivity Analysis Techniques for
             Computer Models, SAND84-1461, R.L.  Iman and  J.C. Helton, Sandia
             National Laboratories, March 1985

SNL 92      Preliminary Performance Assessment for the Waste Isolation  Pilot Plant,
             SAND92-0700, Sandia National Laboratories, December 1992.
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SNL 93a     Conceptual Structure of Performance Assessments for the Waste Isolation Pilot
             Plant, SAND92-2285, J.C. Helton, et al., Sandia National Laboratories, April
             1993.

SNL 93b     Preliminary Performance Assessment of the Greater Confinement Disposal
             Facility at the Nevada Test Site, SAND91-0047, Sandia National Laboratories,
             June 1993.

WU 93       Wu, Y.T., A.B. Gureghian, B. Sagar, and R. Codell, 1993, "Sensitivity and
             Uncertainty Analyses Applied to One-Dimensional Radionuclide Transport in a
             Layered Fractured Rock.  Part II:  Probabilistic Methods based on the Limit
             State Approach", Nuclear Technology, Vol 104, pp 297-308 (Nov. 1993)
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                            4.  Quality Assurance Programs

4.1    Introduction

The DOE's ability to demonstrate compliance with the regulatory requirements of 40 CFR
part 191 depends in part on the adequacy of its quality assurance (QA) programs, especially
as they relate to establishing and maintaining the integrity of data upon which rest the
WIPP's design, construction, and compliance assessment.  The EPA is proposing criteria
aimed  at ensuring the soundness of DOE's QA program for data gathering, analyses, and
modeling.

At the time this chapter was prepared, DOE  was proposing a reorganization of its WTPP
program.  Therefore some of this material  may be dated when read.  However, since EPA
WIPP  Compliance Criteria are independent of DOE's internal organization, this will not
affect EPA's 40 CFR part 194 proposal.

4.1.1  Purpose

This chapter identifies criteria that can be used to assure the quality and completeness of data
used in determining the WIPP's compliance with 40 CFR part 191.  Of specific interest is
DOE's QA program for data gathering, data  analyses, and data  modeling at the WIPP.
Additionally, this chapter evaluates the impact of specifying criteria for the WIPP from
EPA's and NRC's QA programs relating to data.

4.1.2  Scope

This chapter identifies EPA, NRC, and DOE QA standards affecting  data and model quality
and identifies DOE data and data  models to which the QA standards might be applied.

4.1.3  Organization

This chapter is organized into four subsections and four appendices.  Section 4.2 describes
the background and context. Section 4.3 summarizes QA requirements controlling  data
gathering, analysis, modeling, and older data and models requiring validation.  Options for
certifying compliance with QA criteria  are discussed in section 4.4.
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Appendices 4A, 4B, and 4C contain detailed information on DOE, EPA, and NRC, QA
requirements, respectively, which are summarized in section 4.3. Appendix 4D provides a
QA requirements comparison matrix reproduced from a draft of ANSI/ASQC E4.

4.1.4  Summary

DOE/WIPP, EPA,  and NRC requirements are reviewed, and those elements pertinent to data
quality are described. Additionally, options for specifying additional QA data quality
requirements for the WIPP are presented.

The major issues identified in this chapter:

1.      No quality assurance requirements are currently specified for the WIPP by an outside
       regulator except for QA requirements specified through other applicable law and
       regulation, e.g.,  RCRA or UIC.

2.      The DOE has voluntarily chosen to adopt the requirements of EPA QAMS-005/80
       and ASMENQA-1.

3.      The DOE is in the process of voluntarily adopting the American National Standard
       ANSI/ASQC E4, a consensus standard  endorsed by EPA.

4.      DOE/WIPP  management has not formally adopted any NRC QA criteria,  although
       DOE/WIPP  staff do follow selected NRC guidance at the working level.

5.      DOE/WIPP  use of pre-existing data has not been determined with certainty; a study
       has been initiated by DOE/WIPP to determine the quality of such data.

4.2    Background

4.2.1  40 CFR part 191, Subparts B and C

40 CFR part 191 Subpart B, Environmental Standards for Disposal, and Subpart C,
Environmental Standards for Ground-Water Protection, establish the disposal system's
performance requirements by specifying criteria for containment, assurance of performance,
individual protection, and ground-water protection.

No requirements are specified for "Quality Assurance;"  However, the standard requires a
"reasonable expectation" that compliance with the requirements  will be achieved based upon

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the total record before the implementing agency (40 CFR ง191.130?)).  This statement
implicitly  requires, a mechanism to (1) produce a record, and (2) to provide a basis for that
record to  support the concept of "reasonable expectation." The formalization of this
mechanism is quality assurance.

Compliance assessments provide the numerical predictions of disposal system behavior.
Substantial uncertainties are likely in predicting performance over many thousands of years.
Even the best numerical demonstrations of compliance will include unquantifiable
uncertainties, such as the appropriateness of the models used to predict  releases  (NRC93a).
Thus, both the quantitative and qualitative records are important in determining  what
constitutes a reasonable expectation of compliance.

4.2.2  Quality Assurance Programs at the WIPP

Quality assurance is the set of those planned and systematic actions necessary to provide
adequate confidence that a structure, system, or component will perform satisfactorily in
service (ASME89).   The formality of the process helps assure a quality outcome.
However, quality outcomes are possible without such formality.  Standard  "good practice"
often leads to a quality outcome.  The lack of formality, however, can at times  impede the
ability to  demonstrate the inherent quality of the outcome.

Currently, the WIPP operates under a formal QA program. Broad QA policies  and
requirements are passed down from DOE headquarters to field and contractor organizations,
suppliers, etc.  A hierarchy  of management and QA documents is in place to accomplish the
transition. Ultimately, quality assurance  project plans and implementing procedures are
developed to control quality-affecting activities at  the field and site levels.
4.3    Quality Assurance Requirements and Guidance Pertaining to Data Quality

This section identifies data QA requirements and guidance issued by DOE, EPA, and the
NRC.  A primary area of interest is the relationships between planning,  data gathering, data
analysis, and data modeling (i.e., compliance assessment), to determine  whether the
appropriate data have been gathered and controlled to support a compliance determination.

Eight DOE and eighteen Sandia National Laboratory documents were reviewed.  The results

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of this review are compiled in Appendix 4A.  Ten EPA and six NRC documents were also
reviewed.  Those specifying criteria relevant to data quality are documented in Appendices
4B and 4C, respectively.  Appendices 4A, 4B, and 4C list requirements pertaining to data
quality.


The material presented below is a summary  of these three appendices.


4.3.1  General

Significant similarities and differences exist  among DOE, EPA, and NRC approaches to
quality assurance. For example:

•     Each organization has one basic document specifying its QA policy and requirements.

      For DOE, it is DOE Order 5700.6C, "Quality Assurance."  For EPA, it is QAMS-005/80,
       "Interim Guidelines and Specifications  for Preparing Quality Assurance Program
      Plans."  For NRC, it is Appendix B  to 10 CFR Part 50, "Quality Assurance Criteria
      for Nuclear Power Plants and Fuel Reprocessing Facilities."

•     Each organization has published additional QA guidance (e.g., NRC's NUREG 1298,
       "Qualification of Existing Data for High-Level Waste Repositories"; EPA's Land
      Disposal Restrictions, no-migration petition standards (40 CFR part 268.6); and DOE
      headquarters—3 levels,  DOE field—2  levels, contractors—several additional levels).

•     Both DOE and NRC generally endorse the requirements of ASME NQA-1, "Quality
      Assurance Program Requirements for Nuclear Facilities."

•     Both DOE and EPA endorse QAMS-005/80, "Interim Guidelines and Specifications
      for Preparing Quality Assurance Program Plans," an internal EPA document geared
      toward data gathering and analysis.  However, DOE's interpretation of QAMS-005/80
      has raised some issues.

•     While DOE has endorsed NQA-1 and QAMS-005/80 for itself, it may waive or
      modify such requirements  during contract negotiations with  its contractors (DOE91).
      Waivers, if granted, would not relieve  DOE of its responsibility to use validated data.

The DOE and EPA are currently  working to adopt and incorporate the requirements of a new
American National Standard, "Quality Systems Requirements for Environmental Programs,
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ANSI/ASQC E4" (ASQC93, DOE93c).9 ANSI/ASQC E4 describes the minimum set of
quality management elements required to conduct programs involving environmental data
collection and evaluation, and environmental technology design, construction, and operation.
Appendix 4D compares ANSI/ASQC E4 and the major DOE, EPA, and NRC QA
requirements documents (ASQC93).  The comparison shows no meaningful gaps in
requirements. As stated in Appendix 4D:

       A particular requirement contained in another standard may  be addressed by
       ANSI/ASQC E4 differently in order to more closely fit environmental programs.
       Consequently, multiple dots in the comparison matrices will indicate where this
       Standard addresses the contents of a particular requirement for the given standard
       being compared.  This does not imply that the original standard or guidance is more
       efficient.  Rather, it indicates  how this Standard addresses similar concepts from the
       perspective of environmental programs.  Equivalence between this Standard and
       specific pans of other standards must be determined by the user through careful
       comparison of the respective texts and confirmation of their applicability to the needs
       of the user.

In actuality,  endorsement of  a standard by an entity is only the first step in determining
compliance.  Absent a detailed and thorough review of processes and procedures to assess
how requirements have been interpreted and implemented, such as is obtained in a vertical-
slice audit, a final determination on compliance  with the endorsed standard cannot be made
with certainty.

4.3.2  Summary of DOE/WIPP Requirements

Requirements of the current  DOE/WIPP program are identified in section 4.3.2.1  for data
gathering, data analysis, and data  modeling; in section 4.3.2.2 for management oversight;
and for older data and models, in  section 4.3.2.3.

4.3.2.1  Data Gathering, Analysis, and Modeling Under Current Programs.   The DOE,
through  references to QAMS-005/80  and NQA-1, has accepted the basic guidance put  forth
    9  An American National Standard implies a consensus of those substantially concerned with its scope and
provisions.  An American National Standard is  intended to aid the producer, the consumer, and the general
public.  The existence of an American National Standard does not in any respect preclude anyone, whether
he/she has approved the standard or not, from producing, marketing, purchasing, or using products, processes,
or procedures not conforming to the standard.  American National Standards are  subject to periodic review, and
users are cautioned to obtain the latest edition (ASQC93).

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by EPA and NRC as summarized in Appendices 4B and 4C.  As noted earlier, actual
compliance is in the details of interpretation and implementation. The requirements noted
below are summarized from Appendix 4A.


4.3.2.1.1  DOE Order 5700.6C (DOE91).  Requirements:


1.      Senior management is responsible for mission accomplishment and also Quality
       Assurance Program (QAP) implementation; the QAP shall discuss how the QA
       criteria will be satisfied.

2.      Personnel shall be trained and qualified to perform assigned work; all important work
       will be described in documents and records will be kept.

3.      Work shall be performed to established standards using approved instructions;
       equipment used for data collection shall be calibrated and maintained.

4.      Adequacy of designed products shall be verified and validated by others who did not
       do the work.

5.      Management shall periodically assess the QAP to assure results; independent
       assessments shall be conducted to assess quality; persons must be technically qualified
       and knowledgeable in the areas assessed.

4.3.2.1.2  DOE Headquarters - WIPP Project Division (EM-342^) Quality Management Plan
(OMP) (DOE91a).  Requirements:

1.      Projects must be conducted in accordance with applicable DOE Orders, and federal,
       state, local,  and tribal regulations.

4.3.2.1.3  WIPP Project Integration Office Plan for the WIPP Quality Assurance Program
(DOE92a).  Requirements:

1.      The formal QA group is required to be organizationally independent.

2.      The WPIO QA&C Branch is required to  conduct periodic reviews of program
       documentation to assure quality of program data and information.

3.      Performance requires personnel training,  identification of important items, and proper
       handling, storage, and  shipping of data.   Maintenance  and calibration are required of
       data collection equipment.

4.      Design inputs are to be controlled, including verification.
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5.     Inspection and acceptance testing are required to assure that items will perform as
       intended, including completeness and accuracy of data.


4.3.2.1.4  WPIO QA Program Plan for the WIPP Experimental-Waste Characterization
Program (DOE92).  Requirements:

1.     All activities affecting quality are to be performed using written and approved
       procedures, instructions, or drawings.

2.     EPA's QAMS-005/80 criteria (EPA80) and,  where applicable, NQA-1, Elements 2,
       3, 5, 8,  9, 10, 11,  12, 13, 14,  16, 17, and 18 are adopted.

3.     QA objectives require precision, accuracy, representativeness, completeness, and
       comparability in accord with NQA-1, Element 3.

4.     Sampling procedures  require representative samples in accord with NQA-1, Elements
       5 and 13, the latter with respect to handling, storage, cleaning, packaging, shipping,
       and preservation of items.

5.     Sample custody requires conformance to NQA-1, Elements 8 and 13,  with respect to
       identification  and control of sample.

6.     Calibration procedures and frequency require conformance to NQA-1, Elements 12
       and 14.

7.     Analytical procedures must conform to NQA-1, Element 9.

8.     Data reduction, validation and reporting procedures require conformance to NQA-1,
       Element 17, which deals with documenting evidence of compliance.

9.     Internal  QC checks and frequency procedures require conformance to  NQA-1,
       Elements 9 and 11, which  concern process test control, use of spiked  samples,  etc.

10.    Performance and system audit frequency procedures require conformance to NQA-1,
       Element 18.

11.    Preventive maintenance procedures require conformance to NQA-1, Elements 10 and 12.

12.    Specific and routine procedures to assess data quality require conformance to NQA-1,
       Element 11.   "The quality  assurance  objective for measurement data is to ensure that
       characterization data  are of known and acceptable quality.  Precision,  accuracy, and
       completeness  are measures essential to assessing the quality of the analysis  data,  and
       hence, to applying the data appropriately in the decision-making process."
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13.    Corrective action procedures require conformance to NQA-1, Element 16.

14.    QA reports'to management require conformance to NQA-1, Elements 2 and 16.


4.3.2.1.5 WPIO Waste Characterization Proeram Plan for the WIPP (DOE92bN).
Requirements:

1.     With respect to data quality, WPIO QAPP (DOE92) is cited as the source document
       for performance requirements and QA objectives governing waste characterization.

2.     "Implementation Requirements of the Program" requires a waste characterization data
       management system to be in place with the following provisions:  system for
       categorization of records; qualified technical review; specified approval system;
       established media, forms and formats;  controls on  reproduction and storage;
       systematic distribution, transfer, and reporting; and rules for access and security.

3.     A Performance Demonstration Program (PDP) is required to ensure compliance with
       the QA objectives defined in the WPIO QAPP.  This includes all analyses in the TRU
       waste characterization program that can be realistically tested for accuracy.  The PDP
       identifies acceptance criteria  to be used in evaluating a facility's performance.  Use of
       blind audit samples is required.

4.     Training for those functions that involve special skills,  certifications, or controls is
       recommended, but not required.

4.3.2.1.6 WIPP OA Program Description (SNL/QAPD)  (SNL92fr).   Requirements:

1.     This document defines a quality-affecting activity "... as any activity which will
       influence the quality of compliance assessment utilized  data and conclusions generated
       by that activity."  Such activities  include experiment concept and requirements
       development,  experiment design and fielding,  data collection and reduction,  analyses
       and reporting.

2.     "Design Control" sets restrictions  on design of experiments.

3.     "Identification and Control" of Items requires  that  quality-affecting data, samples,
       etc., be identified and controlled.

4.     "Test Control" cites requirements  for logbook control,  including presumably, field
       logbooks.

5.     "Control of Measuring and Test Equipment" requires instrument calibration and
       validation of all data taken with instruments found to be uncalibrated.
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6.     "Handling, Storage and Shipping" requires specification of controlled environments to
       preclude data loss.

7.     "QA Records" requires individual project procedures to specify the QA records
       generated by the activity covered by the procedure.

8.     "Computer Software" requires validation, verification, and changes to software to be
       documented.

4.3.2.1.7 Preliminary Performance Assessment for the Waste Isolation Pilot Plant,
December 1992. Volume 1:  Third Comparison with 40 CFR  191. Subpart B (SNL92a\
Requirements/Findings:

1.     Reports results of preliminary compliance assessments; not a requirements document.

2.     Methods for reducing uncertainties are listed in Table 3-1; all methods stress QA.

3.     One type of uncertainty that cannot be completely resolved is the validity of various
       conceptual models for predicting disposal system behavior 10,000 years into the
       future.

4.     QA procedures control compliance assessment analyses in three areas-data, software,
       and analysis, and two  sub-areas—elicitation of judgments from expert panels and
       documentation.

5.     QA on data ensures traceability  and documentation of data.

6.     QA on software ensures traceability, retrievability, verification, and documentation.

7.     QA for analyses controls traceability, validation, personnel qualifications, data use,
       and peer review.

8.     QA on documentation ensures traceability on how analyses were performed and how
       decisions were reached.

9.     The Environmental Evaluation Group (EEG) of the State of New Mexico provides an
       independent QA function (i.e., technical oversight).

4.3.2.1.8 Preliminary Performance Assessment for the Waste Isolation Pilot Plant.
December 1992. Volume 2:  Technical Basis  (SNL921.  Requirements:

1.     An integrated database is described.  The primary database is to contain measured and
       laboratory data gathered during  regional characterization.
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2.     "Because the analyses can be no better than these data, the data base should contain
       all data necessary for the compliance assessment and disposal system design, have as
       little subjective evaluation as possible, and be quality assured."

4.3.2.1.9  WIPP Procedure No. PAPQ2.  Computer Software Supporting Performance
Assessments of the Waste Isolation Pilot Plant (SNL93a). Requirements:

This procedure  requires documentation, verification reports, peer review, and evidence of
traceability and retrievability.


4.3.2.1.10  WIPP Procedure No. PAP03. Parameter Selection Quality  Assurance Procedures
(SNL93fr).  Requirements:


This procedure  specifies five steps for controlling parameter quality: traceability,
retrievability, verification and parameter review, documentation of parameters, and formal
elicitati9n of expert judgment.


4.3.2.1.11  WIPP Procedure No. PAPQ4. Analysis Quality Assurance Procedures (SNL93c).
Requirements:

The procedure outlines the six main steps to ensure quality: analysis planning, qualification
of personnel,  data entry, validation of models, peer review, documentation for traceability.


4.3.2.1.12  WIPP Procedure No. PAP05. Report Review Quality Assurance Procedures
rSNL93d).  Requirements:

Typical report review procedures are described  with the important addition of using peer
review panels.


4.3.2.1.13  WIPP Procedure No. PAP06. Use of Expert Judgment Panel Quality Assurance
Procedures CSNL93e'). Requirements:


The procedure describes the planning, implementing, reviewing and documenting of the use
of Expert Judgment Panels.


4.3.2.2 Management and Oversight.  The WIPP management structure has many
organizational levels between  DOE headquarters and the activities in the field. Nonetheless,
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DOE management was found to be aware of issues and actively involved in their resolution
(DOE93, DOE93a, DOE93c).

4.3.2.2.1  Organization.  WHO reports to EM-342 (DOE HQ) and is responsible for the
day-to-day implementation of DOE-HQ policy and overall program guidance.  The WPIO
has the direct responsibility for the execution  and implementation of all WIPP-related
activities, including integration of the prime contractors (Westinghouse-Waste Isolation
Division and Sandia National Laboratory) and integration of TRU waste preparation
characterization, packaging, and transportation.  The WPIO sets forth QA requirements
through the WPIO Plan for the WIPP QA Program (DOE92a), the QA Program Plan
(QAPP), the Quality Assurance Program Plan for the Waste Isolation Pilot Plant
Experimental-Waste Characterization Program (DOE92), and the Waste Characterization
Program Plan for the Waste Isolation Pilot Plant (DOE92b).

The DOE WIPP Project Site Office (WPSO)  reports directly to the WPIO and is  responsible
for the management of the WIPP Management and Operating Contractor (MOC—
Westinghouse-Waste Isolation Division).  The WPSO coordinates the MOC activities and
maintains oversight of all site activities, including quality assurance requirements.  The
WPSO sets forth QA requirements through  the Quality Assurance Program Description
(QAPD) (DOE91a).

Westinghouse-Waste Isolation Division (W-WID) reports directly to WPSO and is
responsible for  operations at the WIPP test  site, including support of experiments. The W-
WID QA Program Manual was not reviewed  in this study.

SNL reports directly to WPIO and is responsible for the scientific programs and compliance
assessment for the WIPP.  SNL provides the  necessary  data to address the requirements of
40 CFR part 191  with respect to long-term  performance (DOE92). SNL sets forth its QA
requirements through  its WIPP QA Program, individual QA Project Plans,  and implementing
procedures.

The Albuquerque Field Office (AL) is  responsible for various administrative and contractual
support functions, including support of the QA function and ensuring the implementation of
DOE Orders and policies (DOE92).
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4.3.2.2.2  Oversight of Data Quality. A review of DOE/WIPP procedures found many
instances of management involvement at each organizational level.  However, the quality of
the involvement and oversight cannot be determined solely from the written documentation.
Aii assessment would req_ .re technically focused QA auditing to determine, at the
implementing level, the degree to which activities that affect quality are codified in useable
procedures and instructions, and in fact, to determine actual use.  A judgment on the
soundness of DOE's waste characterization process will depend on DOE's ability to
demonstrate effective administration of the program.

There are no comparable data, documentation, and procedures  for site characterization.  The
extent of decisions on site characterization, design, and construction (i.e., quality-affecting
activities) based on data obtained without a formal QA program will be closely examined in
any compliance application.

4.3.2.3  Older Data and Models Requiring EPA Validation.

4.3.2.3.1  Data.  An important factor in compliance assessment is the quality and extent of
use of older data.  The DOE is presently undertaking a "WIPP data quality assessment" to
determine whether the WIPP data have been collected by SNL and its contractors under a
QA program that satisfies DOE requirements (DOE93c).  Another important  factor is
whether these data have been or will be used in quality-affecting activities. The data quality
assessment is being undertaken under the aegis of the EM-342  Quality Management Plan.

The assessment is divided into two basic tasks:  (1) a review of the WIPP siting and site
characterization activities from 1975  to 1984 called the "review of old data,"  and (2) a
review of current data (1984 to the present).  The assessment will focus on four technical
areas:  natural barriers, disposal system design and engineered barriers, waste interactions,
and human-initiated processes and events.

The primary criteria to be used in the assessment are derived from NRC NUREG  1298,
"Qualification of Existing Data for High-Level Radioactive Waste Repositories.  SNL WIPP
data must have been obtained under an approved QA Program  which  has been revised to
meet changing DOE QA requirements, and SNL WIPP QA Program  must have been
adequately implemented in accordance with written procedures for field and laboratory data
collection and analysis activities.
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Indications are that no formal QA Program was used prior to 1978 for site investigations.

In commenting on EPA's Advance Notice of Proposed Rule-making on compliance criteria,
DOE proposed the following steps to verify data used in compliance assessment (DOE93d):

•      The data  will be examined against currently approved QA procedures.  This
       examination will be directed to show that if the data had been obtained under current
       QA practices,  the results would be equivalent to the ongoing data collection.

•      If QA equivalency of the data cannot be shown,  and the data are crucial to
       compliance demonstration, an independent peer review group will be established to
       assess the validity of the data, and DOE will submit the findings to EPA.

•      If an acceptable QA level cannot be demonstrated to EPA, and the data are crucial to
       compliance, DOE will do statistical resampling to establish the quality of the data or
       initiate an activity to reacquire the needed data.  However, the original data will not
       be discarded.   Instead, it will be used as confirmation of the newly acquired data.

4.3.2.3.2 Models. Sandia National Laboratories is conducting iterative compliance
assessments to provide interim guidance while preparing for a final compliance evaluation
(SNL92).  These compliance assessments describe the conceptual basis for consequence
modeling and the compliance assessment methodology, including the selection of scenarios
for analysis, the determination of scenario probabilities, and the estimation of scenario
consequences. (SNL92)

Several DOE documents describe the relationship between  long-term regulatory information
needs and the experimental progress that will fill those needs. Although the Department has
canceled the WIPP Test Phase,  it is still instructive to review the related documents.  For
radioactive waste tests, the "WIPP Test Phase Plan" describes experimental programs related
to, among other things, rock mechanics, hydrology of and  transport within the WIPP host
rock, and flow and transport in rock layers surrounding the WIPP.  Laboratory and field
studies conducted during the Site Characterization Phase for the WIPP have provided
information used to date in compliance assessments of the WIPP. Details are provided in
"WIPP Test Phase Activities in Support of Critical Performance Assessments (40 CFR 191
B) Information Needs" prepared for the National Academy of Sciences WIPP Panel
(SNL92a).

The modeling process described in references SNL92 and SNL92a includes significant

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participation of peer review groups external to Sandia.  The iterative nature of the work leads
to a constant updating of models.  If, during review of a compliance application, it is
determined that one or more parts of the model(s) is based upon data obtained in the early
stages of the WIPP program when a formal QA program was not used, the model's validity
would become an issue.  If found to exist,  such issues must be settled using the  QA
standards and criteria applicable to the compliance assessment process itself.  NRC Criterion
No. 3, Design Control, discussed in Appendix 4C, addresses this  issue.

WIPP procedure No. PAP02, Computer Software Supporting Performance Assessments of
the Waste Isolation Pilot Plant, mentioned in 4.3.2.1.9, describes  four classes of software:

       A-    Adjudicated (full QA status)
       C-    Candidate (partial QA status, possibly undergoing continued refinement)
       D-    Dormant (obsolete software formerly in Class A or C)
       X-    Experimental (entry level, software in early stages of development or
             experimentation, no QA requirements)

A Software Review Committee decides whether to classify software as Class A.   It is Sandia
policy to use only Class  A software for the compliance assessment to support the application
for certification of compliance.
4.3.3  Summary of EPA Requirements

At least three EPA source documents identify requirements pertaining to data quality:

•      Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans
       QAMS-005/80

•      Hazardous and Solid Waste Amendments Act of 1984

•      Quality Systems Requirements for Environmental Programs ANSI/ASQC: Standard
       E4-199310

The following descriptions are relatively brief, with detailed information contained in
   10 Currently in the process of being adopted by EPA, DOE and others (EPA93a, DOE 93c).

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Appendix 4B.

4.3.3.1 QAMS-005/80. Each entity generating data has the responsibility to implement
minimum procedures to assure that the precision, accuracy,  completeness, and
representativeness of the data  are known and documented.

QAMS-005/80 presents guidelines and specifications describing the 16 essential elements of a
QA Project Plan, covering all environmentally related measurements, i.e., all field and
laboratory investigations that generate data.  A QA Project Plan is a document written for
each specific project or continuing operation.  As described  in Appendix 4B, Section 1.5,
EPA-approved reference, equivalent, or alternative methods must be used, and their
corresponding Agency-approved guidelines must be applied wherever they are available and
applicable.  Specific procedures to assess precision and accuracy on a routine basis during
the project must be described  in each QA Project Plan.

4.3.3.1.1  Data Gathering, Analysis, Modeling. Of the 16 essential elements of a QA
Project Plan, two are administrative and six pertain to management and  oversight.  The
remaining eight elements pertaining to data quality are:  QA objectives for measurement data
in terms of precision, accuracy, completeness, representativeness, and comparability;
sampling  procedures; sample custody; calibration procedures and frequency; analytical
procedures; data  reduction, validation, and reporting; internal quality control checks; and
specific routine procedures used to assess data precision, accuracy, and  completeness.

4.3.3.1.2  Management and Oversight.  The six QA elements pertaining to management
oversight are: project description; project organization and responsibility; preventive
maintenance; performance and system audits; corrective action; and quality assurance reports
to management.
4.3.3.1.3  Older Data.  This topic is not explicitly addressed in QAMS-005/80.

4.3.3.2  Hazardous and Solid Waste Amendments Act of 1984.  The Hazardous and Solid
Waste Amendments Act of 1984 applies to RCRA and UIC  no migration regulations and
generally prohibits the continued land disposal of hazardous  waste unless certain treatment
standards are met.  This prohibition does not apply, however, if the EPA Administrator
makes the  determination that the prohibition is not required  in order to protect human health
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and the environment.  The Administrator may make this determination only if "it has been
demonstrated to the Administrator, to a reasonable degree of certainty, that there will be no
migration of hazardous constituents from the disposal unit or injection zone for as long as the
waste remain hazardous."

The EPA promulgated 40 CFR Part 268.6, standards for review of no-migration petitions.
This regulation applies to land disposal units other than underground injection wells.  The
EPA has provided guidance for petitioners seeking variances from the land disposal
regulations (EPA92a).  The Agency also promulgated 40 CFR Part 148 which contains the
standards for no-migration determinations for underground injection wells.

4.3.3.2.1 Data Gathering. Analysis. Modeling.  40 CFR Section 268.6 specifically requires
a quality assurance and quality control plan that addresses all aspects of the no-migration
demonstration, including if and to what extent any aspects of the demonstration contribute
significantly to uncertainty.  This analysis must include an evaluation of the consequences of
predictable future events.

In addition, the demonstration must meet the following criteria:

•      data must be accurate and reproducible to the extent that state-of-the-art techniques
       allow;

•      estimation techniques for chemical and physical properties of the waste and all
       environmental parameters must have been approved by  EPA;

•      simulation models must be calibrated for the specific  waste and site conditions, and
       verified for accuracy  by comparison with actual measurements; and

•      if an observed condition at the site differs from what was modeled or otherwise
       predicted,  EPA must be notified.

A No-Migration Petition submitted pursuant to 40 CFR Section 268.6 must include a
monitoring plan designed to  verify compliance with the conditions of any variance that is
granted.  There must be a quality assurance and quality control plan addressing all aspects of
the monitoring program.

Unlike 40 CFR Section 268.6, Section  148.21  specifically requires the petitioner to conduct a
sensitivity analysis to determine the effect that significant uncertainty may have on the

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demonstration.  Also Section 148.21 requires that the demonstration then shall be based on
conservative assumptions identified in  the analysis.

Other requirements found in 40 CFR Section 148.21 are similar to, but slightly different
than, those in 40 CFR Section 268.6.  These differences are detailed in Appendix 4B.

4.3.3.2.2 Management and Oversight. This topic is not explicitly addressed in the RCRA
or UIC regulations.

4.3.3.2.3 Older Data.   This topic is not explicitly addressed in the RCRA or UIC
regulations.

4.3.3.3  ANSI/ASQC E4.  ANSI/ASQC E4 describes the minimum set of quality
management elements required to conduct programs involving (1) environmental data
collection and evaluation, and (2) environmental technology design, construction, and
operation. In addition, the elements also contain nonmandatory supplemental guidance that
may be used to augment the basic requirements.  This chapter considers only requirements
related to data quality.

ASQC E4 specifies 15  QA requirements in  the areas of interest to this chapter.

4.3.3.3.1 Data Gathering, Analysis. Modeling.  Of the 15 QA elements,  5 pertain to the
collection and evaluation of environmental data: planning and scoping, design of data
collection operations, implementation of planned  operations, assessment and response, and
assessment and verification of data usability.

4.3.3.3.2 Management and Oversight. Ten QA elements pertain to management and
oversight:  management and organization, quality system and description,  personnel
qualification and training, procurement of items and services,  documents and records,
computer hardware and software, planning, implementation of work processes, assessment
and response, and quality improvement. Detailed requirements in these categories are
supplied in Appendix 4B.

4.3.3.3.3 Older Data.  ASQC E4 contains several requirements directly or indirectly
pertaining to the quality of older data.  These are:
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       any data obtained from sources that did not use a quality system equivalent to ASQC
       E4 shall be assessed according to approved and documented procedures;

       the environmental data collection design process shall ensure that data are traceable to
       the procedures (including revisions) used to produce the data and to the personnel
       generating or collecting the data;

       any restrictions on the use of any interim results shall be identified and stated with the
       data in a manner that clearly defines the nature of the restriction and the specific data
       to which it applies;

       the validity of any measurements and tests performed with out-of-calibration
       equipment shall be evaluated, and such measurements and tests shall be repeated as
       required; and

       data obtained previously from a method or instrument found to be nonconforming to
       specifications shall be evaluated to  determine the impact of the nonconformance on
       the quality of the data. The impact and the appropriate action taken shall be
       documented.
4.3.4  Summary of NRC Requirements


The purpose of this section is to identify NRC QA requirements for data gathering, analyses,
and modeling, for the high-level radioactive waste disposal systems.1
11
Quality assurance requirements for disposal of high-level radioactive waste in geologic
repositories are specified in Subpart G of 10 CFR Part 60.  Subpart G requires DOE to
implement a QA program based on the criteria of Appendix B of 10 CFR Part 50 as
applicable, and appropriately  supplemented by additional criteria.

As stated in 10 CFR Section 60.151, the QA program applies to all systems, structures, and
components "important to safety;" to design  and characterization of barriers "important to
waste isolation"; and to activities related thereto.  These activities include:  site
characterization, facility and component construction, facility operation,  performance
confirmation, permanent closure, and decontamination and dismantling of surface facilities.
   11 References to DOE in this section refer to DOE's Office of Civilian Radioactive Waste Management
(OCRWM), not DOE/WIPP.


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The term  "important to safety," which is defined in 10 CFR Section 60.2, means those
engineered structures,  systems, and components essential to the prevention or mitigation of
an accident that could  result in a radiation dose to the whole body, or any organ, of 0.5 rem
or greater at or beyond the nearest boundary of the unrestricted area at any time until the
completion of permanent closure.

To identify items important to safety and waste isolation, guidance is provided in NUREG-
1318, "Technical Position on Items and Activities in the High-Level Waste Geologic
Repository Program Subject to QA Requirements"  (NRC88B).

To identify structures,  systems, and components important to safety, DOE should use a
systematic analysis according to NUREG-1318.  Probabilistic risk assessment techniques may
be used to the extent practicable.  Probabilities of scenarios and releases will need to be
developed.

Items important to waste isolation should include those engineered  and natural  barriers that
are relied on to meet the post-closure performance objectives of the disposal system.   The
DOE should allocate performance among the various components of the natural and
engineered barrier systems to provide a basis for determining which items may be important
to waste isolation.

The NRC QA requirements relating to data that are important to safety or to waste isolation
are discussed below.

4.3.4.1  Data Gathering, Analysis,  Modeling.

4.3.4.1.1 Data Gathering.  Site characterization is  a data gathering activity.  As required  by
Subpart B of 10 CFR  Part 60, DOE must conduct a program of site characterization in
accordance with the following:

•      Investigations to obtain the required information shall be  conducted in such a manner
       as to limit adverse effects on the long-term performance of the geologic disposal
       system to  the extent practical.

•      The number of exploratory boreholes and shafts shall be limited to the  extent practical
       consistent with obtaining the information needed for site characterization.
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•      To the extent practical, exploratory boreholes and shafts in the geologic disposal
       system operations area shall be located where shafts are planned for underground
       facility construction and operation or where large unexcavated pillars  are planned.

•      Subsurface exploratory drilling, excavation, and in situ testing before  and during
       construction shall be planned and coordinated with geologic disposal system
       operations area design and construction.

The DOE is required to prepare a Site Characterization Plan  (10 CFR 60 Subpart B) which
includes plans for any investigation activities that may  affect  the capability of the area to
isolate high-level radioactive waste; plans  to control any adverse impacts from such site
characterization activities that are important to safety or that  are important to waste isolation;
and plans for quality assurance in data collection, recording,  and retention.

Along with the Site Characterization Plan, DOE must submit to the NRC a description of the
QA program to be applied during the site  characterization phase.   As a  result of meeting  the
requirements of the QA Plan, Q-lists will  be generated.  The criteria  developed in preparing
Q-lists are essential to identifying quality-affecting activities and, of necessity, require a
disciplined, systematic analysis of the entire project (NRC88b).

A Q-list identifies structures, systems, and components important to safety and engineered
barriers important to waste isolation. A quality activities list identifies the site
characterization activities that may provide data for use in compliance assessments  of the
waste isolation and containment capabilities  of natural  and engineered barriers, those
activities related to the actual compliance  assessments,  and those activities that may adversely
impact the waste  isolation capabilities of these barriers.

Data and information needs are identified  by compliance assessments, performance allocation
among the various components of the natural and engineered barrier systems, design, and
modeling of the geologic disposal system. The needs depend on the availability and quality
of existing data.

The QA criteria for data gathering are highlighted below.  Details are provided in  Appendix 4C.

Data collection in support of design development and verification  is a design activity and is
subject to the requirements of design control, design verification,  and design changes control.
Measures must be established to translate  correctly applicable regulatory requirements into

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plans, procedures, and instructions for data collection activities (Criterion 3, Appendix 4C).

Field and laboratory procedures associated with exploratory investigations within the site
characterization program must be controlled to assure that such changes are subsequently
documented and verified in a timely manner by authorized personnel (Criterion 5, Appendix 4C),

Formal control should be established over identification of geologic  cores and field and
laboratory samples.  Identification and control measures  should be designed and maintained
to ensure that geologic and environmental data are correctly identified as to the time and
exact location of origin and that identification is maintained from collection through
shipment, sample split (subsample), and subsequent analysis (Criterion 8, Appendix 4C).

Data collection and other site characterization activities should be controlled as special
processes. Acceptable methods for qualifying the special processes  associated with scientific
investigations include the conduct of a prototype test, a technical review, or a peer review
(Criterion 9, Appendix 4C).

Inspection procedures, instructions, or checklists should  be established.  This includes
identification of mandatory inspection hold points beyond which work may  not proceed until
checked by a designated inspector (Criterion 10, Appendix 4C).

Test controls should be established for data acquisition and scientific investigations. Items
tested should be identified, controlled, and ultimately dispositioned,  and  samples  should be
archived, as required by procedures (Criterion 11, Appendix 4C).

Tools, gauges, instruments, and other measuring and testing devices should be properly
controlled, calibrated, and adjusted at specified periods (Criterion 12, Appendix 4C).

Handling, storage, packaging, and shipping of samples must be controlled to prevent
damage, loss, contamination, deterioration by environmental conditions,  and
misidentification.  Where multiple organizations are involved, appropriate procedures should
describe interface and custody responsibilities (Criterion 13, Appendix 4C).

Inspection and test status of samples  should be identified to prevent inadvertent use of
samples yet to be inspected or tested or found unacceptable for use  (Criterion 13,
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Appendix 4C).

QA records include:  scientific and engineering data and logs; geotechnical data; results of
reviews,  inspections, and tests; monitoring of work performance; qualification of personnel,
procedures, and equipment; and other documentation such as peer review reports.  QA
records should be identifiable, retrievable, and maintained.  Procedures must be established
to determine the retention periods for QA records and to describe methods of
documenting/recording, reviewing, and confirming accuracy of records, which include
laboratory and field notebooks, logbooks, and data sheets (Criterion 17, Appendix  4C).

Audits should include the review and evaluations of the applicable procedures, instructions,
activities, and test data from samples, to ensure they are acceptable (Criterion 18,  Appendix 4C).

4.3.4.1.2 Data Analysis.  Data analysis  is a design activity subject to the requirements of
design control, design verification, and design changes control.  Data analyses include the
initial step of data reduction, as well as broad level systems analyses (such as compliance
assessments) which integrate many other data and analyses of individual parameters
(Criterion 3, Appendix 4C).

QA records should be identifiable, retrievable, and maintained for data analyses, including
data reduction documents (Criterion 17, Appendix 4C).

Audits should encompass technical evaluations of applicable procedures,  data analyses, and
data reduction documents (Criterion 18, Appendix 4C).

4.3.4.1.3 Data Modeling. The data needed for construction of an adequate model of the
disposal system and compliance assessments, and the associated  computer modeling, are
subject to 10 CFR 60 Subpart G QA requirements.

Computer programs should be developed, controlled, and used in accordance with  the QA
program. Guidance for documentation of computer codes is provided by NUREG-0856,
"Final Technical Position on Documentation of Computer Codes for High-Level Waste
Management" (NRC83).  Documentation includes five categories:  software summary,
description of mathematical models and numerical methods, user's manual, code assessment
and support, and continuing documentation and code listing.
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General recommendations for software quality assurance (SQA) programs are provided in
NUREG/CR-464Q, "Handbook of Software Quality Assurance Techniques Applicable to the
Nuclear Industry" (NRC87).  The handbook is  intended to be' used by the nuclear power
industry as an aid for structuring QA programs and assessing the adequacy of existing
software practices including development and use.

Guidance for both NRC organizations and NRC contractors in the development and
maintenance of software for use by NRC staff is provided in NUREG/BR-0167, "Software
Quality Assurance Program and Guidelines" (NRC93). The guidelines in this document
apply to technical application software used in safety decisions by the NRC.  The
applicability of these guidelines will depend on the purpose and use of the software and
management's judgment of the cost-effectiveness of each software quality activity.  Most
projects should incorporate verification and validation, configuration management,  and
documentation control activities.

Verification is the process of ensuring that the products and processes of each major activity
of the life cycle meet the standards for the products and the objectives of that major activity.
Validation is the process  of demonstrating that the as-built software meets its requirements.
Validation is accomplished by review and demonstration in  a live or simulated environment.

Verification and validation activities include planning, formal life cycle reviews and audits,
peer inspections, and testing.  Testing is the process of detecting errors and verifying
performance.  Testing typically includes  unit integration, qualification, and acceptance
testing.

Fundamental to configuration management are the concepts of a baseline and change control.
A baseline is a document or software that has been formally reviewed and agreed upon by
the developer and sponsor, and thereafter serves as the basis for further development.  It can
be changed only through formal change control procedures.  Change control is  the process
by which a change to a baseline is proposed, evaluated, approved or rejected, scheduled, and
tracked.

Peer reviews may be employed for data  modeling and computer models.  Guidance on the
use of the peer review process is provided in NUREG-1297,  "Peer Review  for High-Level
Nuclear Waste Repositories"  (NRC88).  A peer review is a documented,  critical review
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performed by peers who are independent of the work being reviewed.  NUREG -1297
provides guidance on areas where a peer review is appropriate, the acceptability of peers,
and the conduct and documentation of a peer review.

A peer review should be used when the adequacy of information (e.g., data, interpretations,
test results, design assumptions, etc.) or the suitability of procedures and methods (e.g., data
modeling) cannot otherwise be established through testing, alternate calculations, or reference
to previously established standards and practices.

In general, the following conditions indicate situations in which a peer review should be
considered:  critical interpretations or decisions with significant uncertainty, decisions or
interpretations that  significantly affect compliance assessment, and ambiguous data or
interpretations.
The acceptability of any peer review group member is based on two requirements-technical
qualifications and independence—both of which should be satisfied.

Additional discussions of QA criteria relating to data and computer modeling are included in
Appendix 4C, Criteria 3, 6, 8, 9,  11, 14, 15,  17 and 18.

4.3.4.2  Management and Oversight.  NRC QA procedures describe how DOE and prime
contractors exercise responsibility for the overall QA program.  The extent of management
responsibility and authority from DOE headquarters and from the field office should be
addressed.  Clear management controls and effective lines of communication must exist
between DOE and its contractors to assure direction of the QA program. The  more layers of
organizational structure, each claiming responsibility for a percentage of the program, the
more likely communications will break down.  However, the consequences of such
breakdowns are more likely to be manifest in wasted time and effort than in the creation of
safety problems.

The DOE and its prime contractors are required to identify a management position within
each respective organization that retains overall authority and responsibility for the QA
program. This position must:

•      Be at the same or higher organization level as the highest line manager directly
       responsible for performing activities affecting quality and be sufficiently independent
       from cost and schedule.
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•      Have effective communication channels with other senior management positions.

•      Have no duties or responsibilities unrelated to QA that would prevent full attention to
       QA matters.

Persons and organizations performing QA functions must have sufficient authority and
organizational freedom to:

•      Identify quality problems.

•      Initiate, recommend, or provide solutions through designated channels.

•      Verify implementation of solutions.

•      Assure that further processing,  delivery, installation, or operation is controlled until a
       nonconfonnance, deficiency, or unsatisfactory condition has been corrected.

The QA program should provide control over all activities affecting the quality of the
identified activities, structures, systems, and components to an extent consistent with their
required performance.  According to NUREG-1318 (NRC88b), the  10  CFR Part 60 Subpart
G requirements can be met using graded QA measures based on considerations such as:

•      The impact of malfunction  or failure of an item, or the impact of erroneous data
       associated with data collection activities, on safety or waste isolation.

•      The complexity of design or fabrication of an item,  or design and implementation of a
       test, or the uniqueness of an item or test.

•      The special controls and surveillance needed over processes, tests,  and  equipment.

•      The degree to which functional compliance can be demonstrated by inspection or test.

•      The quality, history, and degree of standardization of the item or test.

A readiness review program  should be established  and executed at appropriate major
milestones to complement the inspection program.

Additional discussions of QA criteria related  to management and oversight are included  in
Appendix 4C, Criteria 1, 2,  15, 16, and 18.

4.3.4.3 Older Data.  Data may exist that were developed before the implementation of a 10

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CFR Part 60 Subpart G QA program by DOE and its contractors; or developed outside the
DOE disposal system program, such as by oil companies, national laboratories, universities;
or published in technical or scientific publications.  The "existing data" category does not
include information accepted by the scientific and engineering community as established facts
(e.g., engineering handbooks, density tables, gravitational laws).

NRC specifies that procedures should be established describing methods of reviewing and
qualifying existing data.  Guidance is provided in NUREG-1298,  "Qualification of Existing
Data for High-Level Nuclear Waste Repositories, Generic Technical Position" (NRC88a).

Four alternative methods  or combination of methods are acceptable  for use in qualifying
existing data:

•      Peer review in accordance with NUREG-1297, "Peer Review for High-Level Nuclear
       Waste Repositories" (NRC88).

•      Use of corroborating data (i.e., existing data used to support or substantiate other
       existing data).

•      Use of confirmatory testing.

•      Demonstration that a QA program similar in scope and implementation to a
       10 CFR Part 60 Subpart G QA program had been utilized.

Existing  data should be qualified in accordance with approved and controlled procedures.
These procedures should provide for  the documentation of the decision process and provide
an auditable trail of all factors used in arriving at the  choice of the qualification method(s),
and the decision as to the qualification of the data.  The procedures may allow a graded
approach to qualification  depending on the importance of the data to assuring safety or waste
isolation. Individuals evaluating data should be qualified and not directly responsible for the
data (i.e., not the performer of data acquisition or his immediate supervisor) (Criterion 3,
Appendix 4C).

4.3.5   ANSI/ASQCE4

ANSI/ASQC E4 is organized  into three basic parts:  Part A, Management Systems; Part B,
Collection and Evaluation of Environmental Data; and Part C, Design, Construction, and
Operation of Environmental Technology. For EPA's purposes with respect  to DOE/WIPP,

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only Parts A and B are addressed in the following sections.


For each of 15 ANSI/ASQC E4 criteria, the sections below  list a purpose for that criterion.
The numbers in parentheses indicate corresponding elements of NQA-1.


4.3.5.1       Part A:  Management Systems


4.3.5.1.1 Management and Organization (1)


       PURPOSE:   To identify all quality-affecting activities and to assure tfiat key
                    personnel responsibilities and authorities are clear.


       •      The single most important characteristic of an effective quality assurance
              program is a project manager who accepts full responsibility for the quality of
              the end product and who carefully assigns the achievement and assurance of
              the end product quality to a capable and trained staff.

       •      The project has designed an organization and  assigned functions and authorities
              such that the achievement and assurance of quality are an integrated part of
              everyday work activities.

       •      The project manager retains full responsibility and accountability for the
              overall quality  assurance program.  The project manager is responsible and
              accountable for the end product quality.

       •      Once the total job is understood and can be articulated by the project  manager,
              the organization has been structured, functions assigned,  and plans formulated
              that integrate the actions to accomplish the objectives.

       •      The project manager has made a commitment to comply  with regulatory
              requirements, and this is reflected in the assignment of functional authorities.

4.3.5.1.2 Quality System and Description (2)


       PURPOSE:   To cause the project manager to articulate the actions necessary to plan
                    and implement an effective quality assurance program.


       •      The project has established an effective QA program prior to the start of work.

       •      The project's QA program description reflects full comprehension of the
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             performance objectives of the regulations, and authorities have been effectively
             assigned to ensure accomplishment of the performance objectives and the
             design bases.

       •      The project has identified items and activities important to the accomplishment
             of the performance objectives and the design bases stated in the program
             documents and regulations which are to be covered by the QA program.

4.3.5.1.3  Personnel Qualification and Training (2, 9)

       PURPOSE:   To assure that staff have the necessary training and qualifications to
                    perform in accordance with their responsibilities.


       •      The project has provided for qualified personnel, appropriate equipment,
             suitable environmental conditions for accomplishing planned work,  and
             verification and inspection of the completed work.

       •      The need for "specialty" training is determined (i.e., for those activities where
             unusual skills are required, such as nondestructive testing).

4.3.5.1.4  Procurement of Items and Services (4, 7)


       PURPOSE:   To provide the management controls to manage the work activities of
                    contractors and subcontractors and ensure acceptable quality of the
                    results.  To ensure that the results are consistent with the
                    accomplishment of the performance objectives and the design bases.


       •      The project assures that applicable performance objectives and  the design
             bases, and other requirements necessary  to assure adequate quality are suitably
             included or referenced in documents for procurement of material, equipment,
             and services, whether purchased by the project or by its contractors and
             subcontractors.

       •      The project requires contractors and subcontractors to have quality  assurance
             programs commensurate with the importance of the work assigned to the
             accomplishment of the performance objectives and the design bases.

       •      The project ensures that the contractor and supplier QA programs are reviewed
             for adequacy.

       •      The project describes  the organization responsibilities for (1) procurement
             planning; (2) the preparation, review, approval, and control of procurement

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             documents;  (3) supplier selection; (4) bid evaluations; (5) review and
             concurrence of supplier QA programs prior to the initiation of activities
             affected by  the program.

       •      The project ensures that purchased material, equipment, and services,  whether
             purchased directly or through contractors and subcontractors, conform to
             procurement documents.

       •      The project ensures that documented evidence of review and acceptance of the
             purchased material, equipment, or service is retained and available.

       •      The project assesses the effectiveness of the control of quality by contractors
             and subcontractors.  This  is accomplished at field sites such as -drill rigs.

       •      The involvement of the QA organization is described.

4.3.5.1.5  Documents and Records (6, 17)

       PURPOSE:   To ensure that documents prescribing activities related to the
                    accomplishment of the performance objectives and the design bases are
                    controlled during review, approval, and distribution to ensure that
                    those performing activities have only approved and up-to-date instruc-
                    tions.  To ensure that records important to the accomplishment of
                    performance objectives and the design bases (including the data
                    analysis phase, hearings, permitting and licensing processes) are
                    sufficient to demonstrate  the quality of work performed.  To assure that
                    records will be available should problems related to the performance of
                    the facility occur at a later date.

       •      Controlled documents are identified, out-of-date copies accounted for, and
             changes thereto controlled.

       •      Procedures  established to  assure that documents are available at the location
             where the activity will be performed prior to commencing work.

       •      Are instructions issued for data entry and modification into field notebooks,
             e.g., use of white-out, use of spinal bound notebooks only, etc.

4.3.5.1.6  Computer Hardware and Software (3, 11)

       PURPOSE:  To control the design of computer  codes and machines.

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       •      The project describes measures to assure that applicable performance
             objectives and the design bases are correctly translated into specifications,
             drawings, procedures, and instructions.

       •      The project establishes controls for design interfaces and for coordination
             among participating design organizations.

       •      Provisions have been made for verification and checking the adequacy of the
             design.

       •      Provisions have been made to control the design process.

4.3.5.1.7 Planning (2, 3)

       PURPOSE:   To identify the customer(s), and their needs and expectations, for the
                    results of the work to be performed.  To identify the technical and
                    quality goals that meet the needs and expectations of the customer.   To
                    translate the technical and quality goals into specifications that will
                    produce the desired, result. To consider any cost and schedule
                    constraints within which project activities are required to be performed.
                    To identify acceptance criteria for the result or measures of
                    performance by which the results  will be evaluated and customer
                    satisfaction will be determined.

       •      Procedures for activities to accomplish the technical and administrative
             objectives have been carefully planned and prepared.

       •      The project has written or  scheduled the  writing of the policies, procedures,
             and instructions such that the documented directions are to be in place before
             work starts.

4.3.5.1.8 Implementation of Work Processes (5, 6, 9,  10, 11)

       PURPOSE:   To ensure the use of formal instructions for work activities related to
                    the accomplishment of performance objectives and the  design bases,
                    including the identification of activities that require specially trained
                    personnel,  specialized equipment, or procedures.   To ensure that the
                   following is (are) conducted to determine if an item or service is
                    acceptable, or to satisfy a need for more information:  an operation
                    employed to resolve an uncertainty; a procedure to ascertain

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                    effectiveness, value, proper function, quality, or other characteristic; a
                    procedure to understand a system, subsystem, component, or structure;
                    or a procedure of submitting a statement to such conditions as will lead
                    to its proof or disproof or to its acceptance or rejection.


             Organizational responsibilities are described to assure that data-gathering,
             analysis, and modeling activities important to  the accomplishment of the
             performance objectives and the design bases are conducted via formal
             instructions, procedures, specifications,  and/or drawings.

             Procedures  are established to assure that instructions, procedures,  and
             drawings include quantitative (such as dimensions, tolerances, and operating
             limits) and qualitative  (such as workmanship samples) acceptance criteria for
             determining that important activities have been satisfactorily accomplished

             Procedures  are established to assure that documents  are available at the
             location where the activity will be performed  prior to commencing work.

             "Special" processes, i.e., ones where direct inspection is impossible  or
             disadvantageous, are identified. Criteria are used.

             The project establishes a test program to assure that all testing to demonstrate
             that structures, systems,  and components will  perform satisfactorily in  service
             is identified and performed in accordance with written test procedures, which
             incorporate the requirements and acceptable limits contained in design
             documents.

             The project provides for documenting and evaluating test results to assure that
             test requirements have been satisfied.
4.3.5.1.9 Assessment and Response (1, 2, 3, 18)

       PURPOSE:    To ensure that self-assessments and independent inspections are
                    performed when it is necessary to establish the acceptability of a
                    product, process or  service, either in progress or upon completion.  To
                     ensure that audits, which are pan of the management system's sensors,
                     are effective by being independent, well planned, conducted by trained
                    personnel familiar with the work being audited,  and designed to
                     measure the potential of the activity or process being audited to
                    produce an acceptable product.

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             The independence of the inspection team is assured.  The project has
             established qualification and certification requirements for inspectors.

             The project provides for maintaining control over work performed by
             contractors and suppliers that affects the accomplishment of the performance
             objectives of the regulations and design bases.

             The project assigns an individual to be responsible for the development,
             implementation, and assurance of continued effectiveness of the QA program.
             The individual has organizational freedom to carry out the assignment.

             The project provides for timely measurement  and assessment of the
             effectiveness of the QA program implementation, and are actions to be taken
             to correct deficiencies and prevent their recurrence.

             The project has designed and planned to use "sensors" in the management
             systems to permit "real-time" measurement of the effectiveness of planned
             actions and timely adjustment by management controls to correct for
             anomalies.

             The project provides for independent, multidisciplinary reviews of activities
             affecting quality.

             The audit program now, and always  did, apply to safety-related data activities
             such as core  sampling, etc.  Data-related activities not subject  to audit are
             identified.
4.3.5.1.10 Quality Improvement (15, 16)


       PURPOSE:   To ensure that management systems that comprise the QA program are
                    constantly monitored and that timely measures are taken to correct
                    conditions adverse to quality.  To ensure  that items not conforming to
                    specified requirements are identified and  controlled to prevent
                    inadvertent use.


       •      Project procedures are established for the identification, documentation,
             segregation, review, disposition, and notification to affected organizations of
             nonconforming materials, parts, components, and, as applicable, services
             (including computer codes) if disposition is other than to scrap.

       •      The project establishes measures to assure that conditions adverse to quality,


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              such as failures, malfunctions, deficiencies, deviations, defective material and
              equipment, and nonconformances, are promptly identified and corrected.

       •      The project provides for identification and documentation of significant
              conditions adverse to quality (i.e., a nonconformance or adverse condition
              which, if left uncorrected, could have a serious effect on safety, reliability, or
              performance), the cause of the condition, and the corrective action taken.
              Appropriate levels of management are notified.

4.3.5.2       Part B:  Collection and Evaluation of Environmental Data

4.3.5.2.1 Planning  and Scoping (2, 3)

       PURPOSE:    To define the project/task scope and objectives and the desired action
                     or result from the work.n  To identify the organizations (e. g.,
                     sampling groups and analytical laboratories) that need to participate in
                     the  project and their role in planning, implementation,  and assessment
                     activities.  To identify the environmental data required to achieve the
                     desired action or result.  To identify the QA and QC requirements to
                     establish the quality of the data collected or produced,  including: data
                     quality indicator (e.g., precision, bias) goals, acceptable level of
                     confidence (or statistical uncertainty), and  level of data validation and
                     verification needed.  To identify the documentation needed to
                     adequately describe the quality of the results.   To identify the necessary
                     personnel, their needed skills, and required types of equipment.  To
                     identify the special applicable regulatory requirements  and  other
                     constraints (e.g., time and budget). To identify the conditions under
                     which suspension of work will be necessary.  To determine  the
                     assessment tools needed (e.g., program technical review, peer reviews,
                     surveillance, readiness reviews, and technical audits).  To identify the
                     methods/procedures for storing, retrieving, analyzing,  and  reporting the
                     data produced (based on the intended use of the data).  To identify the
                     possible methods/procedures (including waste minimization objectives)
                     for characterization and disposal of contaminated sample material that
    12 When appropriate, this includes the definition of the precise problem and the associated action to be
taken.  In some cases, it may be necessary to plan and conduct pilot studies (i.e., reconnaissance) to provide
sufficient dada to formulate the scope or objective, of the project.

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                    may be accumulated during the project.

       •      The program objectives that must be met have been determined and listed.

       •      The necessary internal and external interfaces with regulators, legislative
             groups, intervenors, local citizens groups, and appointed technical oversight
             committees been recognized.

4.3.5.2.2  Design of Data Collection Operations (3, 5, 8)

       PURPOSE:   To control the design of tests and sampling patterns to characterize  the
                    geologic setting, to develop models to predict the performance and
                    long-term stability of the site, and to predict the environmental
                    interaction between the site and its surroundings.

       •      In general, the criteria listed under  Computer Hardware and Software in
             section 4.3.5.1.6 apply.

       •      The project describes the plans, procedures, and controls used in data
             collection and analysis leading to the description of the geologic, geotechnical,
             hydrologic, meteorologic, climatologic, and other features of the disposal site
             and vicinity.

4.3.5.2.3  Implementation of Planned Operations  (2, 3, 8, 9,  10,  11,  12, 13, 14)

       PURPOSE:   To  ensure that all materials, pans, samples, and components important
                    to the accomplishment of performance objectives and the design bases
                    are identified and controlled.  To ensure that measurements  that affect
                    the quality of work related to the accomplishment of the performance
                    objectives and the design bases are taken only with instruments,  tools,
                    gauges, or other measuring  devices that are accurate,  controlled,
                    calibrated, and adjusted at predetermined intervals to maintain
                    accuracy within necessary limits.   To ensure control over handling,
                    storage, cleaning, packaging, preservation,  and shipping of items
                    affecting the quality of work related to the accomplishment of the
                    performance objectives and the design bases.  To ensure the
                    identification of the inspection and/or test status of samples, structures,
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                    systems, and components to prevent inadvertent use of items found to be
                    unacceptable for use.


      •      The project establishes a planned program for sampling and testing and ensure
             the precision, accuracy, and repeatability of the analytical data.

      •      The project document the plans, procedures,  results, and verification of
             geotechnical tests.

      •      The project ensures that the mud and other materials used for drilling
             boreholes do not  obscure the objective of the tests being performed.

      •      The project assures the proper calibration of equipment important to assuring
             quality.  It is determined when the next calibration is needed.  Uncalibrated
             equipment is precluded from use.

      •      Measuring and test equipment are traceable 'to the calibration data.

      •      The project prescribes requirements for maintaining chain-of-custody of core
             samples.

      •      The project properly accounts for the special needs of core samples during
             their storage to preclude deterioration, e.g., environmental conditions such as
             temperature and humidity.

      •      The project assures that the status of nonconforming, inoperative,  or
             malfunctioning data gathering, analysis,  and  modeling equipment is
             documented and identified to prevent inadvertent use.

4.3.5.2.4 Assessment  and Response (2,  18)

      PURPOSE:   To ensure that the requirements stated in planning documents  (e.g.,
                    QAPPS, work plans, and sampling plans) are being implemented as
                    prescribed.

      •      In general, the criteria listed under Assessment and Response in section
             4.3.5.1.9 apply.

4.3.5.2.5 Assessment  and Verification of Data Usability (10)

      PURPOSE:   To assure that data shall be assessed, verified, and qualified according


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                   to intended use.

       •      In instances where the project chooses to use existing data (such as existing
             computer codes or data  from existing boreholes), measures have been
             described to validate and/or corroborate the data before its use.

       •      Limitations in the use of data have been stated.

4.4    Summary

This section summarizes various QA programs available for application to an analysis of
WIPP compliance with 40 CFR part 191, Subpart B.  Sections 4.4.1 and 4.4.2 discuss EPA
and NRC requirements, respectively, for the WIPP.  Section 4.4.3 identifies options for
validation or oversight of validation of older data.

4.4.1  EPA QA Requirements

Appendix 4B summarizes EPA QA documents relating to data quality.  EPA regulations and
guidance documents containing substantive EPA QA requirements are identified as (1)
QAMS-005/80, "Interim Guidelines and Specifications for Preparing Quality Assurance
Program Plans," (2) RCRA and UIC No Migration, and (3) Quality Systems Requirements
for Environmental Programs, ANSI/ASQC STANDARD E4-1993 (Draft).
QAMS-005/80 and draft ANSI/ASQC E4 have been adopted for use by DOE headquarters,
Office  of Environmental Restoration and Waste Management, EM-1 (DOE93c).  EPA's
RCRA and  UIC regulations (40 CFR Part 268 and 40 CFR Part 148) are  mandated for use at
DOE/WIPP by law as applicable.

4.4.2  Specifying  NRC QA Requirements for the WIPP

For purposes of this chapter,  NRC requirements are defined as NRC high-level radioactive
waste regulation and applicable guidance documents related to QA.  These documents are:

•      10 CFR Part 60, Subpart G,  quality assurance requirements for disposal of high-level
       radioactive waste in geologic repositories;

•      10 CFR Part 60, Subpart B, which places restrictions on  site characterization
       activities:

       •      Investigations shall limit adverse effects on the long-term performance of the
             geologic disposal system to the  extent practical;

       •      The number of exploratory boreholes and shafts shall be limited to the extent
             practical, consistent with obtaining the information needed;
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      •      To the extent practical, exploratory boreholes and shafts in the geologic
             disposal system operations area shall be located where shafts are planned for
             underground facility construction and operation or where large unexcavated
             pillars are planned; and

      •      Subsurface exploratory drilling, excavation, and hi situ testing before and
             during construction shall be planned and coordinated with geologic disposal
             system operations area design and construction;

•     NUREG-1318,  "Technical Position on Items and Activities in the High-Level Waste
      Geologic Repository Program Subject to QA Requirements" (NRC88b), which
      identifies items important to safety and waste isolation, i.e., items to which the QA
      program would apply;

•     NUREG-0856,  "Final Technical Position on Documentation of Computer Codes for
      High-Level Waste Management" (NRC83);

•     NUREG/CR-4640,  "Handbook of Software Quality Assurance Techniques Applicable
      to the Nuclear Industry" (NRC87);

•     NUREG/BR-0167,  "Software Quality Assurance Program and Guidelines" (NRC93);

•     NUREG-1297,  "Peer Review for High-Level Nuclear Waste Repositories" (NRC88);
      and

•     NUREG-1298,  "Generic Technical Position on Qualification of Existing Data for
      High-Level Nuclear Waste Repositories, Generic Technical Position" (NRC88a).

Of this list,  10 CFR Part 60 Subpart G is essentially the same as NQA-1, a standard already
adopted by DOE/WIPP (DOE93c).  10 CFR Part 60 Subpart B applies to site
characterization planning and activities  prior to construction; the corresponding activities at
DOE/WIPP have already been completed and so would not be affected by these requirements
except as discussed in  section 4.4.3.  Of the remaining NUREG subject matter, all but
NUREG-1298 are addressed in DOE/WIPP QAPPs and QAPjPs.  While there may be
differences between  DOE and NRC requirements, the issues are nonetheless addressed.


The remaining NRC document, NUREG-1298, is discussed in section 4.4.3.


4.4.3 Validation of Older Data and Models


NUREG-1298 provides guidance on acceptable methods to qualify existing data not obtained


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under a formal QA program.  This guidance document could have a significant impact if
DOE/WIPP determines that (a) it relies on such data in a critical area(s), and (b) the data
fails qualification under the requirements of the NUREG. In this instance, new data would
most likely need to be obtained, and the design of the facility and the compliance assessment
models revisited.
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                                 ABBREVIATIONS

ANSI        American National Standards Institute
ASQC        American Society for Quality Control
ASME       American Society of Mechanical Engineers
CCDF       Cumulative Complementary Distribution Factor
MOC        Management and Operating Contractor
MP&R       Management Policies and Requirements
QA          Quality Assurance
QAP         Quality Assurance Procedure, Program, Plan*
QAPD       Quality Assurance Program Description
QAPjP       Quality Assurance Project Plans
QAPP       Quality Assurance Program Plan
QARD       Quality Assurance Requirements and Description
QC          Quality Control
PA          Performance Assessment
PAP         Performance Assessment Procedure
RCRA       Resource Conservation and Recovery Act
SNL         Sandia National Laboratory
UIC         Underground Injection Control
WIPP        Waste Isolation Pilot Plant
WPIO       DOE's WIPP Project Integration Office
WPSO       DOE's WIPP Project Site Office
W-WID      Westinghouse - Waste Isolation Division

"There is a general inconsistency in the use of terms and acronyms among Federal
agencies/departments, State agencies/departments, and private industry.
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                                  4.5 References
ASME89     American Society of Mechanical Engineers, "Quality Assurance Program
             Requirements for Nuclear Facilities," ASME NQA-1-1989 Edition.

ASQC93     American Society for Quality Control, Energy and Environmental Quality
             Division, Environmental Issues Group, "Quality Systems Requirements for
             Environmental Programs," ANSI/ASQC E4-19XX, ASQC Draft Final, Draft
             #27, April 1993.

DOE91       U.S. Department of Energy, "Quality Assurance," DOE Order 5700.6C,
             August 21, 1991.

DOE91a     U.S. Department of Energy, "Quality Management Plan," Office of Waste
             Operations, Office of Waste Management Projects, Waste Isolation Pilot
             Project Division (EM-342), Revision 0, December 1991.

DOE92       U.S. Department of Energy, "Quality Assurance Program Plan for the Waste
             Isolation Pilot Plant Experimental-Waste Characterization Program," Waste
             Isolation Pilot Project, DOE/EM/48063-1, Final Draft, Revision 2.0, October
             1992.

DOE92a     U.S. Department of Energy, "WIPP Project Integration Office Plan for the
             WIPP  Quality Assurance Program," February 1992.

DOE92b     U.S. Department of Energy, "Waste Characterization Program Plan for the
             Waste  Isolation Pilot Plant," DOE/WIPP 89-025, Draft Revision 2.0,
             December 1992.

DOE93       Letter  dated March 31, 1993, to EPA (Michael Shapiro) from DOE (Paul
             Grim), comments on ANPR 58 FR 8029.

DOE93a     Letter  dated July 9, 1993, to EPA (J. William Gunter) from DOE (M. Frei),
             identification of issues.

DOE93b     U.S. Department of Energy, "WIPP Analytical Laboratory Quality Assurance
             Plan,"  Number WP 12-13, Rev. 0, May 1993.

DOE93c     DOE/EPA meeting on DOE/WIPP's QA Program, July 28, 1993.

DOE93d     Letter  dated March 31, 1993, to EPA (M. H. Shapiro) from DOE (P. D.
             Grimm), Attn:  Docket No. A-92-56.
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EPA80       U.S. Environmental Protection Agency, Office of Monitoring Systems and
             Quality Assurance, Office of Research  and Development, "Interim Guidelines
             and'Specifications for Preparing Quality Assurance Program Plans," QAMS-
             005/80, December 1980.

EPA92       U. S. Environmental Protection Agency, Office of Solid Waste, "No-
             Migration Variances to the Hazardous Waste Land Disposal Prohibitions: A
             Guidance Manual for Petitioners," Draft, EPA 530-R-92-023, July 1992.

EPA93       U.S. Environmental Protection Agency, Gary L.  Johnson, Quality Assurance
             Management Staff (MD-75, Research Triangle Park, NC), "Changes to the
             EPA Quality Assurance System for the Collection and Evaluation of
             Environmental Data," EPA/AWMA International Symposium on
             Measurements of Toxic and Related Air Pollutants,  Durham, NC, May 1993.

EPA93a      U.S. Environmental Protection Agency, James Bennetti, "Comments on
             Quality Assurance Program Plan for the Waste Isolation Pilot Plant Waste
             Characterization Program," Office of Radiation and Indoor Air - Las Vegas
             Facility, Field Studies Branch, January 1993.

NRC83      U.S. Nuclear Regulatory  Commission,  S. A. Silling, Office of Nuclear
             Materials Safety and Safeguards,  "Final Technical Position on Documentation
             of Computer Codes for High-Level Waste management," NUREG-0856, June
             1983.

NRC87      U.S. Nuclear Regulatory  Commission/Pacific Northwest Laboratory, J. L.
             Bryant, N. P. Wilburn, "Handbook of  Software Quality Assurance Techniques
             Applicable to the Nuclear Industry," NUREG/CR-4640 (PNL-5784), August
             1987,

NRC88      Altman, W.D., et al.,  "Peer Review for High-Level Nuclear Waste
             Repositories," NUREG-1297, February 1988.

NRC88a     U.S: Nuclear Regulatory  Commission,  W. D. Altman, J. P.  Donnelly, J. E.
             Kennedy, Office of Nuclear Materials Safety and Safeguards, "Qualification of
             Existing Data for High-Level Nuclear Waste Repositories," Generic Technical
             Position, NUREG-1298, February 1988.

NRC88b     U.S. Nuclear Regulatory  Commission,  A. B. Duncan,  S. J. Bilhom, J.  E.
             Kennedy, Office of Nuclear Materials Safety and Safeguards, "Technical
             Position on Items and Activities in the  High-Level Waste Geologic Repository
             Program Subject to Quality Assurance  Requirements,"  NUREG-1318, April
             1988.
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NRC89      Pittiglio., C.L. Jr., "Quality Assurance Guidance for Low-Level Radioactive
            Waste Disposal Facility," NUREG-1293, Final Report, January 1989.

NRC89a     U.S. Nuclear Regulatory Commission, "Review Plan for High-Level Waste
            Repository Quality Assurance Program Descriptions," Revision 2; March
            1989.

NRC93      U.S. Nuclear Regulatory Commission, "Software Quality Assurance Program
            and Guidelines," NUREG/BR-0167, February 1993.

NRC93a     Letter dated March 22, 1993, to EPA (J. W. Gunter) from the U.S. Nuclear
            Regulatory Commission (B. Youngblood), comments on ANPR 58 FR 8029.

SNL90      Sandia National Laboratories, WIPP QA Procedure No. QAP 17-3, "Records
            Inventory and Disposition Schedule," Rev. A, September 1990.

SNL91      Sandia National Laboratories, WIPP QA Procedure No. QAP 16-1, "Trend
            Analysis Program," Rev. B, June 1991.

SNL92      Sandia National Laboratories, WIPP Performance Assessment Department,
            "Preliminary Performance Assessment for the Waste Isolation Pilot Plant,
            December 1992, Volume 2: Technical Basis," SAND92-0700/2, December
            1992.

SNL92a     Sandia National Laboratories, WIPP Performance Assessment Department,
            "Preliminary Performance Assessment for the Waste Isolation Pilot Plant,
            December 1992, Volume 1: Third Comparison with 40CFR191, Subparf B,"
            SAND92-0700/2, March 1993.

SNL92b     Sandia National Laboratories, "Waste Isolation Pilot Plant Quality Assurance
            Program Description," Rev. P, September 1992.

SNL92c     Sandia National Laboratories, WIPP QA Procedure No. QAP 2-2,
            "Qualification and Training Program," Rev. D, September 1992.

SNL92d     Sandia National Laboratories, WIPP QA Procedure No. QAP 2-3,
            "Qualification of SNL Personnel Performing Leak Testing Activities," Rev. A,
            December 1992.

SNL92e     Sandia National Laboratories, WIPP QA Procedure No. QAP 6-1, "Document
            Control Procedure," Rev. C, October 1992.
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SNL92f      Sandia National Laboratories, WIPP QA Procedure No. QAP 17-1, "QA
             Records Requirements," Rev. K, September 1992.

SNL92g      Sandia National Laboratories, WIPP QA Procedure No. QAP 18-1, "QA Audit
             Requirements," Rev. E, September 1992.

SNL93       Sandia National Laboratories, WIPP Procedure No. PAP01, "Definitions for
             and Structure of Performance Assessment Procedures," Rev. 0, March 1993.

SNL93a      Sandia National Laboratories, WIPP Procedure No. PAP02, "Computer
             Software Supporting Performance Assessments of the Waste Isolation Pilot
             Plant," Rev. 0, March 1993.

SNL93b      Sandia National Laboratories, WIPP Procedure No. PAP03, "Parameter
             Selection Quality Assurance Procedures," Rev.  0, March 1993.

SNL93c      Sandia National Laboratories, WIPP Procedure No. PAP04, "Analysis Quality
             Assurance Procedures," Rev.  0, March 1993.

SNL93d      Sandia National Laboratories, WIPP Procedure No. PAP05, "Report Review
             Quality Assurance Procedures," Rev. 0, March 1993.

SNL93e      Sandia National Laboratories, WIPP Procedure No. PAP06, "Use of Expert
             Judgement Panel Quality Assurance Procedures," Rev. 0, March 1993.

SNL93f      Sandia National Laboratories, WIPP QA Procedure No. QAP 19-1, "WIPP
             Computer Software Requirements," Rev. E, May  1993.

SNL93g      Sandia National Laboratories, "SNL WIPP Active Procedures List," April
             1993.
                                       4-43

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APPENDIX 4A  DOE Waste Isolation Pilot Project QA Data Requirements  	4A-1

                         I. Organization and Responsibilities	4A-1

A.  DOE Headquarters	4A-1
      A.I   EM-1, Office of Environmental Restoration and Waste Management .  . . 4A-1
      A.2   EM-30, Office of Waste Operations	4A-1

B.  DOE Field Operations	4A-3
      B.I   WPIO, WIPP Project Integration Office  	4A-3
            B.I.I        WPSO, WTPP Project Site Office	4A-3
            B.I.2        SNL, Sandia National Laboratories	4A-4
      B.2   Albuquerque Field Office (AL)	4A-4

C.  Waste Generators	4A-4

                               n. QA Requirements  	4A-5

D.  DOE WIPP Project QA Documents and Requirements	4A-5
      D.I   DOE HEADQUARTERS	4A-5
            D.I.I        DOE Order 5700.6C (DOE91)  	4A-5
            D.I.2       EM-342 Quality Management Plan (QMP) (DOE91a) .  . . 4A-6
      D.2   DOE Field Operations  	4A-6
            D.2.1        WIPP Project Integration Office Plan for the WIPP
                         Quality Assurance Program  (DOE92a)   	4A-6
            D.2.2       WPIO QA Program Plan for the WIPP Experimental-
                         Waste Characterization Program (DOE92)  	4A-7
            D.2.3       WPIO Waste  Characterization Program Plan for the
                         WIPP (DOE92b)	4A-8
      D.3   SANDIA NATIONAL LABORATORIES  	4A-9
            D.3.1        WIPP QA Program Description (SNL/QAPD)(SNL92b)  . . 4A-9
            D.3.2       Preliminary Performance Assessment for the Waste
                         Isolation Pilot Plant, December 1992, Volume 2:
                         Technical Basis (SNL92)	4A-9
            D.3.3       Preliminary Performance Assessment for the Waste
                         Isolation Pilot Plant, December 1992, Volume 1: Third
                         Comparison with 40CFR191, Subpart B (SNL92a)  .... 4A-10
            D.3.4       WIPP QA Procedure No. QAP 2-2, Qualification and
                         Training Program (SNL92c)	4A-11
            D.3.5       WIPP QA Procedure No. QAP 2-3, Qualification of SNL
                         Personnel Performing Leak  Testing Activities (SNL92d)   4A-11
            D.3.6       WIPP QA Procedure No. QAP 6-1, Document Control
                         Procedure (SNL92e)	4A-11


                                      4A-i

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D.3.7       WIPP QA Procedure No. QAP 16-1, Trend Analysis
            Program (SNL91)	 4A-11
D.3.8       WIPP QA Procedure No. QAP 17-1, QA Records
            Requirements (SNL92f)	4A-12
D.3.9       WIPP QA Procedure No. QAP 17-3, Records Inventory
            and Disposition Schedule (SNL90)	 . 4A-12
D.3.10      WIPP QA Procedure No. QAP 18-1, QA Audit
            Requirements (SNL92g)  	4A-12
D.3.11      WIPP QA Procedure No. QAP 19-1, WIPP Computer
            Software Requirements (SNL93f)	4A-13
D.3.12      WIPP Procedure  No. PAP01, Definitions for and
            Structure of Performance Assessment Procedures
            (SNL93)	4A-13
D.3.13      WIPP Procedure  No. PAP02, Computer Software
            Supporting Performance Assessments of the Waste
            Isolation Pilot Plant (SNL93a)	4A-13
D.3.14      WIPP Procedure  No. PAP03, "Parameter Selection
            Quality Assurance Procedures (SNL93b)	4A-14
D.3.15      WIPP Procedure  No. PAP04, Analysis Quality
            Assurance Procedures (SNL93c) 	„	4A-14
D.3.16      WIPP Procedure  No. PAP05, Report Review Quality
            Assurance Procedures (SNL93d)	4A-14
D.3.17      WIPP Procedure  No. PAP06, Use of Expert Judgement
            Panel Quality Assurance Procedures (SNL93e)  	4A-15
D.3.18      WIPP Active Procedures List (SNL93g)  	4A-15
                         4A-ii

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        APPENDIX 4A DOE Waste Isolation Pilot Project QA Data Requirements

This appendix summarizes the DOE WIPP Project organization and its QA requirements
relating to data quality.  DOE offices and documents containing QA requirements are
identified and summarized in the following sections.  Original document structure and
wording are retained to the extent practical.  The information presented is based on
documents supplied by, and meetings held with, the DOE (DOE91, DOE91a, DOE92,
DOE92a, DOE92b, DOE93, DOE93a, DOE93b,  DOE93c).
                         I. Organization and Responsibilities

A.  DOE Headquarters

A.I   EM-1, Office of Environmental Restoration and Waste Management

The Assistant Secretary, DOE/EM (EM-1) is ultimately responsible for the successful
completion of the WIPP. EM-1 relies on EM-20, the Office of Quality Assurance and
Quality Control, to develop QA programs for all of EM.  EM-1  coordinates all WIPP-related
activities at DOE-HQ and with the Congress, EPA, NRC, NAS, ACNFS, DNFSB, and other
external agencies.  EM-1 has  delegated the day-to-day responsibility for program
management, technical direction,  and oversight to EM-34.  The policies of EM-1  and EM-20
are documented in the EM "Quality Assurance Requirements and Description," (EM-1/20
QARD).  The EM-1/20 QARD is guided by DOE's top-level QA document, DOE Order
5700.6C, "Quality Assurance" (DOE91a).

EM-1/20 is responsible for issuance of the QARD and  implementing quality assurance
procedures (QAPs).  EM-1 performs annual management assessments of the EM HQ QA
Program.  EM-20 performs periodic oversights, independent assessments, and audits of EM
organizations, including EM-30, Office of Waste Management, and EM-34, Office of Waste
Management Projects (DOE93c).
                                       4A-1

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A.2   EM-30, Office of Waste Operations

EM-30, through its Regulatory Compliance Division of the Office of Program Support (EM-
331), provides general guidance to EM-34 through several documents: the EM-30
Management Policies and Requirements document (MP&R), the EM-30 Management Plan
(MP), the EM-30 Quality Assurance Program Description (QAPD), and EM-30 Standard
Operating Project Procedures (SOPPs) currently under development (DOE91a).

EM-30 is responsible for reviewing and approving EM-34's QA Plans and procedures,
performing management assessments, and conducting annual independent assessments of the
QA Program (DOE93c).
EM-34. Office of Waste Management Projects. The EM-34 Director reports to the Assistant
Secretary, DOE/EM for WIPP-related activities. The EM-34 Director reports to the Deputy
Assistant Secretary, Office of Waste Operations (EM-30) for non-WEPP-related project
activities. EM-34 provides day-to-day program management, technical direction, and
oversight using the resources of the WIPP Project Division (EM-342). EM-34 is also
responsible for approving project implementation plans and for assessing the status and
adequacy of the WIPP project implementation (DOE91a).

With respect to QA, EM-34 is responsible for reviewing and approving EM-342's (WIPP
Project Division) Quality Management Plan (QMP) and implementing procedures.
Additionally, EM-34 performs annual management assessments  (DOE93c).
EM-342. WIPP Project Division. The EM-342 Division Director is responsible for
supporting EM-34 through the use of its own resources and those of its contractors).  QA
guidance is prescribed in the EM-342  Quality Management Plan (WIPP QMP) (DOE91a).

With respect to QA, EM-342 reviews  and approves the DOE/WPIO Quality Assurance
Program Plan (QAPP) and implementing procedures.  EM-342 also performs annual
management self-assessments, periodic internal QA Program assessments, and periodic QA
audits of DOE/WPIO, and generally provides oversight of WIPP activities (DOE93c).
                                       4A-2

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B.  DOE Field Operations

B.I   WPIO, WIPP Project Integration Office

WPIO reports to EM-34 and is responsible for the day-to-day implementation of DOE-HQ
policy and overall program guidance from EM-34.  The WPIO coordinates all WIPP-related
activities with EM, the DOE's Albuquerque Field Office (AL), and the WIPP site.  The
WPIO has the direct responsibility for the execution and implementation of all WTPP-related
activities, including integration of the prime contractors (Westinghouse  Waste Isolation
Division and  Sandia National Laboratory) and integration of TRU waste preparation
characterization,  packaging, and transportation.  The WPIO sets forth its QA requirements
through its WPIO Plan for the WIPP QA Program (DOE92a), the QA Program Plan
(QAPP), the Quality Assurance Program Plan for the Waste Isolation Pilot Plant
Experimental-Waste Characterization Program (DOE92), and the Waste Characterization
Program Plan for the Waste Isolation Pilot Plant (DOE92b). WPIO is responsible for
overseeing the design,.construction,  and maintenance of the WIPP facility (DOE92a)
(DOE91a).

Specific to QA, WPIO approves the QA plans and procedures for WPSO, SNL, and Waste
Generator and Transportation activities, and performs independent oversight.  WPIO also
performs readiness reviews of selected WIPP project activities.  For site activities, WPIO
delegates authority to WPSO (DOE92a) (DOE93c).
B.I.I        WPSO, WIPP Project Site Office

The WPSO reports directly to  the WPIO and is responsible for the management of the WIPP
Management and Operating Contractor (MOC).  The WPSO coordinates the MOC activities
and maintains oversight of all  site activities, including quality assurance requirements. The
WPSO sets forth its QA requirements  through its Quality Assurance Program Description
(QAPD) (DOE91a).

WPSO reviews and approves the W-WID QA Program Manual and implementing
procedures.  WPSO also performs surveillance, annual management assessments,  and
periodic audits of WID (DOE93c).
                                        4A-3

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B.I. 1.1  WID. Westinghouse Waste Isolation Division. W-WID reports directly to WPSO
and is responsible for operations at the WEPP test site, including support of experiments.

With respect to QA,  W-WID reviews and approves subcontractor QA plans and procedures,
and performs surveillance, internal and external audits, and annual management assessments
(DOE93c).
B.I.2        SNL, Sandia National Laboratories

SNL reports directly to WPIO and is responsible for the scientific programs and compliance
assessment for WIPP.  SNL provides the necessary data to the address the requirements of
40 CFR part 191 with respect to long term performance (DOE92).

SNL reviews and approves subcontractor QA plans and procedures, and performs
surveillance, internal and external audits, and annual management assessments (DOE93c).
B.2   Albuquerque Field Office (AL)

AL is responsible for various administrative and contractual support functions, including
support of the QA function and ensuring the implementation of DOE orders and policies
(DOE92).
C.  Waste Generators

Characterization of the waste to be used in the bin-scale and alcove tests is in progress at the
Idaho National Engineering Laboratory (INEL) and the Rocky Flats Plant (RFP).  Waste
generators are required to follow the requirements specified in DOE's TRU Waste
Characterization Program Plan to characterize their waste (DOE92).  WPIO establishes the
QA program for this work.
                                       4A-4

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                                n.  QA Requirements

D.  DOE WTPP Project QA Documents and Requirements


Requirements for WTPP QA activities are derived from the documents listed below
(DOE93c).  However, actual requirements are those Listed in the project documents
controlling quality affecting activities (DOE93c).


•     DOE Order 5700.6C, "Quality Assurance"

•     EM Management Policies and Plans

•     National Standards, including ASME NQA-1, "Quality Assurance Program
      Requirements for Nuclear Facilities," and draft ASME/ASQC E4, "Quality Systems
      Requirements for Environmental Programs"

D. 1   DOE HEADQUARTERS


D.I.I        DOE Order 5700.6C (DOE91)


Purpose:  Makes QA requirements mandatory to ensure risks and environmental impacts are
minimized and safety,  reliability and performance are maximized commensurate with the
risks posed by the facility.

Scope: Applies to  work performed by  all DOE elements and M&Os as provided by law and
contract.

Requirements: 1.  Senior management is responsible for mission accomplishment and also
QAP implementation; the QAP shall discuss how the QA criteria will be  satisfied.

2. Personnel shall  be trained and qualified to do assigned work; all important work will be
described in  documents and records kept.

3. Work shall be performed to established standards using approved instructions; equipment
used for data collection shall be calibrated and maintained.

4. Adequacy of designed products shall be verified and validated by others who did not do
the work.
                                        4A-5

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5. Management shall periodically assess the QAP to assure results; independent assessments
shall be conducted to assess quality; persons must be technically qualified and knowledgeable
in the areas assessed.

D.I.2        EM-342 Quality Management Plan (QMP) (DOE91a)

Purpose: Implements higher-level DOE/EM policies and provides requirements for quality
management and overview plans at field and project office levels.

Scope:  Applies to EM-342 and the activities it oversees.

Requirements:  1. Projects must be conducted in accordance with applicable DOE Orders,
and federal,  state, local, ancf tribal regulations.

2. Many requirements  are delegated to the field and project offices, including Criterion 5,
"Work Processes."   Since this criterion seems to include data gathering, it would appear that
the QMP does not explicitly get involved with "quality of data" issues.

D.2    DOE Field Operations

D.2.1        WIPP Project Integration  Office Plan for the WIPP Quality Assurance
             Program  (DOE92a)


Purpose: States WPIO's policies with respect to QA and assigns responsibilities for
implementation of the WPIO QAPP.


Scope:  Requirements "...apply to work performed in support of the WIPP Project by all
DOE elements, including prime contractors and supporting contractors as provided by law
and contract, and as implemented by the DOE WIPP Contracting Officer."


Requirements:  1. The formal QA group is required to be organizationally independent.

2. The WPIO QA&C Branch is required to conduct periodic reviews of program
documentation to assure quality of program data and information.

3. Performance requires personnel training, identification of important items, and proper
handling, storage, and shipping of data.  Maintenance and calibration  are required of data
collection equipment.

4. Design inputs are to be controlled, including verification.
                                        4A-6

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5. Inspection and acceptance testing are required to assure that items will perform as
intended, including completeness and accuracy of data.

D.2.2        WPIO QA Program Plan for the WIPP Experimental-Waste Characterization
             Program (DOE92)


Purpose: Sets forth QA requirements applicable to the characterization of waste to be
disposed of at the WIPP.


Scope:  Applies to the Test Phase of the WIPP project; i.e., excluded are the site
characterization phase and the disposal phase. Applies to all quality-affecting activities.


Requirements:   1.  All activities affecting quality are to be performed using  written and
approved procedures, instructions, or drawings.

2. Adopts EPA's QAMS-005/80 criteria (EPA80) and, where applicable, NQA-1, Elements
2, 3, 5,-8, 9, 10, 11,  12, 13, 14,  16, 17, and 18.

3. QA Objectives require precision, accuracy, representativeness, completeness, and
comparability in accord with NQA-1, Element 3.

4. Sampling procedures require representative samples in accord with NQA-1, Elements 5
and 13 (the latter with respect to handling, storage, cleaning, packaging, shipping, and
preservation of items).

5. Sample custody requires conformance to NQA-1, Elements 8 and 13 (with respect to
identification and control of sample).

6. Calibration procedures and frequency require conformance to NQA-1, Elements 12
and 14.

7. Analytical procedures must conform to NQA-1, Element 9.

8. Data reduction, validation and reporting procedures require conformance to NQA-1,
Element 17, which deals with documenting evidence of compliance.

9. Internal QC checks and frequency procedures require conformance to NQA-1, Elements 9
and 11, which deal with process test control, use of spiked  samples, etc.

10. Performance and system audit frequency procedures require conformance to NQA-1,
Element 18.
                                         4A-7

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11. Preventive maintenance procedures require conformance to NQA-1, Elements 10
and 12.

12. Specific and routine procedures to assess data quality require conformance to NQA-1,
Element 11. "The quality assurance objective for measurement data is to ensure that
characterization data are of known and acceptable quality. Precision, accuracy, and
completeness are measures essential to assessing the quality of the analysis data,  and hence,
to applying the data appropriately in the decisionmaking process."

13. Corrective action procedures require conformance to NQA-1, Element 16.

14. QA reports to management require conformance to NQA-1, Elements 2 and 16.

D.2.3        WPIO Waste Characterization Program Plan for the WIPP (DOE92b)


Purpose:  Describes requirements for waste characterization and makes sure appropriate data
are obtained to support  compliance with 40 CFR part  191 and 40 CFR Section 268.6 and 40
CFR Section 264. Provides contact-handled waste generators  and waste storers with
information needed to develop site-specific characterization implementation plans.


Scope: To support WIPP Test Phase (i.e., the time period during which laboratory, source-
term,  bin-scale, and alcove experiments will be conducted to support disposal phase
decisions) and  define  activities required to characterize waste at the WIPP.  Preparation of
waste for bin-scale and  alcove tests is underway at INEL  and Rocky Flats Plant.


Requirements:  1. With respect to data quality,  WPIO QAPP (DOE92) is cited as the
document where performance requirements and QA objectives governing waste
characterization are stated.

2. Implementation Requirements  of the Program specify  that a waste characterization data
management system is to be in place with the following provisions:   system for
categorization of records; qualified technical review; specified approval system; established
media, forms and formats; controls on reproduction and storage; systematic distribution,
transfer, and reporting;  and, rules for access and security.

3. A  Performance Demonstration Program (PDP)  is required  to ensure compliance with the
QA objectives  defined in the WPIO QAPP. This should include all analyses in the TRU
waste  characterization program that can be realistically tested for accuracy.  The PDP
identifies acceptance criteria to be used in evaluating a facility's performance.  Use of blind
audit samples is required.
                                        4A-8

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4. Training for those functions that require special skills, certifications, or controls are
recommended, but not required.

D.3    SANDIA NATIONAL LABORATORIES

D.3.1        WIPP QA Program Description (SNL/QAPD)(SNL92b)


Purpose:  Assures that the WIPP, even though an R&D facility, carries out its work under a
more restrictive umbrella than other R&D operations.  Thus, the QAPD ensures that
information and data collected for compliance assessment and regulatory compliance is
quality assured.


Scope:  Applies to SNL and SNL sponsored work affecting quality.

Requirements:  1. A quality-affecting activity is defined "... as any activity which will
influence the quality of performance assessment utilized data and conclusions generated by
that activity." Such activities include experiment concept and requirements development,
experiment design and fielding, data collection and reduction, analyses and reporting.

2. Design Control  sets restrictions on design of experiments.

3. Identification  and Control of Items requires that quality-affecting data,  samples, etc., be
identified  and controlled.

4. Test Control cites requirements for logbook  control, including presumably, field
logbooks.

5. Control of Measuring and Test Equipment requires instrument calibration and  validation
of all data taken with instruments found to be uncalibrated.

6. Handling, Storage and Shipping requires specification of controlled environments to
preclude data loss.

7. QA Records requires individual project procedures to specify the QA records  generated
by the activity covered by the procedure.

8. Computer Software requires validation, verification, and changes to software to be
documented.

D.3.2        Preliminary Performance Assessment for the Waste Isolation Pilot Plant,
             December 1992, Volume 2: Technical Basis (SNL92)
                                         4A-9

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Puipose: Describes the technical basis for compliance assessment, including conceptual
model development, probability modeling, and consequence modeling.

Scope:  SNL compliance assessment activities.

Requirements:  1.  A primary data base is needed to contain measured and laboratory data
gathered during regional characterization.

2.  "Because the analyses can be no better than these data, the data base should contain all
data necessary for the compliance  assessment and repository  design, have as little subjective
evaluation as possible, and be quality assured."

D.3.3       Preliminary Performance Assessment for the Waste Isolation Pilot Plant,
             December 1992, Volume 1: Third Comparison with 40CFR191, Subpart B
             (SNL92a)

Purpose: Sets forth the results of  iterative compliance assessments to provide interim
guidance while preparing  for final compliance evaluations.

Scope:  Compliance with  40 CFR  part 191 only, not RCRA.

Requirements/Findings:  1.  The report presents results of preliminary compliance
assessments; it is not a requirements document.

2.  Methods for reducing  uncertainties are listed in Table 3-1; all methods stress QA.

3.  One type of uncertainty  that cannot be completely resolved is the validity of various
conceptual models for predicting disposal system behavior 10,000 years into the future.

4.  QA procedures control compliance assessment analyses in three areas - data, software,
and analysis - and two sub-areas -  elicitation of judgments from expert panels, and
documentation.

5.  QA on data control ensures traceability and documentation of data.

6.  QA on software ensures traceability, retrievability, verification and documentation.

7.  QA for analyses controls traceability, validation, personnel qualifications, data use, and
peer review.

                                        4A-10

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8. QA on documentation ensures traceability on how analyses were performed and how
decisions were reached.

9. The Environmental Evaluation Group (EEC) of the State of New Mexico provides an
independent audit function.

D.3.4        WIPP QA Procedure No. QAP 2-2, Qualification and Training Program
             (SNL92c)


Purpose:  Assures SNL staff working on the WIPP have the necessary training and
qualifications to perform.


Scope: Applies to staff when the WIPP is their primary responsibility.


Requirements:   1. Requires meeting NQA-1 and Supplement 2S-4.

2. Section 8.4 seems to require the drilling coordinator to be trained but not the driller.

D.3.5        WIPP QA Procedure No. QAP 2-3, Qualification of SNL Personnel
             Performing Leak Testing Activities (SNL92d)

Purpose:  Qualifies staff who perform leak testing activities.

Scope: Persons performing NDE.

Requirements:   1. Requirements are many and varied but targeted toward performance of
good NDE.



D.3.6        WIPP QA Procedure No. QAP 6-1, Document Control Procedure (SNL92e)


Purpose:  Prescribes control of documents that affect quality.


Scope: Six document categories are established: QAPD  and QAPs, Test Plans, WEPP
Procedures, Drawings and Engineering Sketches, ES&H SOPs, and Technology
Development Descriptions.


Requirements:   1. Basic requirements are for peer review, approval,  issuance, and change
control.
                                       4 A-11

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D.3.7        WIPP QA Procedure No. QAP 16-1, Trend Analysis Program (SNL91)

Purpose:  Analyze-audit findings and non-conformance reports for trends which could
indicate a breakdown of the A program.

Scope: All quality affecting activities.

Requirements: Cites DOE Order 5700.6B, not 5700.6C.


D.3.8        WIPP QA Procedure No. QAP 17-1, QA Records Requirements (SNL92f)

Purpose:  Describes collection, filing, storage, and maintenance of QA records.

Scope: "Applies to all activities."   Included are site underground facility characteristics,
environmental characteristics, site validation documentation, and records associated with the
fielding of an experiment, such as: Test Plans, Drilling and Coring Logs, Calibration
Records,  Raw Data, Installation Sheets, etc.

Requirements: 1.  References NQA-1 and Supplement 17S-1.


D.3.9        WIPP QA Procedure No. QAP 17-3, Records Inventory and Disposition
             Schedule (SNL90)

Purpose:  Schedules the submittal of QA records to the Central Records Center.

Scope: All QA records.

Requirements: N/A


D.3.10       WIPP QA Procedure No. QAP 18-1, QA Audit Requirements (SNL92g)

Purpose:  Establishes a system of independent checks and balances.


                                       4A-12

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Scope:  Applies to "all" SNL activities.


Requirements: I/ Cites NQA-1 and Supplements 2S-3 and 18S-1.


D.3.11       WIPP QA Procedure No. QAP 19-1, WIPP Computer Software Requirements
             (SNL93f)


Purpose: Documents the development and use of software  to ensure the software
accomplishes what was intended.

Scope:  All SNL software quality-affecting activities.


Requirements: 1.  References NQA-1, Supplement 11S-2,  "Computer Program Testing."
D.3.12       WIPP Procedure No. PAP01, Definitions for and Structure of Performance
             Assessment Procedures (SNL93)


Purpose: Defines terms and organizational responsibilities.


Scope:  Compliance assessment activities.

Requirements:  1.  Validation  - the process of making valid by confirming, corroborating,
substantiating, or supporting, where valid means of good authority, well founded, sound and
to the point, and applicable to the subject or circumstances against which few objections can
be fairly brought.

2. Validation of an applied model  the process of validating through sufficient testing
(subjective) using system-specific observed data that a conceptual model and the
corresponding mathematical and computational models explain a system with sufficient
accuracy (subjective), consistent with the purpose of the model. This is an ongoing process.

3. Verification  of a computational model - the process of verifying that a computational
model appropriately solves and implements the mathematical model.
D.3.13       WIPP Procedure No. PAP02,  Computer Software Supporting Performance
             Assessments of the Waste Isolation Pilot Plant (SNL93a)

                                       4 A-13

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Puipose: Ensures quality of software tools used for compliance assessment.

Scope:  Scope statements in procedure are confusing.

Requirements: 1.  Require, documentation, verification reports,  peer review, and evidence
of traceability and retrievability.


D.3.14       WIPP Procedure No. PAP03, "Parameter Selection Quality Assurance
             Procedures (SNL93b)

Purpose: Ensures the quality of parameters used in compliance assessment by establishing a
framework and assigning specific responsibilities.

Scope:  All parameters related to WIPP compliance assessment.


Requirements: 1.  Requires five  steps for controlling parameter quality: traceability,
retrievability, verification and parameter review, documentation of parameters, and formal
elicitation of expert judgment.


D.3.15       WIPP Procedure No. PAP04, Analysis Quality Assurance Procedures
             (SNL93c)


Purpose: Ensures the quality of engineering analyses used in compliance assessment.


Scope:  Analyses conducted by the SNL compliance assessment department.


Requirements: 1.  Requires six main steps to ensure quality: analysis planning, qualification
of personnel,  data entry,  validation of models, peer review, documentation for traceability.


D.3.16       WIPP Procedure No. PAP05, Report Review Quality Assurance Procedures
             (SNL93d)


Purpose: Ensures adequate review of formal reports produced by the Software, Parameter,
and Analysis QA procedures.
                                       4A-14

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Scope: Applies to quality-affecting reports produced by the SNL compliance assessment
department.


Requirements: 1. Typical report review procedures are included with the addition of using
peer review panels.
D.3.17       WTPP Procedure No. PAP06, Use of Expert Judgement Panel Quality
             Assurance Procedures (SNL93e)

Purpose: Guides and documents the use of Expert Judgment Panels in providing input to
compliance assessment.

Scope:  Applies to all SNL compliance assessment activities requiring expert judgment
panels.

Requirements: 1.  The procedure requires the planning, implementing, reviewing and
documenting of the use of Expert Judgment Panels.
D.3.18       WIPP Active Procedures List (SNL93g)

Purpose:  Provides SNL personnel with an updated list of the latest version of procedures in
effect to preclude the use of outdated versions.

Scope:  Applies to all SNL quality-affecting procedures.

Requirements:  1.  None were stated.
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APPENDIX 4B  EPA QA Data Requirements	4B-1

                  I.  Interim Guidelines and Specifications for Preparing
                     Quality Assurance Project Plans, QAMS-005/80	4B-1

1. Introduction  	4B-1

2. Definition, Purpose, and Scope	4B-1

3. Plan Preparation and Responsibilities	4B-1

4. Plan Review, Approval, and Distribution  	4B-1

5. Plan Content Requirements	4B-1
       5.1    Title Page	4B-1
       5.2    Table of Contents	4B-2
       5.3    Project Description   	4B-2
       5.4    Project Organization and Responsibility	4B-2
       5.5    QA Objectives for Measurement Data in Terms of Precision, Accuracy,
             Completeness, Representativeness, and Comparability	4B-2
       5.6    Sampling Procedures  	'.	4B-2
       5.7    Sample Custody  	4B-3
       5.8    Calibration Procedures and Frequency	4B-4
       5.9    Analytical Procedures	4B-4
       5.10  Data Reduction, Validation and Reporting  	4B-4
       5.11  Internal Quality Control Checks  	4B-4
       5.12  Performance and System Audits  	4B-5
       5.13  Preventive Maintenance  	4B-5
       5.14  Specific Routine Procedures Used to Assess Data Precision, Accuracy
             and Completeness	4B-5
       5.15  Corrective Action	4B-6
       5.16  Quality Assurance Reports to  Management	4B-6
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                          H.  RCRA and UIC No Migration  	4B-7

1. Background   	4B-7
2. Data QA Reqyirements in 40 CFR Section 268.6	4B-7
3. Data QA Requirements in 40 CFR Section 148.21 and How They Compare with
      Those of Section 268.6	4B-8

             ffl. Quality Systems Requirements for Environmental Programs
                           ANSI/ASQC: Standard E4-1993  .	4B-10

1.    General Provisions	4B-10
      1.1    Introduction	4B-10
      1.2    Purpose and Content  	4B-10
      1.3    Scope and Field of Application	4B-10
      1.4    References  	4B-11
      1.5    Definitions  	4B-11
2. Part A:  Management Systems	4B-11
      2.1    Management and Organization  	4B-12
      2.2    Quality System and Description	4B-13
      -2.3    Personnel Qualification and Training   	4B-14
      2.4    Procurement of Items and Services	4B-15
      2.5    Documents and Records	4B-15
      2.6    Computer Hardware, and Software	4B-16
      2.7    Planning	4B-18
      2.8    Implementation of Work Processes	4B-18
      2.9    Assessment and Response  	4B-19
3.    Part B:  Collection and Evaluation of Environmental Data	4B-21
      3.1    Planning and scoping	4B-22
      3.2    Design of Data Collection Operations	4B-23
      3.3    Implementation of Planned Operations	"	4B-25
      3.4    Assessment and Response  	4B-27
      3.5    Assessment and Verification of Data Usability	4B-27
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APPENDIX 4B EPA QA Data Requirements

This appendix summarizes EPA QA documents relating to data quality.  Documents
containing EPA QA requirements are identified and summarized in the following sections.
Original document structure and wording are retained to the extent practical.

                   I. Interim Guidelines and Specifications for Preparing
                     Quality Assurance Project Plans, QAMS-005/80

1.  Introduction

Each EPA office or laboratory generating data has the responsibility to implement minimum
procedures which assure that precision, accuracy, completeness, and representativeness of its
data are known and documented.

2.  Definition, Purpose, and Scope

This EPA document presents guidelines and specifications that describe the 16 essential
elements of a QA Project Plan, covering all environmentally-related measurements, i.e., all
field and laboratory investigations that generate data. A QA Project Plan is a document
written  for each specific project or continuing operation.

3.  Plan Preparation and Responsibilities

These requirements are  not specific to data quality.

4.  Plan Review, Approval, and Distribution

These requirements are  not specific to data quality.

5.  Plan Content Requirements

The  sixteen (16) essential elements described in this section must be considered and
addressed in each QA Project Plan. If a particular element is not relevant to the project
under consideration, a brief explanation of why the element is not relevant should be
included.  EPA-approved reference, equivalent or alternative methods must be used and their"
corresponding Agency-approved guidelines  must be applied wherever they are available and
applicable.

Specific procedures to assess precision  and  accuracy on a routine basis during the project
must be described in each QA Project Plan.
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5.1    Title Page

These requirements are not specific to data quality.

5.2    Table of Contents

These requirements are not specific to data quality.

5.3    Project Description

•      Provide a general description of the project, including the experimental design.
       Where appropriate, include flow diagrams, tables and charts, dates anticipated for
       start and completion, and intended end use of acquired data.

5.4    Project Organization and Responsibility

•      Include a table or chart showing the project organization and line authority.

•      List the key individuals, including the Quality Assurance Officer (QAO), who are
       responsible for ensuring the collection of valid measurement data and the routine
       assessment  of measurement systems for precision and accuracy.

5.5    QA Objectives for Measurement Data in Terms of Precision, Accuracy,
       Completeness, Representativeness, and Comparability

•      For each major measurement parameter, including all pollutant measurement systems,
       list the QA objectives for precision, accuracy  and completeness.

•      All measurements must be made so that results are representative of the media (air,
       water, biota, etc.) and conditions being measured.

•      Unless otherwise specified, all data must be calculated and reported  in units consistent
       with other organizations reporting similar data to allow  comparability of data bases
       among organizations.

•      Data quality objectives for accuracy and precision established for each measurement
       parameter will be based on prior knowledge of the measurement system employed and
       method validation studies using replicates,  spikes,  standards,  calibrations, recovery
       studies, etc, and the requirements of the specific project.
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5.6    Sampling Procedures

•      For each major measurement parameter(s), including all pollutant measurement
       systems, provide a description of the sampling procedures to be used.  Where
       applicable,  include the following:

       •      Description of techniques or guidelines used to select sampling  sites.
       •      Inclusion of specific sampling procedures to be used (by reference in the case
              of standard procedures and  by actual description of the entire procedure in the
              case of nonstandard procedures).
       •      Charts, flow diagrams or tables delineating sampling program operations.
       •      A description of containers, procedures, reagents, etc., used for sample
              collection, preservation, transport,  and storage.
       •      Special conditions for the preparation of sampling equipment and containers to
              avoid  sample contamination (e.e., containers for organics should b e solvent-
              rinsed; containers for trace  metals should be acid-rinsed).
       •      Sample preservation methods and holding times.
       •      Time considerations for shipping samples promptly to the laboratory.
       •      Sample custody or chain-of-custody procedures (to be described later in this
              document).
       •      Forms, notebooks and procedures to be used to record sample history,
              sampling conditions and analyses to be performed.

5.7    Sample Custody

•      Where samples may be needed for legal purposes, "chain-of-custody" procedures, as
       defined by  the EPA Office of Enforcement, will be used.  However, as a minimum,
       the following sample custody procedures will be addressed in the QA Project Plans:

       A.     Field Sampling Operations:

       •      Documentation of procedures for preparation of reagents or supplies which
              become an integral part of the sample (e.g., filters, and absorbing reagents).
       •      Procedures and forms for recording the exact location and specific
              considerations  associated with sample acquisition.
       •      Documentation of specific sample preservation method.
       •      Pre-prepared sample labels  containing all information necessary for effective
              sample tracking.
       •      Standardized field tracking reporting forms to establish sample  custody in the
              field prior to shipment.

       B.     Laboratory .Operations:

       •      Identification of responsible party to act as sample custodian at the laboratory


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             facility authorized to sign for incoming field samples, obtain documents of
             shipment (e.g., bill of lading number or mail receipt), and verify the data
             entered onto the sample custody records.
       •      Provision for a laboratory sample custody log consisting of serially numbered
             standard lab-tracking report sheets.
       •      Specification of laboratory sample custody procedures for sample handling,
             storage and dispersement for analysis.

5.8    Calibration Procedures and Frequency

•      Include calibration procedures and information:

       •      For each major measurement parameter,  including all pollutant measurement
             systems, reference the applicable standard operation procedure (SOP) or
             provide a written description of the calibration procedure(s) to be used.
       •      List the frequency planned for recalibration.
       •      List the calibration standards to be used and their source(s), including
             traceability procedures.

5.9    Analytical Procedures

•      For each measurement parameter, including all pollutant measurement systems,
       reference the applicable  standard operation procedure (SOP) or provide a written
       description of the analytical procedure(s) to be used.

5.10   Data Reduction, Validation and Reporting

•      For each major measurement parameter, including all pollutant measurement systems,
       briefly describe the following:

       •      The data reduction scheme planned on collected data, including all equations
             used to calculate  the concentration or value of the measured parameter and
             reporting units.
       •      The principal criteria that will be used to validate data integrity during
             collection and reporting of data.
       •      The methods used to identify and treat outliers.
       •      The data flow or reporting scheme from  collection of raw data through storage
             of validated concentrations. A flow chart will usually be needed.
       •      Key individuals who will  handle the data in this reporting scheme (if this has
             already been described under project organization and responsibilities,  it need
             not be repeated here).
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5.11   Internal Quality Control Checks

•      Describe and/or reference all specific internal quality control ("internal" refers to both
       laboratory and field activities) methods to be followed. Examples of items to be
       considered include: replicates, spiked samples, split samples, control  charts, blanks,
       internal standards, zero and span gases, quality control samples, surrogate samples,
       calibration standards and devices, and reagent checks.

5.12   Performance and  System Audits

•      Each project plan must describe the internal and external performance and systems
       audits which will  be required to monitor the capability and performance of the total
       measurement system(s).

•      The systems audit consists of evaluation of all  components of the measurement
       systems to determine their proper selection and use.  This audit includes a careful
       evaluation of both field and laboratory  quality control procedures.

•      Systems audits are normally performed prior to or shortly after systems are
       operational;  however, such audits should be performed on a regularly scheduled basis
       during the lifetime of the project or continuing operation.

•      After systems are operational and generating data, performance audits are conducted
       periodically  to determine the accuracy of the total measurement system(s) or
       component parts thereof.

•      The plan should include a schedule for conducting performance audits for each
       measurement parameter, including a  performance  audit for all measurement systems.

•      As part of the performance audit process,  laboratories may be required to participate
       in analysis of performance evaluation samples  related to specific projects.

•      Project plans should also indicate, where applicable, scheduled participation in all
       other inter-laboratory performance evaluation studies.

5.13   Preventive Maintenance

•      The following types of preventive maintenance items should be considered and
       addressed in the QA Project Plan:

       •      A schedule of important preventive maintenance tasks  that must be carried out
              to minimize downtime of the  measurement systems.

       •      A list of any critical spare parts that should be on hand to minimize downtime.


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5.14   Specific Routine Procedures Used to Assess Data Precision, Accuracy and
       Completeness

•      For all environmental monitoring and measurement data, specific procedures to assess
       precision and accuracy on a routine bases on the project must be described in each
       QA Project Plan.

•      For each major measurement parameter, including all pollutant measurement systems,
       the QA Project Plan must describe the routine procedures used to assess the precision,
       accuracy and completeness of the measurement data.

•      These procedures  should include the equations to calculate precision, accuracy and
       completeness, and the methods used to gather data for the precision and accuracy
       calculations.  Examples of these procedures include:

       •      Central tendency and dispersion - arithmetic mean, range, standard deviation,
              relative standard deviation, pooled standard deviation, and geometric mean;
       •      Measures of variability - accuracy, bias, and precision within laboratory and
              between laboratories;
       •      Significance test -  u-test, t-test, F-test, and Chi-square test;
       •      Confidence limits; and
       •      Testing for outliers

5.15   Corrective Action

•      Corrective action procedures must be described for each project which include the
       following elements:

       •      the predetermined  limits for data acceptability beyond which corrective action
              is required,
       •      procedures for corrective action, and
       •      for each measurement system, the individual responsible for initiating the
              corrective action and also the individual responsible for approving the
              correcting action, if necessary.

5.16   Quality Assurance Reports to Management

•      QA Project Plans  should provide a mechanism for periodic reporting to management
       on the performance of measurement systems and data quality.  As a minimum, these
       reports should include:

       •     periodic assessment of  measurement data accuracy, precision and
              completeness,
       •     results of performance  audits,


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       •      results of system audits, and
       •      significant QA problems and recommended solutions.

       The individual(s) responsible for preparing the periodic reports should be identified.

       The final report for each project must include a  separate QA section which
       summarizes data quality information contained in the periodic reports.
                           H.  RCRA and UIC No Migration

1.  Background

The Hazardous and Solid Waste Amendments of 1984 (HSWA), which amended the
Resource Conservation and Recovery Act (RCRA), imposed substantial new requirements on
the land disposal of hazardous waste. HSWA generally prohibits the continued land disposal
of hazardous waste unless certain treatment standards are met.  This prohibition does not
apply, however, if the EPA Administrator makes the determination that the prohibition is not
required in order to protect human health and the environment.  55 FR 47709.

The Administrator may make this determination only if "it has been demonstrated to the
Administrator, to a reasonable degree of certainty, that there will be no migration of
hazardous constituents from the disposal unit or injection zone for as long as the wastes
remain hazardous." 55 FR 47709.

On November 7, 1986, EPA promulgated 40 CFR Section 268.6,  standards for review of
No-Migration Petitions. This regulation, which applies to land disposal units other  than
underground injection wells,  describes the information required in such petitions and estab-
lishes EPA's procedures for approving or denying them.  On July 26, 1988, EPA
promulgated 40 CFR Part 148.  This regulation contains the standards for no-migration
determinations for underground injection wells receiving hazardous waste and describes the
information to be submitted in support of No-Migration Petitions for such wells.

2.  Data QA Requirements in 40 CFR Section 268.6

40 CFR Section 268.6(b)(4) specifically requires a quality assurance and quality control plan
                                         4B-7

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that addresses all aspects of the demonstration of no migration. This plan must be included
as part of the demonstration and is subject to EPA approval.  The demonstration must also
include an analysis of whether and to what extent any aspects of the demonstration contribute
significantly to uncertainty. This analysis must include an evaluation of the consequences of
predictable future events.  Included as examples of "predictable" events are earthquakes,
floods, severe storm events, droughts, or other natural phenomena.

In addition, the demonstration must meet the following criteria, which can be broadly
included within the term QA:

•      All waste and environmental sampling, test, and anal)ils data must be accurate and
       reproducible to the extent that state-of-the-art techniques allow.

•      All  sampling,  testing, and estimation techniques for chemical and physical properties
       of the waste and all environmental parameters must have been approved by  EPA.

•      Simulation models must be calibrated for the specific waste and site conditions, and
       verified for accuracy by comparison  with actual measurements.

•      If an observed condition at the site differs from what was modeled or otherwise
       predicted, EPA must be notified.

A No-Migration Petition submitted pursuant to 40 CFR Section 268.6 must include a
monitoring plan designed to verify compliance with the conditions of any approved petition.
There must be a quality assurance and quality control plan addressing  all aspects of the
monitoring program.   This plan is subject to EPA approval.  Additionally, the following
monitoring program requirements  can be broadly considered as coming within the term QA.

•      All sampling,  testing, and analytical methods must have been approved by EPA and
       must provide data that are accurate and reproducible.13

•      All estimation and monitoring techniques must be approved by EPA.

3.     Data QA Requirements in 40 CFR Section 148.21 and How They Compare with
       Those of Section 268.6

Similar to 40 CFR Section 268.6, 40 CFR Section 148.21 requires a quality assurance and
   13 40 CFR ง 268.6(c)(5)(i), provides that "[a}ll sampling, testing, and analytical data must be approved by the
Administrator and must provide data that is [sic] accurate and reproducible."

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quality control plan that addresses all aspects of the demonstration.  This plan must be
included as part of the demonstration and is subject to EPA approval. In addition, the
demonstration must also include an  analysis of whether and to what extent any aspects of the
demonstration contribute significantly to uncertainty.


Unlike 40 CFR Section 268.6,  40 CFR Section 148.21 specifically requires the petitioner to
conduct a sensitivity analysis to determine "the  effect that significant uncertainty may
contribute to the demonstration." Also 40 CFR Section 148.21 requires that "[t]he
demonstration shall then be based on conservative assumptions identified in the  analysis." 40
CFR ง 148.21.


Other requirements found in the UIC regulations are similar to, but slightly different than,
those in the RCRA Land Disposal Restrictions.


•      "Waste analysis and any new testing performed by the petitioner" must be accurate
       and reproducible.  Testing must be performed in accordance with quality assurance
       standards.  In contrast, 40 CFR Section  268.6 refers to "[a]ll waste and  environmental
       sampling, test,  and analysis  data"  and in addition requires that it  be accurate and
       reproducible to the extent that state-of-the-art techniques allow.  Although 40 CFR
       Section 268.6 does not specifically require these activities to be conducted in
       accordance with quality assurance standards, that can be reasonably inferred.

 •     "Verified and validated" "predictive models"  must be "appropriate for the specific
       site, waste streams, and injection  conditions ..., and shall be calibrated for existing
       sites where sufficient data are available  ...."  These requirements are somewhat
       different from those imposed by 40  CFR Section 268.6. 40 CFR Section 268.6
       requires that all "simulation  models" be  "calibrated for the specific waste and site
       conditions, and verified for accuracy with actual measurements ...."

•      Estimation techniques must be appropriate and EPA certified test protocols must be
       used where available and appropriate. 40 CFR Section 268.6 requires EPA approval
       of all sampling, testing, and estimation techniques.

•      In addition to the requirement imposed by 40 CFR Section  148.21 that conservative
       assumptions identified in the sensitivity analysis be the basis for the demonstration, 40
       CFR Section 148.21 requires that whenever estimated values or values taken from the
       literature are used in lieu  of site-specific measurements, the values used must be
       reasonably conservative.  There is no comparable provision in 40 CFR Section 268.6.

•      If a petitioner is attempting to show that waste will be no longer hazardous by the
       time they migrate  from  the injection zone, results of laboratory tests verifying the

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      waste transformation must be included with the petition.

•     The monitoring plan referred to in 40 CFR Part 148 appears to be simply a procedure
      that may be used V enhance confidence in one or more aspects of the demonstration"
      rather than a mandatory portion of the demonstration, as it is in 40 CFR Section
      268.6.

             ffl.  Quality Systems Requirements for Environmental Programs
                            ANSI/ASQC: Standard E4-1993

ANSI/AS QC E4 describes the minimum set of quality management elements required to
conduct programs involving (1) environmental data collection and evaluation, and (2)
environmental technology design, construction, and operation. In addition, the elements also
contain nonmandatory supplemental guidance that may be used to augment the basic
requirements. For the purposes of this chapter,  only requirements related to data quality are
considered.  Original document structure
and wording is retained to the extent practical.

1.     General Provisions

1.1   Introduction

These requirements are not specific to data quality.

1.2   Purpose and Content

ANSI/ASQC E4 describes the minimum set of quality management elements required to
conduct programs involving environmental data collection and evaluation, and environmental
technology design, construction,  and operation.

1.3   Scope and Field of Application

1.3.1 Scope

This Standard provides the minimum criteria for Quality Systems for environmental
programs,  and their associated management systems.
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1.3.2  Field of Application

Part A: Management Systems, contains the quality management elements that are applicable
to common or routine functions and activities necessary to support all types of environmental
programs.

Part B: Collection and Evaluation of Environmental Data, contains  the quality management
elements that apply to project-specific environmental activities involving the generation,
collection, analysis, evaluation, and reporting of environmental data.

Part C: Design, Construction, and Operation of Environmental Technology, contains the
quality management elements that apply to systems, facilities, processes, or methods used for
pollution prevention, pollution control, waste treatment, waste remediation, and waste
packaging and storage; and research demonstration projects where new environmental
technology is demonstrated.

1.4    References

Not applicable.

1.5    Definitions

For this standard,  the definitions given in  other national consensus standards14 and in
Appendix 4A apply. Where similar or duplicate definitions occur, the specific definition
given in this Standard for environmental programs has precedence.  This Standard uses the
accepted definitions of shall, must, should, and may which are repeated here (and in
Appendix 4A) to ensure clarity.

       •      shall, must          when  the element is required
       •      should               when  the element is recommended
       •      may                when  the element is optional or discretionary
    14These standards include, but are not limited to, ANSI/ASQC A3, ANSI/ASQC: Q.90 series, and ASME
NQA-1 (1989).

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2. Part A:  Management Systems


2.0    General


Part A defines the framework containing the common quality management functions that
enable project-specific operations to be planned, implemented, and assessed.  These elements
must be used in conjunction with the other parts of this Standard to formulate a complete
quality system.  Many of the elements contained in Part A reflect requirements found in
other consensus standards15


2.1    Management and Organization


2.1.1  Basic Requirements


Management shall:


•      establish and implement a quality policy to ensure that environmental programs
       produce the type and quality of results needed and expected;

•      formally define the relevant organizations, functional responsibilities, levels of
       accountability and authority, and lines of communication in the quality system;

•      identify the customers (both internal and external) for the work to be performed and
       the suppliers of items or services;

•      identify the needs and expectations of the customer for the items or services to be
       provided and define work objectives that will satisfy the customer's needs;

•      when necessary, negotiate acceptable measures of quality  and  success when
       constraints of time, costs,  or other problems affect the supplier's capability to fully
       satisfy the customer's needs and  expectations'

•      ensure that applicable elements of this Standard are understood and are implemented
       in environmental programs, under their responsibility;

•      provide adequate resources and assign sufficient authority and independence to line
    15The elements of Part A are intended to be substantively equivalent to many requirements found in other
consensus standards including ASME NQA-1 (1989) and the ANSI/ASQC Q90 series  (or ISO 9000 series).
Programs developed under other recognized standards  should be reviewed to ensure equivalence  with the
requirements of E4.  It is not the intent of this standard to require a separate, stand-alone Quality System for
environmental programs.  The requirements of this standard should be integrated with wider-scope programs when
they already exist.
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       management and to staff to enable them to plan, implement, assess, and improve the
       organization's quality system effectively;

•      stop unsafe work and work of inadequate quality, or delegate the authority to do so to
       others;

•      regularly assess and document the adequacy of the quality system;

•      define the objectives of the assessment process and determine the measures for
       ensuring that the quality system has been established, documented, and implemented
       effectively; and,

•      determine what response actions are required as a result of independent assessments
       or self-assessments, and implement such  actions in a timely manner.

2.1.2  Non-mandatory Supplement

Not applicable.

2.2    Quality System and Description

2.2.1  Basic Requirements

 A quality system shall be planned, established,  documented, implemented, and assessed as
an integral part of a management  system for planning, implementing, and assessing
environmental programs.  The quality system shall:

•      include the organizational  structure, policies and procedures, responsibilities,
       authorities, resources, requirements documents, and guidance documents necessary for
       implementing the quality management process;

•      include provisions to ensure that the products  or results of the environmental
       programs are of the type and quality needed and expected;

•      establish management elements of the quality system before the initiation of applicable
       environmental projects and activities;

•      be described in a quality management plan document(s) or quality manual(s) that have
       been reviewed and approved for implementation as policy or a directive authorized by
       management; and,
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•      be reviewed and updated at regular intervals, (at least annually) to reflect physical
       changes in the organization as well as changes in policy.

The quality systern description shall:

•      define when and how controls are to be applied to specific technical or project efforts
       and outline how these efforts are planned, implemented, and assessed;

•      address all applicable parts of this Standard;

•      identify in general terms those items, programs,  or activities to which it applies; and,

•      identify and document activities  which directly or indirectly affect quality including
       general and specific responsibilities for management and staff, responsibilities and
       authorities for technical activities,  and all necessary interfaces.

2.2.2  Non-mandatory Supplement


Not applicable.


2.3    Personnel Qualification and Training


2.3.1  Basic Requirements


•      Personnel performing work shall be trained and qualified based on project-specific
       requirements prior to the start of the work or activity.

•      The need to require formal qualification or certification of personnel performing
       certain specialized activities shall be evaluated and implemented where necessary.

•      Appropriate technical and management training shall be performed and documented.

•      When job requirements change,  the need for retraining to ensure continued
       satisfactory job proficiency shall be evaluated.

•      Objective  evidence of personnel  job proficiency shall be documented and maintained
       for the duration of the project or activity affected, or longer if required by statute or
       organization policy.

•      Resources for required training shall be provided.
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2.3.2  Non-mandatory Supplement

Not applicable.


2.4    Procurement of Items and Services

2.4.1  Basic Requirements

•      The procurement of purchased items and services that directly affect the quality of
       environmental programs shall be planned and controlled to ensure that the quality of
       the items and services is known, documented, and meets the technical requirements
       and acceptance criteria of the customer.

•      Procurement documents shall contain information clearly describing the item or
       service needed and the associated technical and quality requirements.

•      The procurement documents shall specify the quality system elements of this Standard
       for which the supplier is responsible and how the supplier's conformance to the
       customer's requirements will be verified.

•      Procurement documents shall be reviewed for accuracy and completeness by qualified
       personnel prior to release.

•      Changes to procurement documents shall receive the same level of review and
       approval as the original documents.

•      Appropriate measures shall be established to ensure  that the procured items and
       services satisfy all stated requirements and specifications.

•      Each supplier shall have a demonstrated capability to furnish items and services that
       meet all requirements specified in the procurement documents.

2.4.2  Non-Mandatory Supplement


Not applicable.
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2.5    Documents and Records


2.5.1  Basic Requirements


•      Procedures shall be established, controlled, and maintained for identifying, preparing,
       reviewing, approving, revising, collecting, indexing, filing, storing,  maintaining,
       retrieving, distributing, and disposing of pertinent quality documentation and records;
       such procedures shall be applicable to all forms of documents and records, including
       print and electronic media.

•      Documents requiring control shall be identified.

•      Documents, including revisions, shall be reviewed by qualified personnel for
       conformance with technical requirements and quality system requirements and
       approved for release by authorized personnel.

•      Documents used to perform work (e.g., technical manuals and operating procedures)
       shall be identified and kept current for use by personnel performing  the work.

•      Measures shall be taken to ensure that users understand the documents to be used.

•      Obsolete or superseded documents shall be identified and measures shall be taken to
       prevent their use, including removal from the  work place and from the possession of
       users when practical.

•      Sufficient records shall be specified, prepared, reviewed,  authenticated, and
       maintained to reflect the achievement of the required quality for completed work
       and/or  to fulfill any statutory requirement.

•      The maintenance of records shall include provisions for retention, protection,
       preservation, traceability, and retrievability.

•      Where  evidentiary records are  involved, the maintenance of records  shall also include
       establishing and implementing appropriate chain-of-custody and confidentiality
       procedures for the affected records.

•      Retention times for records  shall be determined based on contractual and statutory
       requirements, or, if none are stated, as specified by management.

•      While in storage, records shall be protected from damage, loss, and deterioration.
                                         4B-16

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2.5.2  Non-mandatory Supplement


Not applicable.


2.6    Computer Hardware, and Software


Computer software and computer hardware/software configurations covered by this Standard
include, but are not limited to, experimental design, design analysis, modeling of environ-
mental processes  and conditions, operation or process control of environmental technology
systems (including automated data acquisition and laboratory instrumentation) and data bases
containing environmental data.


2.6.1  Basic Requirements


•      Computer software  and computer hardware/software configurations16 used in
       environmental programs shall be installed, tested, used,  maintained, controlled, and
       documented to meet the requirements of the user and shall conform to .this Standard
       and all applicable consensus standards17  and/or data management criteria.

•      Computer'hardware/software configurations  shall be tested prior to actual use and the
       results shall be  documented and maintained.

•      Computer hardware/software configurations  integral to measurement and testing
       equipment (M&TE) that are calibrated for a specific purpose do not require  further
       testing unless:

       •      the scope of the software usage changes,  or
       •      modifications are made to the hardware/software configuration.

•      Changes to hardware/software configurations shall he assessed to determine  the
       impact of  the change on the technical and quality objectives of the environmental
       program supported.  If any of the components are  changed or modified, a new
       configuration results and must be re-documented and re-tested.
     Computer hardware/software configuration used in this Standard refers to the combination of computer
program software version, operating software version, and model of computer hardware.

    17National consensus standards pertaining to computer software may include, but are not limited to: ANSI/IEEE
Standard 730-1989, "IEEE Standard for Software Quality Assurance Plans," and ASME NQA-2, Part 2.7, "Quality
Assurance Requirements of Computer Software for Nuclear Facility Applications."

                                         4B-17

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2.6.2  Non-mandatory Supplement


Not applicable.


2.7    Planning


2.7.1  Basic Requirements


•      A systematic planning process shall be established, implemented, controlled, and
       documented as necessary to:

       •      identify the customer(s), and their needs and expectations, for the results of
              the work to be performed,
       •      identify the technical and quality goals that meet the needs and expectations of
              the customer,
       •      translate the technical and quality goals into specifications that will produce the
              desired result,
       •      consider any cost and schedule constraints within which project activities are
              required to be performed, and
       •      identity acceptance criteria for the result or measures of performance by which
              the results will be evaluated and customer satisfaction will be determined,

•      All planning documentation shall be reviewed and approved  for implementation by
       authorized personnel before work commences; such documentation includes but s not
       limited to work plans, schedules, and QAPPs.

2.7.2  Non-mandatory Supplement


Not applicable.


2.8    Implementation of Work Processes


2.8.1  Basic Requirements


•      Work shall be performed according to approved planning and technical documents and
       according to the prescribed  sequence defined during planning when appropriate and
       stated.

•      Implementation of work shall be accomplished with a level of management oversight
       and inspection commensurate with the importance of the particular project and the


                                         4B-18

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       intended use of the project results.

•      Procedures18 shall be developed, documented, and implemented for appropriate
       routine, standardized, special, or critical operations.

•      Procedures shall be written in a format that can be readily comprehended by the user
       and shall contain sufficient detail and clarity to ensure that results are achieved
       effectively.

•      The following shall be addressed at a minimum:

       •      identification of operations  needing procedures;
       •      preparation of procedures, including form, content, and applicability; and,
       •      review and approval of procedures.

•      Procedures that specify technical requirements shall be reviewed for adequacy and
       approved by technically qualified personnel before use.

•      Implementation of work processes  shall include the routine measurement of
       performance against established technical and quality  specifications.

•      The work process shall be monitored to ensure continued satisfactory performance.

•      The independence of personnel monitoring the work performance shall be
       commensurate with the nature and importance of the  activity,

2.8.2  Non-mandatory Supplement


Not applicable.


2.9    Assessment and Response


2.9.1  Basic Requirements


•      Assessments of environmental programs shall be  planned, scheduled and periodically
       conducted, and their results evaluated to measure the effectiveness of the implemented
       quality system.

•      Both independent and self-assessments shall be performed.


•      Management shall determine during planning the type of assessment activity
    18In the context of this standard, work procedures may include formal Standard Operating Procedures (SOPs),
safety procedures, and computer operating protocols, which may be applied to a specific work activity.

                                          4B-19

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appropriate for a particular project and the assessment tool to be used.

Assessments shall include an evaluation to determine and verify whether technical
requirements, not just procedural compliance, are being implemented effectively.

Assessments shall be performed according to approved written procedures, based on
careful planning of the scope of the assessment and the information needed.

Assessment results shall be documented, reported to, and reviewed by management.

Personnel conducting assessments shall be qualified in regard to technical or
management skills to perform the assigned assessment based  on project-specific
requirements and the type of assessment being conducted.

The responsibilities and authorities of personnel conducting assessments shall be
defined clearly  and documented, particularly in regard to authority to suspend or stop
work in progress upon detection and identification of an immediate adverse condition
affecting the quality of results or the health and safety of personnel.

Assessment personnel shall have sufficient authority, access to programs and
managers, and organizational freedom to:

•      identify  and document problems that affect quality;
•      identify  and cite noteworthy practices that may be shared with others to im-
       prove the quality of their operations and products;
•      propose recommendations (if requested) for resolving  problems that affect
       quality;
•      independently confirm implementation and effectiveness of solutions; and
•      provide  documented assurance (if requested) to line management that, when
       problems are identified, further work performed is monitored carefully until
       the problems are suitably resolved.

Responses to adverse conclusions from the findings and recommendations of
assessments shall be made in a timely manner.

Conditions needing corrective action shall be identified and the appropriate response
made promptly.

Follow-up action shall be taken and documented to confirm the implementation and
effectiveness of the response action.
                                  4B-20

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2.9.2  Non-mandatory Supplement


Not applicable.


2.10   Quality Improvement


2.10.1 Basic Requirements


•      A quality improvement process shall be established and implemented to continuously
       develop and improve the quality system.

•      Procedures shall be established and implemented to prevent as well as detect and
       correct problems that adversely affect quality during  all phases of teclinical and
       management activities.

•      When problems are found to be significant, the relationship between cause and effect
       and the root causes shall be determined.

•      Root causes should be determined before preventive measures are planned and
       implemented.

•      Appropriate actions shall be planned, documented, and implemented in response to
       findings.

2.10.2 Non-mandatory Supplement


Not applicable.



3.     Part B:  Collection and Evaluation of Environmental Data


3.0    General


Part B contains the additional quality system elements needed to plan, implement, and assess
environmental data operations, including the collection, handling, analysis, and evaluation of
environment-related data.  The Part B elements must be used in conjunction with Part- A in
order to provide an adequate quality system for collecting and evaluating environmental data.
                                         4B-21

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3.1    Planning and scoping


3.1.1  Basic Requirements

•      All work involving the generation, acquisition, and use of environmental data shall he
       planned and documented.

•      The type and quality of environmental data needed for their intended use shall be
       identified and documented using a systematic planning process19.

•      The project-specific planning must involve the key users and customers of the data as
       well as the technical staff responsible for ol lining, analyzing, and evaluating the
       data.

•      Results of planning activities shall be subject to review20 for conformance to
       technical and quality expectations.

•      Project planning shall  be coordinated among participating organizations and shall
       include, as applicable, the;

       •       definition of project/task scope and objectives and the desired action or result
               from the work21;
       •       identification of organizations (e.g., sampling groups and  analytical laborato-
               ries) that need  to participate in the project and their role in planning,
               implementation, and assessment activities;
       •       identification of the environmental data required to achieve the desired action
               or result;
       •       identification of QA and QC requirements to establish the quality of the data
               collected or produced, including:
               •      data quality indicator (e.g., precision, bias) goals,
               •      acceptable level of confidence (or statistical uncertainty),  and
    19Systematic planning may be accomplished through several demonstrated techniques including the Data Quality
Objectives process and the observational method.


    20Reviews of project-specific planning may include reviews by independent technical experts, as well as project
management and regulators, to ensure compliance with technical objectives.


    21When appropriate, this includes the definition of the precise problem and the associated action to be taken.
In some cases, it may be necessary to plan and conduct pilot studies (i.e., reconnaissance) to provide sufficient data
to formulate the scope or objective of the project.

                                            4B-22

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              •      level of data validation and verification needed;
       •      identification of the documentation needed to adequately describe the quality of
              the results;
       •      identification of necessary personnel, their needed skills, and required types of
              equipment;
       •      identification of special applicable regulatory  requirements and other
              constraints (e.g., time and budget);
       •      identification of conditions under which suspension of work will be necessary;
       •      determination of assessment tools needed  (e.g., program technical review, peer
              reviews, surveillance, readiness reviews, and technical audits);
       •      identification of methods/procedures for storing, retrieving, analyzing, and
              reporting the data produced  (based on the intended use of the data); and
       •      identification of possible methods/procedures (including waste minimization
              objectives) for characterization and  disposal of contaminated sample material
              that may be accumulated during the project.


3.1.2  Non-mandatory Supplement


Not applicable.


3.2    Design of Data Collection Operations


3.2.1  Basic Requirements


•      The design of data collection operations shall be  defined, controlled to the extent
       required, verified, and documented.

•      The design process shall identify all relevant activities pertaining to environmental
       data operations, establish performance specifications, and identify appropriate
       controls.

•      The design process shall include (but not be limited to) consideration and development
       of detailed specifications for22:

       •      assessments needed during the project (e.g., surveillance, audits, performance
              evaluations);
       •      data reporting requirements;
       •      data validation  and verification methods;
       •      integrating cost or schedule  constraints into design;
       •      protection of health and safety of workers and of the public;
       •      readiness reviews prior to data collection;
       •      requirements for calibration and performance  evaluation samples for analytical
              methods used;
       •      requirements for data (and data base) security, archival, and retention;
    22The elements in this list are in random order.

                                          4B-23

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       •      requirements for field and laboratory QA/QC activities;
              requirements and qualifications for sampling and analysis personnel;
       •      sample handling, packaging, shipping,  and custody requirements;
       •      sample types, numbers, and quantities, and sampling location requirements;
       •      selection of analytical methods and their quality performance expectations;
       •      selection of analytical facility (or laboratory);
       •      selection of field sampling or testing methodology, including specific sampling
              or field analytical instrumentation requirements and other analytical testing
              requirements23;
       •      techniques for assessing limitations on data use; and
       •      disposal or minimization procedures for waste produced during sampling and
              analysis operations.

•      Key variables that determine or directly affect the quality  of results shall be identified
       and controlled as appropriate according to the specifications determined during
       design.

•      The environmental data collection design process shall ensure that data are traceable
       to the procedures (including revisions) used to produce the data and to the personnel
       generating or collecting the data.

•      Data transfer, reduction, verification, and validation requirements  must be determined
       and documented.

•      Data interpretation and analysis needs, such as the use of  specific  statistical methods,
       shall be determined and specified in the design.

•      Reports to management regarding the status  of work,  interim results of work, and
       results of assessment activities shall be identified and documented.

•      Any restrictions on the use of any interim results shall be  identified and stated with
       the data in a  manner that clearly defines the nature of the  restriction and the specific
       data to which it applies.

•      If the data are stored in magnetic media, the restrictions shall be encoded with the
       data  as well as reported in any  accompanying documentation, to the extent
       practicable.

•      The results of the environmental data collection design process shall be documented in
    T\
     Other analytical testing includes, but is not limited to, geophysical tests, locational data determinations, and
treatability tests.
                                         4B-24

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       a QA project plan (QAPP) and other planning document(s) according to the
       requirements of the quality system and as found necessary or appropriate by line
       management.

•      The QAPP and/or other planning documents shall be reviewed24 and approved by
       designated persons who, together, are technically capable of evaluating all aspects of
       the project.

•      The organization's quality system must identify who, in addition to project line
       management, must review and approve the project-specific QAPP and explain the
       process by which this review is conducted.

•      Changes to data collection designs or procedures, including field changes, shall be
       subject to the same review and approval protocols as the original documents.

3.2.2  Non-mandatory Supplement

Not applicable.

3.3    Implementation of Planned Operations

3.3.1  Basic Requirements


•      Environmental data operations shall be implemented according to the approved
       applicable planning documents and by qualified personnel.

•      Deviations shall be documented and  reported to  management.

•      The impact and significance of the deviation on  planned operations shall be
       determined, and appropriate adjustments to  such operations shall be made as needed.

•      Approved changes to planning documents and operating guides and  manuals shall be
       made and distributed to project personnel to replace previous versions of the
       documents.

•      Data collected during implementation shall be traceable to the planning documents
       actually used and to the personnel collecting the data.
    ^Reviews may include a peer review of the final survey design and a QA review to determine conformance
to quality objectives as stated in the quality management plan or quality manual.

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Only qualified and accepted services and items shall be used in the environmental data
operations. Acceptance shall be identified on the items themselves and/or in
documents traceable to the items.

Inspections; and acceptance testing of sampling, measurement, and analytical
instrumentation (or ">ther measurement systems) and their components shall be
performed as required to confirm the intended use of the items as specified by the
design.

When acceptance  criteria are not met, deficiencies shall be resolved and re-inspection
performed as necessary prior to their use.

Tools, gauges, instruments, and other sampling, measuring, and testing equipment
used for activities affecting quality shall be controlled as required and, at specified
intervals,  calibrated to maintain accuracy within specified limits.

Equipment found  to be unsuitable for its prescribed use shall be identified in a
conspicuous manner.

The validity of any measurements and tests performed with out-of-calibration
equipment shall be evaluated, and such measurements and tests shall be repeated as
required.

The basis  for equipment calibration shall be documented.

Documentation of calibration shall be maintained and shall be traceable to the
equipment,

Periodic preventive and corrective maintenance of measurement and testing equipment
shall be performed to ensure availability and satisfactory performance of the systems.

All equipment subject to maintenance or repair shall be re-calibrated as necessary
before the equipment is used.

Handling,  storage, cleaning, packaging, shipping, and preservation of field and
laboratory samples shall be performed according to required specifications, protocols,
or procedures to prevent damage, loss, deterioration, artifacts, or interference.

Sample  chain-of-custody shall be tracked and documented.

Data or information management, including transmittal, storage, validation,
assessment, processing, and retrieval, shall be performed in accordance with the
approved instructions, methods, and procedures.
                                  4B-26

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3.3.2  Non-mandatory Supplement

Not applicable.


3.4    Assessment and Response


3.4.1  Basic Requirements


•      Activities performed during environmental data operations that affect the quality of
       the data shall be assessed regularly and the findings reported to management to ensure
       that the requirements stated in planning documents  (e.g., QAPPS, work plans, and
       sampling plans) are being implemented as prescribed.

•      Appropriate corrective actions shall be taken and their adequacy verified and
       documented in response to the findings of the assessments.

•      Data obtained previously from a method or instrument found to be nonconforming to
       specifications shall be evaluated to determine the impact of the nonconformance on
       the quality of the data.  The impact and the appropriate action taken shall be
       documented.

3.5    Assessment and Verification of Data Usability


3.5.1  Basic Requirements

•      Data obtained from environmental data operations shall be assessed, verified, and
       qualified according to intended use.

•      Any  limitations on data  use shall be expressed (quantitatively to  the extent practicable)
       and shall be documented in any reporting of the data, either in print or electronically.

•      Any  data obtained  from sources that did not use a quality system equivalent to this
       Standard shall be assessed according to approved and documented procedures.

•      Project reports containing data,  or reporting the results of environmental data
       operations,  shall be reviewed independently (i.e., by others than those who produced
       the data or  the reports) to confirm that the data or results are presented  correctly.
       These reports shall be approved by management prior to release, publication, or
       distribution.

3.5.2  Non-mandatory Supplement


Not applicable.
                                         4B-27

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APPENDIX 4C  NRC QA Requirements Pertaining to Data"

This appendix summarizes NRC QA documents relating to data quality.  The primary NRC
source for QA requirements for high-level radioactive waste repositories is 10 CFR Part 60,
Subpart G. The text references other NRC guidance documents as appropriate.

NRC regulations in  10 CFR Part 60, Subpart G require the high-level waste disposal system
program to be performed under a quality assurance program which meets the nuclear power
plant QA requirements in 10 CFR 50 Appendix B, "as applicable."  Specific QA criteria
which the NRC staff used to review the DOE QA program are provided in "Review Plan for
High-Level Waste Repository Quality Assurance Program Descriptions"  (NRC89a). It
provides NRC's position on the meaning of "as applicable" in the use of Appendix 4B in the
disposal system program.

The NRC Review Plan endorses NQA-1, "Quality Assurance Program Requirements for
Nuclear Facilities, 1986;" incorporates  lessons learned from the Ford Study (NUREG-1055),
such as  the use of technical audits and readiness reviews; where necessary,'better accounts
for differences between power reactor projects and the high-level nuclear waste disposal
system program; and references the staffs Technical Positions.

Each section of this Review Plan corresponds to one of the 18 criteria of Appendix B to
10 CFR 50 and provides  acceptance criteria which are used by the NRC staff to evaluate QA
program descriptions or plans.

Similar  guidance for low-level waste disposal facilities is provided in NUREG-1293, "Quality
Assurance Guidance for Low-Level Radioactive Waste Disposal Facility" (NRC89).

The following summary of NRC QA criteria is mostly taken from the NRC Review Plan.
Certain  discussions from  NUREG-1293 have been added to help clarify selected criteria.
    ^References to DOE in this appendix refer to DOE's Office of Civilian Radioactive Waste Management
(OCRWM), not DOE/WIPP.

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CRITERION 1 - ORGANIZATION

The authorities and duties of persons and organizations performing activities important to
safety or waste isolation should be clearly established and delineated in writing.

The DOE and prime contractors should describe how responsibility is exercised for the
overall QA program.  The extent of management responsibility and authority from DOE
headquarters and from the field office should be addressed.  Clear management controls and
effective lines of communication must exist, for QA activities, between DOE and its
contractors, to assure direction of the QA program.

The DOE and its prime contractors should identify a management position within each
respective organization that retains overall authority  and responsibility for the QA program.
This position has the following characteristics:

•      Is at the same or higher organization level as the highest line manager directly
       responsible for performing activities affecting quality and is sufficiently independent
       from cost and schedule.

•      Has effective communication channels with other senior management positions.

•      Has no other duties or responsibilities unrelated to QA that would prevent full
       attention to QA matters.

Persons and organizations performing QA functions  must have sufficient authority and
organizational freedom to:

•      Identify quality problems.

•      Initiate, recommend, or provide solutions through designated channels.

•      Verify implementation of solutions.

•      Assure that further processing, delivery, installation, or operation is controlled until
       proper disposition  of a nonconformance, deficiency, or unsatisfactory condition has
       occurred.

CRITERION 2 - QUALITY ASSURANCE PROGRAM

A QA program must be established and documented which complies with the QA controls of

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10 CFR Part 60, Subpart G; with 10 CFR Part 50, Appendix B; and with the NRC Review
Plan for High-Level Waste Repository Quality Assurance Program Descriptions (NRC89a).

Criteria must be established and documented for determining and identifying structures,
systems, components, software and activities which are to be controlled by the QA program.
Guidance for determining these items and activities is provided in NUREG-1318, "Technical
Position on Items and Activities in the High-Level Waste Geologic Repository Program
Subject to Quality Assurance Requirements" (NRC88b).

Provisions should be established which demonstrate through a matrix system or other means
that each criterion of Appendix 4B is properly documented and covered by implementing
procedures and/or instructions.

The QA program should provide control over all activities affecting the quality of the
identified activities, structures, systems, and components to  an extent consistent with their
required performance.

The QA program includes a commitment that all development, control, and/or use of
computer programs will be conducted in accordance with the QA program.  Guidance for the
content of documentation of computer codes is provided by  NUREG-0856, "Final Technical
Position on Documentation of Computer Codes for High-Level Waste Management"
(NRC83).

The QA program should provide for indoctrinating and training personnel performing
activities affecting quality to ensure understanding of the technical procedure and QA
requirements.

Appropriate management monitoring for the performance of individuals involved in activities
affecting quality and determining the need for retraining and/or replacement need to be
included.  A system of annual appraisal and evaluation can satisfy this criterion.

Measures describing the extent a readiness review program  will be established and executed
at appropriate major milestones to complement the inspection program.
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CRITERION 3 - DESIGN CONTROL

The term design refers to specifications, drawings, design criteria, and component
performance requirements for the natural and engineered components of the disposal system.
It includes design inputs and outputs at each stage of design development.  Design
information and design activities refer to data collection and analyses activities and computer
codes that are used in supporting design development and verification.  This includes general
plans and detailed procedures for data collection and analyses and related information such as
test results and analyses.  Data analyses include the initial step of data reduction , as well as
broad level systems analyses (such as compliance assessments) which integrate many other
data and analyses of individual parameters.

Measures must be established to assure that applicable regulatory requirements, design bases
and design features developed through the site characterization phase activities are correctly
translated into specifications,  drawings, plans, procedures, and instructions.

Design Control

Design control measures  must be established and applied to:   (a) the design of engineered
items important to safety or waste  isolation; (b) the description of geologic setting and plans
for data collection and analysis activities that will generate information pertinent to the
disposal system design and that will be relied on in licensing; and (c) computer codes.  These
design control measures apply to the design inputs, outputs, and implementation of the Site
Characterization Plan into scientific investigation plans and study plans.

Procedures should be established to assure that plans for data collection and analyses are
completed before performing the date collection and analysis  activities.

The degree of design control  that management must exercise  over a given element of design
depends to a great degree on  how important that element is in meeting the performance
objectives and the technical requirements for the high-level waste facility.   The ability to
demonstrate the soundness  of the design is a key consideration in establishing management
controls.

Scientific investigations carried out to characterize the  site shall be defined, controlled, and
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verified. Documentation of the intended use of data is part of the planning. Any alternate
use of the data must be evaluated for appropriateness and the justification documented.
Planning should assure the compatibility of scientific investigations with any conceptual or
mathematical models used at each applicable stage.  Planning should establish provisions for
the evaluation of data quality to assure that data generated is valid, comparable, complete,
representative, precise,  and accurate.

Procedures shall be established describing methods of reviewing and qualifying data which
was gathered without a  fully  implemented 10 CFR Part 60 QA Program. Guidance is
provided in NUREG-1298, "Generic Technical Position on Qualification of Existing Data for
High-Level Nuclear Waste Repositories" (NRC88a).

Design  Verification

Procedural controls shall provide for verifying or checking the adequacy of design, such as
by the performance of design reviews,  by the use of alternate or simplified  calculation
methods, or by the performance of a suitable testing program.

Procedures must be established and described for verification of designs and design activities.
Individuals verifying designs should  be qualified and not directly responsible for the design
(i.e.,  not the performer or his immediate supervisor).  In exceptional cases, the designer's
immediate  supervisor can perform  the verification, provided:  (a)  the supervisor is the only
technically qualified individual, and  (b) the need is individually documented and approved in
advance, with concurrence of the QA manager.

Where a test program is used to verify the adequacy of a specific engineering design feature
in lieu of other verifying or checking processes, it shall include suitable qualifications testing
of a prototype unit under the most adverse design conditions.

Peer reviews may  be employed as  part of the actions necessary to provide adequate
confidence in the work under review, where the work may be a design, a plan, a test
procedure,  a research report, materials choice,  or a site exploration. Because of the potential
uncertainty in most geotechnical data and  their  analyses, the need to make projections over
several  hundred years, and the lack of  unanimity among experts,  expert judgment will need
to be  used  in assessing the adequacy of some work.  The guidance of NUREG-1297,
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"Generic Technical Position on Peer Review for High-Level Nuclear Waste Repositories"
(NRC88), should be used for determining the applicability and conducting a peer review.

Procedures shall be established to assure that verified computer codes are certified for use
and that their uses are specified.

Design "verification" consists of confirming that the design of the structure, system, or
component is suitable for its intended purpose.  Design "checking", which  should also be
performed, includes such things as confirming the numerical accuracy of computations and
the accuracy of data input to computer codes. Confirming that the correct  computer code  has
been used is part of the design verification.

Computer software should be verified, validated,  and documented.  NUREG-0856,  "Final
Technical Position on Documentation of Computer Codes for High-Level Waste
Management" (NRC83), provides guidance on documentation. Computer software verificat-
ion is defined as the process that demonstrates that the mathematical model embodied in the
computer software is a correct representation of the process or system for which it is
intended.

Design Changes

Design changes, including field changes, shall be subject to the  same design controls that
were applicable to the original design.  Such a configuration control system should be in
place at the earliest practicable  time. These changes should be analyzed to assure that
change is required.  Associated changes to procedures and training should be considered and
communicated to all affected groups or individuals.

Computer software should be placed under configuration control as each baseline element is
approved. Changes to computer software should  be systematically evaluated, coordinated,
and approved to ensure that the impact  of a change is carefully assessed before updating the
baseline.

CRITERION 4  - PROCUREMENT DOCUMENT CONTROL

Procedures must be established to assure the applicable regulatory requirements, design

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bases, and other requirements are referenced or stated in procurement documents; that there
are adequate acceptance and rejection criteria, where appropriate; and that procurement
documents have been prepared,  reviewed, and approved to confirm that these requirements
have been correctly carried out.

Procurement documents must specify that contractors, subcontractors and consultants are to
provide an acceptable QA program commensurate with the scope, complexity and safety of
the activity.

CRITERION 5  INSTRUCTIONS, PROCEDURES,  AND DRAWINGS

Activities affecting quality shall be prescribed by documented instructions, procedures, or
drawings and accomplished in accordance with these instructions, procedures, or drawings.

Procedures shall be established to assure that instructions, procedures, and drawings include
or reference quantitative or qualitative acceptance criteria for determining that quality-related
activities have been satisfactorily accomplished.

Provisions shall be included for controlling changes to field and laboratory procedures
associated with exploratory investigations within the site characterization program to assure
that such changes are subsequently documented and verified in a timely manner by authorized
personnel.

CRITERION 6  DOCUMENT CONTROL

Procedures for the review, approval, issuance,  and revision of documents shall be
established.

Procedures shall be established to assure that correct and applicable documents are available
at the location where the activity will be performed, before commencing the work.

Changes to documents shall be reviewed and approved by the same organizations that
performed the original review and approval, unless the applicant designated another
responsible organization.

A master list or equivalent document control system must be established to identify the
current  revision of instruction, procedures, specifications, drawings, and procurement
documents.
                                         4C-7

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CRITERION 7 - CONTROL OF PURCHASED MATERIALS, EQUIPMENT, ITEMS AND
SERVICES AND SOFTWARE

Measures must be established and described to assure that purchased items and services,
including software, whether purchased directly or through contractors and subcontractors,
conform to procurement documents.

Procedures governing procurement of items or services shall provide for:  (a) evaluation and
selection of suppliers; (b) objective evidence of quality furnished by suppliers; (c) inspections
and audits of suppliers' activities, items, services and software; and (d) receiving
instructions.

Documents attesting to the acceptability of procured items should be sufficient to identify the
specific requirement, such as codes, standards, or specifications, met by the purchased item,
and retained in the records storage facilities for retrievability, as necessary.

Provisions  shall be established by DOE or its designee to assess and ensure the control of
quality by contractors and subcontractors.  These assessments will be performed at intervals
consistent with the importance, complexity, and  quantity of the product or services.

CRITERION 8   IDENTIFICATION AND CONTROL OF ITEMS, SERVICES, AND
SOFTWARE

The purpose of this criterion is to provide for formal control over identification of items such
as core and laboratory test samples.  All material collected for observation or tests that
contribute to the design bases or compliance assessments  shall be identified and controlled.

Measures should be established for identifying and controlling materials, parts, components,
geologic cores and field and laboratory samples. These measures should ensure that, where
appropriate, identification of the item, core, or sample is maintained by appropriate
identification either on the item, core, or sample, or on records traceable to the original
item,  core, or sample.  These identification and  control measures should be designed and
maintained to ensure that geologic and environmental data are correctly identified to the time
and exact location of origin and that identification is maintained from collection  through
shipment,  sample split (sifbsample.) and subsequent analysis. Measures should be established
                                        4C-8

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for identifying and controlling materials, parts and components.

Correct identification of samples must be verified and documented before release for use or
analysis.  Controls are to be established to preclude the inadvertent use of incorrect or
defective items,  software, and samples.

CRITERION 9 - CONTROL OF SPECIAL PROCESS

The criteria for determining those processes that are controlled as special processes shall be
described.  As complete a listing as possible of special processes will be provided, which
generally are those processes  where direct inspection is impossible or disadvantageous,  such
as heat treatment, welding, nondestructive testing, data collection, and other site charac-
terization  activities.

Procedures, equipment, and personnel associated with special processes must be qualified and
in conformance with applicable  codes, standards, QA procedures, and specifications.
Acceptable methods for qualifying those special processes associated with scientific
investigations are:  (1) the conduct of a prototype test, if possible, that demonstrates the
process maintains quality or produces a quality product; or (2)  a technical review; or (3) a
peer review.

CRITERION  10  - INSPECTION

Inspection procedures, instructions, or checklists should provide for the following:  (a)
Identification of characteristics and activities to be inspected,  (b) A description of the
method of inspection,  (c) Identification of the individuals or groups responsible for
performing the inspection operation,  (d) Acceptance and rejection criteria,  (e) Identification
of required procedures, drawings, and specifications and revisions, (f) Recording inspector
or data recorder and the results  of the inspection operation,  (g) Specifying necessary
measuring and test equipment, including accuracy requirements.

Procedures shall  include identification of mandatory inspection hold points beyond which
work may not proceed until inspected by a designated inspector.

Provisions shall  be established to assure that when inspection of processed material  or
                                          4C-9

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products is impossible or disadvantageous, indirect control by monitoring processing
methods, equipment, and personnel is provided.

CRITERION 11 - TEST CONTROL

A test program shall be established to assure that all testing associated with software,
scientific investigations, and acquiring data from samples is identified and performed in
accordance with written test procedures incorporating, as appropriate, the  requirements and
acceptance limits contained in applicable design documents.

Procedural controls shall be established  to assure the test program includes, as appropriate,
proof tests before installation, preoperational tests, and operational tests during site charac-
terization, construction and operation  of the high-level waste storage facilities.

Program procedures for test control shall provide for:   (a) determining  when a test is
required and how testing activities are performed; and (b) assurance that the test program is
conducted by trained and appropriately qualified personnel.

The potential sources of uncertainty and error in test plans, procedures, and parameters,
which must be controlled and measured to assure that tests are well-controlled, must be iden-
tified.

Test procedures  or instructions shall provide for the following:  (a) the requirements and
acceptance limits, including required levels of precision and accuracy, as appropriate, are
contained in applicable documents;  (b) instructions for performing the tests; (c) test
prerequisites such as: calibrated instrumentation, adequate test equipment and
instrumentation,  completeness of item to be tested, suitable and controlled environmental
conditions, and provisions for data collection and storage; (d) mandatory inspection hold
points (as required); (e) acceptance and  rejection criteria, including required levels of
precision and accuracy;  (f) methods of documenting or recording test data and results; (g)
provisions for assuring test prerequisites have been met.

Test results shall be documented,  evaluated, and their acceptability determined by responsible
individual or group, as described  in Section 3.
                                         4C-10

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Items tested should be identified, controlled, and ultimately dispositioned, and samples
should be archived, as required by procedures.

CRITERION 12 - CONTROL OF  MEASURING AND TEST EQUIPMENT

The scope of the program shall be  described for assuring that tools, gauges, instruments and
other measuring and testing devices are properly controlled, calibrated, and adjusted, at
specified periods, to maintain accuracy within necessary  limits.

Measuring and test equipment shall be labeled, tagged or otherwise documented to indicate
due date of the next calibration and to provide traceability to calibration test data.

Measuring and test equipment shall be calibrated at specified intervals, based on  required
accuracy and equipment history of drifting, precision, purpose, degree of use, stability,
characteristics, and other conditions which could affect measurement.

When measuring and test equipment are found to be out  of calibration, evaluations shall be
made and documents to determine  the validity and acceptability of measurements performed
since the last calibration.  Inspections  or tests shall be repeated on items determined to be
suspect.

CRITERION 13   HANDLING, STORAGE, AND SHIPPING

Procedures must be established and described to control cleaning, handling,  storage,
packaging, and shipping of items and  samples in accordance with design  and procurement
requirements and manufacturer's recommendations to preclude damage, loss, or deterioration
by environmental conditions such as temperature or humidity.

It is of particular importance that attention be given to application of this criterion to the
control of samples to prevent damage, loss, deterioration, and misidentification.  When
necessary for particular products, a special protective environment (such  as inert gas
atmosphere), moisture content levels,  and temperature levels should be specified and
provided.

Samples  shall  be controlled during  handling, storage, and shipment to preclude damage or

                                         4C-11

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toss and to minimize deterioration.  Controls should be established for appropriate packaging,
handling, and modes of transportation, with consideration being given to types of containers,
time constraints on perishable materials (i.e., shelf life), and other environmental and safety
considerations applicable to the samples. Measures shall be taken to avoid sample
contamination during handling and shipment. Where multiple organizations are involved,
appropriate procedures should describe interface and custody responsibilities. Sample
identification should be verified and maintained when samples are handled, transported, or
transferred from one organization's responsibility to another.

Provisions shall be made to maintain sample characteristics, integrity, and identification
while in storage.  These provisions should be consistent with the planned duration and
conditions of storage and  should describe actions to be taken where samples have a maximum
life expectancy while in storage.  Storage methodology  should be developed and implemented
to ensure that  samples are maintained in predetermined environmental conditions
commensurate with the samples' intended purposes. Samples should be controlled to
preclude mixing of like samples or contamination.  Provisions shall be made for
identification and storage  of tested samples in areas physically separated from untested
sample materials.

CRITERION 14  INSPECTION, TEST, AND OPERATING STATUS

Procedures shall be established to indicate by the use of markings the status of inspections
and tests, and  the operating status of individual items and software.

Procedures should be established and described to control altering the sequence of required
tests, inspections, and other operations important to safety.  Such actions should be subject to
the same controls as the original review and approval.

The inspection and test status of samples, structures, systems, and components should be
identified. Such identification will prevent inadvertent use of a sample, structure, system, or
component yet to be inspected or tested or that has been found unacceptable for use.

CRITERION 15  - NONCONFORMANCES

Procedures shall be established for identifying, documenting, tracking, segregating,
                                        4C-12

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reviewing, dispositioning, and notifying affected organizations of nonconforming or defective
items, software, procedures, records, and activities. The procedures identify positions
authorized to dispose of and close out nonconformances.

CRITERION 16 - CORRECTIVE ACTION

Procedures shall be established indicating that an effective corrective action program has
been established to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviations, nonconforming and defective items, samples, procedures, and
records  are promptly identified and corrected.

Corrective action is to be documented and initiated after a nonconformance to preclude
recurrence.

Follow-up action should be taken by the QA organization to verify proper implementation of
corrective action and to close out the corrective action in a timely manner.

The cause of significant conditions adverse  to quality shall be determined and the corrective
action shall be taken to preclude repetition.

CRITERION 17  QA RECORDS

The scope of the records program shall be described which assures  that sufficient records
affecting quality are identifiable, retrievable, and maintained.  QA records include scientific,
engineering, and operational data and logs;  geotechnical data; results of reviews, inspections.
tests, audits, and material analyses; monitoring of work performance;  qualification of
personnel, procedures,  and equipment;  and other documentation such as drawings,
specifications, procurement documents, calibration procedures and reports,  design review
reports, peer review  reports, nonconformance reports, and corrective action reports.
Criteria should be established and described in procedures for determining when a document
becomes a QA record and the  retention periods for such records.

Procedures shall be established describing methods of documenting/recording, reviewing,  and
confirming accuracy  of records,  which include laboratory and field notebooks and log books,
data sheets, data reduction documents, and  software.
                                         4C-13

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Suitable facilities for the storage and security of records shall be described and used to
preclude deterioration, damage, loss and misuse of records.

CRITERION 18 - AUDITS

An audit plan shall be prepared identifying audits to be performed, their frequencies, and
schedules, taking into consideration the complexity, safety, importance and degree of
previous audits, inspections and surveillance.  Audits shall be regularly scheduled, based on
the status of safety importance of the activities being performed, and are initiated early
enough to assure effective QA during design, procurement, site characterization,
manufacturing, construction, installation, inspection and testing.

Audits should include technical evaluations of the applicable procedures, instructions,
activities, and/or items.  As applicable, they should include the review of documents and
records,  including software and test data from samples, to ensure they are acceptable.

A tracking system for audit findings should be established to help assure that all  findings are
appropriately addressed, prioritized and analyzed for trends.

Provisions shall be established and described to assure that the cause of each finding is also
identified, the corrective action for it described, and follow-up action is accomplished to
assure proper closeout of deficiencies.
                                          4C-14

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APPENDIX 4D  Comparison Matrices of Quality Assurance Program Requirements and
Guidance with ANSI/ASQC E4

The comparison matrices in this appendix are reproduced from a draft of ANSI/AS C E4 and
provide a frame of reference for the reader.  The matrices relate the basic requirements of
the reference document (e.g., NQA-1 Basic Requirements) to those of ANSI/ASQC E4 Parts
A, B, and C. The matrices identify the elements  of the Standard that are either substantively
equivalent or that address the same, subject.  Since NQA-1 is essentially equivalent to NRC's
10 CFR Part 50 Appendix B and NRC's 10 CFR Part 60 Subpart G, a comparison with it
approximates to a fair degree comparisons with the NRC standards.

Each of the referenced standards was developed for a specific industry  and scope. For
example, ASME NQA-1  was developed for the design, construction, operation, and
decommissioning of nuclear facilities.  ANSI/ASQC E4 has been developed for
environmental programs.   Since ANSI/ASQC E4 incorporates quality management concepts
not addressed in other requirements, some elements of this Standard are not found in the
other QA requirements documents.

In addition, while QAMS-005/80 is not a standard, it has been included here in recognition
of its widespread use in environmental programs. QAMS-005/80 was intended by the U.S.
Environmental Protection Agency (EPA) only to  provide guidance for preparing QA Project
Plans; however, it became a de facto standard for the EPA QA program in many places since
its release in 1980.

A particular requirement  contained in another standard may be addressed by ANSI/ASQC E4
differently in order to more closely fit environmental programs.  Consequently, multiple dots
in the comparison matrices will indicate where this Standard addresses  the contents of a
particular requirement for the given standard being compared.  This does not imply that the
original standard or guidance is more efficient.  Rather, it indicates how this Standard
addresses similar concepts from the perspective of environmental programs.  Equivalence
between this Standard and specific pans of other standards must be determined by the user
through careful comparison of the respective texts and confirmation of their applicability to
the needs of the user.

Comparison matrices are provided for the following standards:

                   - ASME NQA-1 (1989)
                   - DOE Order 5700.6C
                   - EPA QAMS-005/80
                   - NUREG-1293, Rev. 1

                                       4D-1

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                    COMPARISON MATRIX OF QUALITY ASSURANCE PROGRAM REQUIREMENTS
                                         ASME NQA-1 vs ANSI/ASQC E4
                                                                                           ANSI/ASQC-E4-19X3
NQA-1
1. Organization
2. Quality Assurance Program
3. Design Control
4. Procurement Document Control
5. Instructions, Procedures, &
Drawings
6. Document Control
7. Control of Purchased Items &
Services
8. Identification & Control of Items
9. Control of Processes
10. Inspection
11. Test Control
12. Control of Measuring and Test
Equipment
13. Handling, Storage & Shipping
14. Inspection, Test & Operating
Status
15. Control of Nonconforming
Items
16. Corrective Action
1 7. Quality Assurance Records
18. Audits, Surveillance, and
Managerial Controls
2.0


















2.1
•

















2.2

•
















2.3

•






•









2.4



•


•











2.5





•












2.6


O







O





O

2.7

•
•















2.8




•
•


•
•
•







2.9
•
•
O














•
2.10














•
• •


Key: •- Primary corresponding requirement in NQA-1
     o- Requirements appear in NQA-1 & 2 and/or 3

3.0



















3.1

O
O
















3.2


•

•


O











3.3

O
0




•
O
•
•
•
o
•





3.4

•















•

3.5









ฎ





























4.0



















4.)

•

















4.2


•


•













4.3







•
•
•
•
•
•






4.4







•
•
•
•
•
•
•





4.5

•













•

•

4.6









•
•







ฎ- Contains similar but not specifically the same requirement.
o- NQA-1 requirements correspond, however, primary guidance
    is provided in NQA-3.

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                       COMPARISON MATRIX OF QUALITY ASSURANCE PROGRAM REQUIREMENTS
                                             DOE Order 5700.6C v5 ANSI/ASOC F4
                                                                                                          ANSI/ASQC-E4-19x
 DOE Order 5700.6C
J9a. General
2.012.1 2.2
2.3 12.4 12.512.6 I 2.7 I 2.8 I 2.9 12.10
3.013.1 3.2  3.3  3.4
 9b. Quality Assurance Criteria
    (1) Management
3.5
4.0

4.1

4.2

4.3

4.4

4.5

4.6

1 . Program
2. Personnel Training &
Qualification
3. Quality Improvement
4. Documents & Records








•




*









•




•













•









•



























•























    (2)  Performance
5. Work Processes
6. Design
7. Procurement
8. Inspection & Acceptance
Testing


















•





00


fli
•



•


*














•




•


•


*




ฎ


ฎ







•




•


•


*
•


*







*
    (3)  Assessment
       9. Management Assessment
       10. Independent Assessment
 Key:   •- Primary corresponding requirement in DOE Order 5700.6C Criteria.
       ฎ - Contained within the context of the criteria but is not specifically the same requirement.

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                    COMPARISON MATRIX OF QUALITY ASSURANCE PROGRAM REQUIREMENTS
                                        EPA QAMS-005/80 vs ANSI/ASQC E4
                                                                                              ANSI/ASQC-E4-19X?
EPA QAMS-005/80
5.1 Title Page
5.2 Table of Contents
5.3 Project Description
5.4 Project Organization &
Responsibility
5.5 QA Objectives
5.6 Sampling Procedures
5.7 Sample Custody
5.8 Calibration Frequency &
Procedures
5.9 Analytical Procedures
5.10 Data Reduction, Validation &
Reporting
5.1 1 Internal Quality Control
Checks
5.12 Performance & System Audits
5.13 Preventive Maintenance
5.14 Routine Procedures to Assess
Data Quality
5.15 Corrective Action
5.16 QA Reports to Management
2.0
















2.1



•












2.2


ฎ













2.3
















2.4
















2.5
ฎ
ฎ




ฎ








ฎ
2.6
















2.7
















2.8
















2.9











•



•
2.10














•
• • .
                                                                 3.0
3.1
3.2
3.3

3.5
Key:  •- Primary corresponding requirement in NUREG 1293 basic requirements.
     ฎ- Contains similar but not specifically the same requirement.
4.0
4.1
4.2
4.3
4.4
             4.5
4.6

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                                                                                             ANSI/ASQC-E4-19X)
                    COMPARISON MATRIX OF QUALITY ASSURANCE PROGRAM REQUIREMENTS
                                          NUREG 1293 vs ANSI/ASQC E4
NUREG 1293
\. Organization
2. Quality Assurance Program
3. Design Control
4. Procurement Document Control
5. Instructions. Procedures, &
Drawings
6. Document Control
7. Control of Purchased Items &
Services
8. Identification & Control of Items
9. Control of Processes
10. Inspection
1 1 . Test Control
12. Control of Measuring and Test
Equipment
13. Handling, Storage & Shipping
14. Inspection. Test & Operating
Status
15. Control of Nonconforming
Items
16. Corrective Action
17. Quality Assurance Records
18. Audits, Surveillance, and
Managerial Controls
2.0


















2.1
•

















2.2

•
















2.3

•
















2.4



•


•











2.5





•










•

2.6


•















2.7

•
















2.8




•
•


•
•



•




2.9
•
•















•
2.10














•
•


                                                                 3.0
3.1
3.2
3.3
3.4
3.5
4.0





Key:   •- Primary corresponding requirement in NUREG 1293 basic requirements.

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5.  Issues for the Selection and Development of Models and Computer Codes

5.1    Introduction

The DOE is currently selecting and developing models  and computer codes to meet
compliance assessment objectives for the WIPP.  The EPA will ultimately have to accept or
reject the DOE selection and/or application of models and computer codes. This section
identifies the issues considered by EPA in the development of acceptance criteria for WIPP
model and code selection.

The DOE has already selected and applied a number of computer codes at the WIPP to gain
a preliminary insight into the kinds  of problems that may  be encountered in the more detailed
modeling analyses that will be conducted for the compliance assessment in support of the
compliance application.  In the process of DOE's continued formulation and testing of the
various components of the disposal  system conceptual models, attention is given to many
aspects of the system and possible avenues of analysis.  These include system
conceptualization (i.e., definition of the physical framework, relevant processes, and the
boundary conditions present) and model conceptualization (i.e., what approaches are
justifiable and relevant to meeting performance objectives).  After the conceptual model has
been formulated, appropriate codes  will be selected by  matching a detailed description of the
modeling needs with well-defined, quality-assured characteristics of existing codes, while
taking into account the compliance assessment objectives of the study.  If a good match
between model requirements and  code characteristics cannot be found,  modification of an
existing code or the development of a new code may be considered.

Radiological dose calculations are required to meet the  Individual Protection Requirements of
40 CFR part 191. The 1992 compliance assessment was performed  according to the original
(1985) standard, which limited the maximum dose to an individual during the first 1,000
years after disposal. Since Sandia considered it unlikely that there would be any releases
during the first 1,000 years  of undisturbed performance, it did  not perform those dose
calculations.  Nevertheless,  a computer code for performing such calculations  was prepared
(i.e.,  GENII-S) and may be used  in future compliance assessments.

A key consideration for WIPP compliance assessment is the existence of multiple conceptual
models. For example, there are at  least two hydrogeologic conceptual models.  As described
in the  1990 Performance Assessment Phase Plan, the models are very different in their
conceptualization of the flow and transport processes in the Salado formation, which is the
primary natural barrier to the accessible environment at the site (WIPP Test Phase Plan:
                                          5-1

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Performance Assessment, 1990):

       •     In one conceptual model, brine in the pore space is released by
             deformation that accompanies the creation of any opening in the
             salt.

       •     In a second conceptual model, the salt, even though it is plastic,
             has continuous filaments of connected brine, and  flow in the
             system can be described by Darcy's law.

The hypothesis  selected will ultimately determine the inherent computer code requirements
necessary to simulate flow and transport in the Salado  formation.

In the 1992 compliance assessment, DOE presented other components of its  site conceptual
model. These components focused on the Culebra  dolomite member of the Rustler formation
overlying the Salado formation. The Culebra dolomite is thought to present the most likely
avenue for radioactive waste to reach the accessible environment.  However, there is
considerable uncertainty regarding the system boundary conditions and flow  and transport
mechanisms.  Many of the field tests which have not yet been performed are designed to test
various components of the conceptual model(s). It  is premature to develop comprehensive
screening criteria without these test  results.

Another consideration is that computer codes are seldom designed to be universally
applicable. More often than not,  code development is aimed at solving a  specific
environmental problem or range of problems that previous  codes had not satisfactorily
addressed. Therefore,  a single code will not simulate  all of the components of the conceptual
model. For example, most scenarios consider three time-dependent gas-generation processes
which are expected to be involved in the degradation of transuranic (TRU) waste in the
disposal system:  (1) oxic and anoxic corrosion of metals, (2) aerobic and anaerobic
microbial degradation of cellulosic materials, and (3) radiolysis. The potential  for large
quantities of gas has strong links to other processes associated with closure of the disposal
rooms and panels.  After the panel seal is installed, the surrounding rocksalt formation flows
(creeps) inward upon and compacts the decomposing waste and the backfill, and pressurizes
the radionuclide- and hazardous constituent-contaminated brine,  and the VOC-contaminated
gas.  The pressure within these materials may extrude the brine and compressed gas through
natural, and perhaps even induced, fractures toward the regulatory boundaries.   The distance
to which the brine and gas are driven depends upon the pressure, the permeability and
storage capacity of the surrounding  formation, and  the quantity of the generated gas.
Because a single code will most probably not be used  to simulate all aspects of this scenario,
criteria on which processes the code should or should  not be capable of simulating are

                                          5-2

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difficult to develop.

Section 5.2 of this chapter discusses how a code review would first determine if the selected
code was  compatible with the modeling objectives set forth in the compliance assessment.
Section 5.3 focuses on the code development process, code capabilities, and the quality of the
accompanying documentation. Issues related to the application of a computer code are
considerably  different than those associated with code development and selection (i.e., a
properly  selected code can be improperly applied).  Although the primary objective of this
chapter is to  present issues related to model and code selection rather than to code
application, section 5.4 discusses  code application criteria in a global sense.

Of course, model development and acceptance review should always be performed by an
experienced team consisting of at least a scientist knowledgeable in theoretical aspects of
modeling relevant technologies, a software engineer(s), and other specialists with appropriate
backgrounds. Because the theoretical framework of a code is becoming increasingly
complex,  the review team would be expected to involve multiple disciplines (e.g., solid
mechanics, hydrodynamics,  hydrogeology, geochemistry, contaminant chemistry, aquatic
microbiology, health physics, and stochastic and numerical analysis.)

5.2    Compliance Assessment Modeling  Objectives

In very general terms, compliance assessment uses a series of mathematical models, each of
which simulates the behavior of a component or a series of components of the waste isolation
system.  When these models are coupled together,  the end result is supposed to be a complex
mathematical representation of the expected behavior of the disposal system. The
determination of a model's acceptability for a particular application at the WIPP depends on
whether the model attributes are consistent with the site characteristics.

The compliance assessment  may be viewed as an effort to find answers to the following three
questions:

       •      What events can happen? (scenarios)

       •      How likely are events to happen? (probabilities of scenarios)

       •      What are the outcomes, if these events happen? (consequences of scenarios)
                                           5-3

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The first question is answered by a systematic scenario construction that provides a set of
comprehensive ancj mutually exclusive scenarios for consequence analysis.  Answering the
second question requires probability analysis for the scenarios chosen for analysis.
Answering the third question requires a modeling  system for estimating consequences.

From the viewpoint of long-term performance of the WIPP facility, some fundamental
questions are (1) whether brine inflow into the disposal rooms will be sufficient to saturate
backfill, waste, and the disturbed rock zone, either before or after compaction to the final
mechanical state;  (2) whether the far-field permeability will be sufficient to dissipate brine
and/or gas pressures at and near the final state, at some fluid pressure below lithostatic load,
and (3) how will the system behave when human-initiated processes and events occur.

Key regulations applicable to the WIPP are,  among others,  EPA's regulations 40 CFR part
191, 40 CFR 268.6, and 40 CFR 264, Subpart X. EPA regulation 40 CFR part 191
specifies environmental standards for the disposal  of radioactive waste,  including reference to
Part 141 which relates to the Safe Drinking Water Act.  RCRA is implemented by 40 CFR
268.6 and 40  CFR 264 Subpart X.  Regulation 40 CFR part 191 (Subparts B and C)  includes
containment, assurance, individual protection, and ground-water protection requirements.

Of particular interest are the containment requirements (section 13 of 40 CFR part 191) for
the "disposal system,"  which sets limits on the probabilities of exceeding specified
cumulative releases of particular radionuclides to  "the accessible  environment" for 10,000
years after disposal. Guidance accompanying the regulation specifies that compliance be
shown, to the extent practicable, in a single  "complementary cumulative distribution   .
function" (CCDF) displaying probabilities of exceeding certain cumulative releases of
radionuclides  to the accessible environment.  To demonstrate compliance with the
containment requirements of section  13(a) of 40 CFR part 191, it is necessary  to estimate the
releases of radionuclides that might occur during  a period of 10,000  years after the disposal
system  has been sealed.  Also,  in estimating releases, it is necessary  to consider (i.e., model)
all the significant processes and events that might affect the ability of the disposal system to
isolate waste.  Moreover, the releases are to be treated probabilistically; it is necessary to
estimate probabilities of occurrence for the releases.

The site conceptual model is currently being divided into a number of discrete components,
each to be described by separate computer code(s). Therefore, the compliance assessment
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calculations will rely heavily on the linkage among these individual codes through CAMCON
in order to construct complementary cumulative distribution functions.  It will be important
to ensure that proper consideration is given to the effects that uncertainty and parameter
sensitivities within each code can have on the total system  behavior.
5.3    Code-related Issues

A brief discussion follows concerning how the various regulations that must be addressed at
the WIPP may influence the acceptance or rejection of a particular code.  The determination
of a computer code's acceptability for a particular application at the WIPP depends on
whether the code can potentially meet the modeling objectives.  In addition, the code
evaluation process must also consider attributes that are integral components of the computer
code(s) including:

       •      Source Code Availability

       •      History of Use

       •      Code Documentation

       •      Code Testing

       •      Hardware Requirements

       •      Solution Methodology

       •      Code Dimensionality

5.3.1  Source Code  Availability

To facilitate thorough review of the generic code, detailed documentation of the code and its
developmental history is required, and the source code should be available for inspection. In
addition, to ensure independent evaluation of the reproducibility of the verification and
validation results, the computer source code as  well as the compiled version of the code (i.e.,
computer code in machine language) should be available to the reviewer, together with files
containing the original test data used in the code's verification and validation.
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5.3.2  History of Use

Much of the information needed for a thorough code evaluation can be obtained from the
author or distributor of the code. In fact, inability to obtain the necessary publications can
indicate that the code is either not well documented or that the code is not widely used. The
acceptance and evaluation process should rely on user opinions and published information, in
addition to hands-on experience and testing. User opinions are especially valuable in
determining whether the code functions as documented or has significant errors or
shortcomings. In some instances, users independent of the developer have performed
extensive testing and bench-marking or are familiar with published papers documenting the
use of the code.

5.3.3  Quality Assurance

Code acceptance issues are closely tied to the quality assurance issues followed during  the
developmental process  of the computer code. These criteria are associated with the adequacy
of the code testing and documentation.

Quality assurance in modeling is the procedural and operational framework put in place by
the organization managing the modeling study, to assure technically and scientifically
adequate execution of all project tasks included in the study, and to assure that all modeling-
based analysis is verifiable and defensible (TA85).

The two  major elements  of quality assurance are quality control and quality assessment.
Quality control refers to  the procedures that ensure the quality of the final product.  These
procedures include the  use of appropriate methodology in developing and applying computer
simulation  codes, adequate verification and validation procedures, and proper usage of  the
selected methods and codes  (HE92).  To monitor the quality control procedures and to
evaluate the quality of  the studies, quality assessment is  applied (HE89).

Software quality assurance (SQA) consists of the application of procedures, techniques, and
tools through the software life cycle, to ensure that the products conform to pre-specified
requirements (BR87).   This requires that in the initial stage of the software development
project, appropriate SQA procedures (e.g., auditing, design inspection, code inspection,
error-prone analysis, functional testing, logical testing, path testing, reviewing, walk-through)
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and tools (e.g., text-editors, software debuggers, source code comparitors, language
processors) need to be identified and the software design criteria be determined (HE92).

Quality assurance for code development and maintenance implies a systematic approach,
starting with the careful formulation of code design objectives (section 5.2), criteria, and
standards, followed by an implementation strategy.  The implementation strategy includes the
design of the code structure and a description of the way in which software engineering
principles will be applied to the code.  In this planning stage, measures are to be taken to
ensure complete documentation of code design and implementation, record-keeping of the
coding process, description of the purpose and structure of each code segment (functions,
subroutines),  and record-keeping of the code verification process.

Records for the coding and verification process may include a description of the fundamental
algorithms describing the physical process(es) to be modeled; the means by which the
mathematical algorithms have been translated into computer code (e.g., fortran); results of
discrete checks on the subroutines for accuracy; and comparisons among the codes'
numerical solutions with either analytical or other independently verified numerical solutions.

Software used for compliance assessment should have both internal and external
documentation. Internal documentation, which is part of the source code, describes the
operation of the program and includes the name of the author, other sources of the software,
and its revision history.  External documentation includes a software abstract, an on-line help
file stored on the applicable computer system, records of verification and changes, and
formal reports including a theory manual and a user's manual.

Code verification or testing ensures that the underlying mathematical algorithms have been
correctly translated into computer code.  The verification process varies for different codes
and ranges from simply checking the results of a plotting routine to comparing the results of
the computer code to known analytical solutions or to results from other verified codes.

Traceability describes the ability of the compliance assessment analyst to identify the
software that  was used to perform a particular calculation, including its name, date, and
version number, while retrievability refers to the availability of the same version of the
software for further use.
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5.3.3.1  Code Documentation.  Detailed guidelines for the preparation of comprehensive
software documentation are given by the Federal Computer Performance Evaluation and
Simulation Center,(FEDS 1).  The "Computer Model Documentation Guide" discusses the
structure recommended for four types of manuals providing model information for managers,
users, analysts,  and programmers.  According to FEDSIM (1981), the manager's summary
manual should contain a model description, model development history,  an experimentation
report, and a discussion of current and future applications. Currently, ASTM (American
Society for Testing and Materials) is developing a standard ground-water code description for
this specific purpose (HE92).

In general, the code documentation should describe the theoretical framework represented by
the generic model on which the code is based, code structure and language standards applied,
and code use instructions regarding model setup and code execution parameters.  The
documentation should also include a complete treatment of the equations on which the
generic model is based, the underlying mathematical and conceptual assumptions, the
boundary conditions that are incorporated in the model, the method and  algorithms used to
solve the equations, and the limiting conditions resulting from the chosen approach.  The
documentation should also include user's instructions for implementing and operating the
code and preparing data files.  It should present examples of model formulation (e.g., grid
design, assignment of boundary conditions), complete with input and output file descriptions,
and include an extensive code verification and validation~or field testing  report.  Finally,
programmer-orientated documentation should provide instructions for code modification and
maintenance.

Code Documentation Issues

An integral part of the code development process is the preparation of the  code
documentation.  This documentation of QA in model development consists of reports and
files pertaining to the development of the model and could include:

      •      A report on the development of the code including the
             (standardized and approved) programmer's bound notebook
             containing detailed descriptions of the code verification process;

      •      Verification report including verification scenarios, parameter
             values, boundary and initial conditions, source-term conditions,
             dominant flow and transport processes;

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•      Orientation and spacing of the grid and justification;

•      Time-stepping scheme and justification;

•      Changes and documentation of changes made in code after
       baselining;

•      Executable and source code version of baselined code;

•      Input and output (numerical and graphical) for each verification
       run;

•      Notebook containing reference material (e.g., published papers,
       laboratory results, programmer's rationale ) used to formulate
       the verification problem.

Furthermore, the purpose of the software  documentation is to (GA79):

•      record technical information that enables system and program
       changes to be made  quickly and effectively;

•      enable programmers and system analysts, other than software
       originators,  to  use and to work on  the programs;

•      assist the user in understanding what the program is about and
       what it can do;

•      increase program sharing potential;

•      facilitate auditing and verification of program operations;

•      provide managers with information to review  at significant
       developmental  milestones so that they may independently
       determine that project requirements have been met and that
       resources should continue to be expended;

•      reduce disruptive effects of personnel turnover;

•      facilitate understanding among managers, developers,
       programmers, operators,  and users by providing information
       about maintenance, training, and changes in and operation of the
       software;

•      inform other potential users of the  functions and capabilities of
       the software, so that they can determine whether it  serves their
       needs.

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The user's manual could consist of items such as:




       •      an extended model description;




       •      model input  lata description and format;




       •      type of output data provided;




       •      code execution preparation instructions;




       •      sample model runs;




       •      trouble shooting guide; and




       •      contact person/affiliated office.




The programmer's manual could consist of items such as:




       •      model specifications;




       •      model description;




       •      flow  charts;




       •      descriptions of routines;




       •      database description;




       •      source listing;




       •      error messages; and




       •      contact person/affiliated office.




The analyst's manual could consist of items such as:




       •      a functional description of the model;




       •      model input and output data;




       •      code  verification and validation information; and




       •      contact person/affiliated office.
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The code itself should be well structured and internally well documented; where possible,
self-explanatory parameter, variable, subroutine, and function names should be used.

5.3.3.2 Code Testing. Before a code can be used as a planning and decision-making tool,
its credentials must be established through systematic testing of the model's correctness and
evaluation of the model's performance characteristics (HE89).  Of the two major approaches
available, the evaluation or review process is qualitative in nature, while code-testing results
can be expressed using quantitative performance measures.

Code testing (or code verification) is aimed at detecting programming errors, testing
embedded algorithms,  and evaluating the operational characteristics of the code through its
execution on carefully selected example test problems and test data sets. ASTM84 defines
verification as the examination of the numerical technique in the computer code  to ascertain
that it truly represents  the conceptual model, and that there are no inherent problems that
prevent obtaining a correct solution.

At this point, it is necessary to distinguish between generic simulation codes based on an
analytical solution of the governing equation(s) and codes that include a numerical solution.
Verification of a coded analytical solution is restricted to comparison with independently
calculated results using the same mathematical expression, i.e., manual calculations, using
the results from computer programs coded independently by third-party programmers.
Verification of a code  formulated with numerical methods might take two forms: (1)
comparison with analytical solutions, and (2) code intercomparison between numerically
based codes, representing the same generic simulation model, using synthetic data sets.

It is also important to distinguish  between code testing and model testing. Code testing is
limited to establishing  the correctness of the computer code with respect to the criteria and
requirements for which it is designed (e.g., to represent the mathematical model). Model
testing (or model validation) is more inclusive than code testing, as it represents the final step
in determining the validity of the  quantitative relationships derived for the real-world system
the model is designed to simulate.

Attempts to validate models must address the issue of spatial and temporal variability when
comparing model predictions with limited field observations.  If sufficient field data are
obtained to derive the probability  distribution of contaminant concentrations, the results of a
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stochastic model can be compared directly.  For a deterministic model, however, the
traditional approach has been to vary the input data within its expected range of variability
(or uncertainty) and determine whether the model results satisfactorily match historical field
measured values. This code-testing exercise is sometimes referred to as history matching.

Konikow and Bredehoeft (KO92) argue compellingly that computer models cannot be truly
validated but can only be invalidated.  As reported by Hawking (HA88), any physical theory
is only provisional,  in the sense that it is only a hypothesis that can never be proven.  No
matter how many times the results  of the experiments agree with  some theory,  there is never
complete certainty that the next test will not contradict the theory.  On the other hand, a
theory can be disproven by finding even a single observation that disagrees with the
predictions of the theory.

From a philosophical perspective, it is difficult for EPA to develop acceptance  criteria for a
model validation process that may be intrinsically flawed; however, some strategy is
necessary to ensure that the conceptual model with the highest probability of most accurately
representing the system is selected.  As noted in Section 5.1, there are at least two very
different conceptual models for flow and transport in the Salado formation, the  primary
barrier at the WIPP site.  Therefore, model validation and conceptual model formulation and
testing will play an important role in the overall code acceptance  approach.

5.3.3.3      Quality Assurance Standard

The American Society of Mechanical Engineers (ASME) Committee on Nuclear Quality
Assurance has developed standards for the development and use of computer software used in
the design and operation of nuclear facilities (ASME90).  This  standard was developed under
procedures accredited as meeting the criteria for American National Standards.   It addresses
the following:

       •     general requirements

       •     software life cycle

       •     software verification and validation

       •     software configuration control

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       •     documentation

       •     verification reviews

       •     problem reporting and corrective action

       •     access control

       •     software procurement

       •     records

5.3.4  Hardware Requirements

In general, hardware requirements are rarely a discriminatory factor in the selection of a
computer code.  However, a number of the codes that DOE intends to use in modeling the
WIPP will require very sophisticated hardware, not so much because of th6 intrinsic
requirements of the code but because the processes to be modelled are very complex.

5.3.5  Mathematical Solution Methodology

Every ground-water or contaminant transport model is based upon a set of mathematical
equations.  Solution methodology refers to the  strategy and techniques used to solve these
equations.  In ground-water modeling, the equations are normally solved for head (water
elevations in the subsurface) and/or contaminant concentrations.  Other disposal system
processes will be modeled with codes that solve for gas-filled porosities and the quantity of
radioactive material (in curies) brought to the surface  as cuttings generated by a drilling
operation that penetrates the disposal system.

Mathematical methods can be broadly classified as either deterministic or stochastic.
Deterministic methods assume that a  system or process operates such that the occurrence of a
given set of events leads to .a uniquely definable outcome.  Stochastic  methods pre-suppose
the outcome to  be uncertain and are structured  to account for this uncertainty.

Most stochastic methods are not completely stochastic in that they often utilize a
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deterministic representation of processes and derive their stochastic nature from their
representation of inputs and/or spatial variation of characteristics and resulting movement
(i.e., Monte Carlo methods).  While the deterministic approach results in a specific value of
a variable (e.g., solute concentration) at pre-specified points in the domain, the stochastic
approach provides the probability (within a level of confidence) of a specific value occurring
at any point.

Deterministic methods may be broadly classified as either analytical or numerical. Analytical
methods usually involve approximate or exact solutions to simplified forms of the differential
equations for water movement and solute transport.  Simple analytical methods are based on
the solution of applicable differential equations which make a  simplified idealization  of the
field and give qualitative estimates of the extent of contaminant transport.  Such models are
simpler to use than numerical models and can generally be solved with the aid of a
calculator,  although computers are also used.  Analytical models are restricted to simplified
representations of the physical situations and generally require only limited site-specific input
data. They are useful for screening sites and scoping the problem to  determine data needs or
the applicability of more detailed numerical models.

Analytical solutions are used in modeling investigations to solve many different kinds of
problems.  For example, aquifer parameters are obtained from aquifer pumping and  tracer
tests through the use of analytical models, and ground-water flow and contaminant transport
rates can also be estimated with the use of analytical  models.

Numerical models provide solutions to the differential equations describing room collapse,
water movement, and solute transport using numerical methods such as finite differences and
finite elements.  Numerical methods account for complex geometry and heterogeneous
media, as well as dispersion, diffusion, matrix deformation, salt creep and chemical
retardation processes (e.g., sorption, precipitation, radioactive decay, ion exchange,
degradation).  These methods almost always require a digital computer, greater quantities of
data than analytical modeling,  and experienced modelers.

The validity of the results from mathematical models depends strongly on the quality and
quantity of the input data. Stochastic, numerical, and analytical codes have strengths and
weaknesses inherent within their formulations, all of  which  need to be considered prior to
their selection and EPA acceptance.
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5.3.6  Code Dimensionality

The determination as to the number of dimensions that a code should be able to simulate is
based primarily upon the modeling objectives and the dimensionality of the processes the
code is designed to simulate.

In determining how many dimensions are necessary to meet the objectives, a basic
understanding is needed of how the physical processes (e.g., salt creep, ground-water flow,
transport, dose rate) are affected by the exclusion or inclusion of an additional dimension.
The movement of ground water and contaminants is usually controlled by advective and
dispersive processes which are inherently three-dimensional.  Advection is more responsible
for the time (i.e., travel time) it takes for a contaminant to travel from the source term  to a
downgradient receptor, while dispersion  directly influences  the concentration of the
contaminant along its travel path.  This fact is very important in that it provides an intuitive
sense for the effect dimensionality has on contaminant migration rates and concentrations.

As a general rule, the fewer the dimensions, the more the model results will over-estimate
concentrations and under-estimate travel  times.  In a model with fewer dimensions, predicted
concentrations will generally be greater because dispersion, which is a three-dimensional
process, will be dimension limited and will not occur to the same degree as it actually would
in the field. Similarly, predicted travel times will be shorter than the actual travel time, not
because of  a change in the contaminant velocities but because a more direct travel path  is
assumed. Therefore, the lower dimensionality models tend to be more conservative in their
predictions  and are frequently used for screening analyses.

One-dimensional simulations of contaminant transport usually ignore dispersion altogether,
and contamination is assumed to migrate solely by advection, which results in a highly
conservative approximation.  Vertical analyses in one dimension are generally reserved  for
evaluating flow and transport in the unsaturated zone. In the 1992 compliance assessment
modeling of the Culebra dolomite, advective and dispersive flow and transport were modeled
in two dimensions with SECO, whereas matrix diffusion was  confined to one dimension.
This type of mixed-dimensionality approach is not uncommon early in a modeling analysis.
However, DOE recognizes the need to review the modeling assumptions that have been used
in the application of these codes and to ensure that the analyses are defensible.  The DOE
has therefore developed three-dimensional versions of SECOFL and SECOTP for this
purpose.  They will be used to perform additional sensitivity analyses.
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Two-dimensional analyses of an aquifer flow system can be performed as either a planar
representation, where flow and transport are assumed to be horizontal (i.e., longitudinal and
transverse components), or as a cross-section where flow and transport components are
confined to vertical and horizontal components. In most instances, two-dimensional analyses
are performed in an areal orientation, with the exception of the unsaturated zone,  and are
based on the assumption that most contaminants enter the saturated system from above and
that little vertical dispersion occurs.  However, a number of limitations accompany two-
dimensional planar simulations.  These include the inability to simulate multiple layers (e.g.,
aquifers and aquitards) as well as any partial penetration effects.  Furthermore, because
vertical components of flow are ignored, a potentially artificial lower boundary on
contaminant migration has been automatically assumed which may or may not be the case.

A two-dimensional formulation of the flow system is frequently sufficient for the purposes of
risk assessment provided that flow and transport in the contaminated aquifer are essentially
horizontal. The added complexities of a site-wide, three-dimensional flow and transport
simulation are often believed to  outweigh the expected improvement in the evaluation of risk.
Complexities include limited site-wide hydraulic head and lithologic data with-depth and
significantly increased computational demands.

Quasi three-dimensional analyses remove some of the limitations inherent in two-dimensional
analyses.  Most notably, quasi three-dimensional simulations allow for the incorporation of
multiple layers; however, flow and transport in the aquifers are still restrained to longitudinal
and transverse horizontal components, whereas flow and transport in the aquitards are even
further restricted to vertical flow components only.  Although partial penetration effects still
cannot be accommodated in quasi three-dimensional  analyses, this method can sometimes
provide a  good compromise between the relatively simplistic two-dimensional analysis and
the complex,  fully three-dimensional analysis.  This  is the case particularly if vertical
movement of contaminants or recharge from the shallow aquifer through a confinin? unit and
into a deeper aquifer (e.g., Culebra) is suspected.

Fully three-dimensional modeling generally allows both the geology and all of the dominant
flow and transport processes to be described in three dimensions.  This approach is usually
the most reliable means of predicting ground-water flow and contaminant transport
characteristics, provided that sufficient representative data are available for the site.
However, at the WIPP it may turn out that the most conservative and appropriate modeling
approach is a two-dimensional analysis.
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Modeling of the Culebra Dolomite of the Rustler Formation at the WIPP has assumed two-
dimensional horizontal flow. The DOE rationale for this approach is that most hydrologic
test wells in the Culebra Dolomite are completed across the entire vertical extent of the
Culebra.  Parameters derived from tests on these wells are therefore composite or averaged
values over the vertical extent of the member.  Although flow is known to be localized to
particular elevations within the Culebra at several wells, information is insufficient to
characterize vertical variability of hydrologic properties within the unit. A vertically
integrated two-dimensional model has therefore been adopted for the 1992 compliance
assessment calculations.

Although the intrinsic dimensionality of the code should be an important consideration in
accepting or rejecting the code, this determination will also be  closely tied to the code
application and modeling objectives.  For example,  SANCHO, applied in the 1992
compliance assessment to model the two-dimensional closure of a waste disposal room by salt
creep, assumed a constant rate of gas generation and ideal gas behavior.  If this two-
dimensional approach can be successfully defended  as conservatively simulating all of the
critical processes with respect to the room closure rates, it may be unnecessary to perform
more realistic simulations in three dimensions.  However, many of the individual components
of the site conceptual model were insufficiently understood at the time of the 1992
compliance assessment to make this determination.

5.4   Model Application

The application of a generic simulation model to a site-specific problem is often called
"model application" or "(computer/simulation) code application." The application of a
generic model  to site-specific conditions should follow a well-structured model application
protocol.  Such protocols are described by Mercer and Faust (ME81), van der Heijde et. al
(HE88), and Anderson and Woessner (AN92), among others.  Quality assurance in these
types of studies follows the same pattern as discussed  for generic model development  projects
and consists of using appropriate data, data analysis procedures, modeling methodology and
technology, administrative procedures and auditing.  To a large extent, the quality of  a
modeling study is determined by the expertise of the modeling  and quality assessment teams.
The following  discussion is consistent with procedures found in an EPA-sponsored
publication (HE92).
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Quality assurance in code application addresses all facets of the modeling process, including
such issues as:


       •     Historical review of code verification and benchmarking process;

       •     Correct and clear formulation of problems to be solved;

       •     Project description and objectives;

       •     Type of modeling approach to the project;

       •     Decision whether modeling is the best available approach and if
             so, that the selected code is appropriate and cost-effective;

       •     Conceptualization of system and processes, including
             hydrogeologic framework, boundary conditions,  stresses, and
             controls;

       •     Detailed description of assumptions and simplifications, both
             explicit and implicit (to be subject to critical peer review);

       •     Data acquisition and interpretation;

       •     Code selection considerations, or justification for modifying an
             existing code or developing a new one;

       •     Model preparation  (parameter selection, data entry or
             reformatting,  gridding);

       •     Validity of the parameter values used in the model application;

       •     Protocols for parameter estimation and model calibration to
             piovide guidance, especially for sensitive parameters;

       •     Level of information in computer output (variables and
             parameters  displayed; formats; layout);

       •     Identification of calibration goals and evaluation of how well
             they have been met (e.g., root-mean square errors, etc.);

       •     Role of sensitivity  analysis  in evaluating parameter uncertainties
             and creating probability distributions;
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       •      Post-simulation analysis (including verification of reasonableness
              of results, uncertainty analysis, and the use of manual or
              automatic data processing techniques, as for contouring);

       •      Establishment of appropriate performance targets which should
              characterize the limits of the data;

       •      Presentation and documentation of results;

       •      Evaluation of how closely the modeling results answer the
              questions raised by management.

QA for model application should include complete record-keeping of each step of the
modeling process.  The paper trail for QA should consist of reports and files addressing the
following items:

       •      Assumptions and limitations;

       •      Parameter or input values and sources including  rationale for
              their selection, range, and distribution;

       •      Boundary and initial conditions;

       •      Nature of grid and grid design justification;

       •      Changes and verification of changes made in code;

       •      Actual input used;

       •      Output of model runs and interpretation;

       •      Validation (or at least calibration) of model.

As is the case with code development QA, all data files, source codes, and executable
versions of computer software used in the  modeling study should be retained for auditing or
post-project re-use (in hard-copy and, at higher levels, in digital form) including:

       •      Version of the source and executable  image of the code used;

       •      Calibration input and output;

       •      Verification input and output;

       •      Application input and output (e.g., for each of the  scenarios
              studied).

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If the code used in the modeling study is modified, then the code should be tested again
according to a standard testing protocol; the code should be subject to the full QA procedure
for code development, including accurate record-keeping and reporting.  All new input and
output files  should be saved for inspection and possible re-use together with existing files,
records,  codes, and data sets.
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                                       5.5  References
AN92
ASME90
ASTM84
BR87
FED81
GA79
HA88
HE88
HE89
Anderson, M.P., and W.W. Woessner, 1992.  Applied Groundwater
Modeling: Simulation of Flow and Advective Transport.  Academic Press,
Inc., San Diego, California.

Am. Soc. of Mechanical Engineers (ASME), 1990.  Quality Assurance
Program Requirements for Nuclear Facilities. ASME NQA-2a-1990, PART
2.7, Quality Assurance Requirements of Computer Software for Nuclear
Facility Applications, Am. Soc. of Mechanical Engineers, New York.

Am. Soc. for Testing and Materials (ASTM), 1984.  Standard Practices for
Evaluating Environmental Fate Models of Chemicals. Annual Book of ASTM
Standards, E 978-84, Am. Soc. for Testing and Materials, Philadelphia,
Pennsylvania.

Bryant, J.L., and N.P. Wilburn, 1987.  Handbook of Software Quality
Assurance Techniques Applicable to the Nuclear Industry. NUREG/CR-4640,
Off. of Nuclear Reactor Regulation, U.S.  Nuclear Regulatory Commission,
Washington, DC.

Federal Computer Performance Evaluation and Simulation Center (FEDSIM),
1981. Computer Model Documentation Guide.  NBS Special Publ. 500-73,
Inst. for Computer Science and Technology, Nat. Bur.  of Standards, U.S.
Dept. of Commerce, Washington, DC.

Gass, S.I., 1979. Computer Model Documentation:  A Review and an
Approach. NBS Special Publ. 500-39, Inst. for Computer Science and
Technology, Nat. Bur. of Standards, U.S. Dept. of Commerce, Washington,
DC.

Hawking, S.W., 1988.  A Brief History of Time:  From  the Big Bang to
Black Holes.  Bantam Books, New York.

van der Heijde, P.K.M., and M.S. Beljin, 1988. Model  Assessment for
Delineating Wellhead Protection Areas. EPA 440/6-88-002, Office of
Ground-Water Protection, U.S. Environmental Protection Agency,
Washington, DC.

van der Heijde, P.K.M., 1989. Quality Assurance and Quality Control in
Groundwater Modeling.  GWMI 89-04. Internal.  Ground Water Modeling
Center, Holcomb Research Inst., Indianapolis, Indiana.
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HE92       van der Heijde, P.K.M., and O.A. Elnawawy, 1992.  Compilation of Ground-
            water Models.  GWMI 91-06.  International Ground Water Modeling Center,
            Colorado School of Mines, Golden, Colorado.

KO92       Konikow, L.F. and J.D. Bredehoeft, 1992. Ground-water Models Cannot be
            Validated, Advances in Water Resources 15, pp. 75-83.

ME81       Mercer, J.W. and C.R. Faust,  1981.  Ground Water Modeling, Nat. Water
            Well Assoc.,  Dublin, Ohio.

TA85       Taylor, J.K.,  1985.  What is Quality Assurance?  In:  J.K. Taylor and T.W.
            Stanley (eds.), Quality Assurance for Environmental Measurements, pp. 5-11.
            ASTM Special Technical Publication 867, Am. Soc. for Testing and Materials,
            Philadelphia,  Pennsylvania.
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                             6. Passive Institutional Controls

6.1    Introduction

In order to show that the WIPP meets the disposal standards, DOE must demonstrate through
probabilistic risk assessment techniques that TRU waste can be effectively contained for
10,000-years.  Preliminary compliance assessments conducted by Sandia National
Laboratories (the principal scientific advisor to DOE on the WIPP Project) have shown that
certain human-initiated processes and events present the most serious problem in
demonstrating compliance with the disposal standards (SAND 92). These  processes disturb
the geologic and engineered barriers used in the repository to contain the waste.

EPA plans to provide specific guidance regarding human-initiated processes and events in the
compliance criteria being developed  for 40 CFR part  194.  The primary purpose of this
chapter is to provide technical information considered in developing 40 CFR part 194.  40
CFR part 191  contains an"assurance requirement" which is interrelated with evaluation of
human-initiated processes  and events under the containment requirements.  40 CFR 191.14(c)
requires the use of passive institutional controls at disposal systems. Passive institutional
controls are designed to reduce the probability of human-initiated processes and events.  As
stated in the disposal standards:

       "Disposal sites shall be designated by the most permanent markers, records  and other
       passive institutional controls practicable to indicate the dangers of wastes and their
       location" (40 CFR 191.14c).

The disposal standards provide both  a quantitative requirement as to the amount of
radioactivity which can be released to the environment through human-initiated processes and
events and qualitative requirements designed to reduce the probability of such processes  and
events.  This chapter focuses on passive institutional controls.

Passive institutional controls are required to provide additional assurance that geologic
repositories will perform as designed.  In this  section, passive institutional controls are
defined from a regulatory  perspective. The utility of various types of these controls are
assessed in terms of their ability to reduce the possibility of human-initiated processes and
events which may unfavorably alter projected performance.
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6.1.1  Regulatory Background

This sub-section provides the regulatory framework for understanding passive institutional
controls.  The regulation of principal interest is the EPA regulation codified at 40 CFR Part
191 - "Environmental Standards for the Management and Disposal of Spent Nuclear Fuel,
High-Level and Transuranic Radioactive Wastes." The U.S. Nuclear Regulatory
Commission rules involving site markers and records are included for perspective on a
similar regulatory approach.

6.1.1.1      EPA Regulations

"Passive institutional controls" are defined in 40 CFR 191.12(e) as follows (50 FR 38085):

       (1)    permanent markers placed at the disposal site,

       (2)    public records and archives,

       (3)    government ownership and regulations regarding land or resource  use, and

       (4)    other methods of preserving knowledge about the location and contents of a
             disposal system.

Passive institutional controls are one of the assurance requirements specified in 40 CFR
191.14.  The assurance requirements are designed to provide additional confidence that the
containment requirements (40 CFR 191.13) for radioactive wastes are realized.  Since the
containment requirements are based  on probabilistic assessment of radioactive releases over
10,000 years, substantial uncertainty is inherent in the calculational process.  The Assurance
Requirements are qualitative conditions which must be met to counterbalance the quantitative
uncertainties involved in the calculating the magnitude of radioactive releases to the
accessible environment.  As noted in the preamble to the 40 CFR 191 Standards, "Each of
the assurance requirements  was chosen to reduce the potential harm from some aspect of our
uncertainty about the future" (50 FR 38072).

The specific regulatory requirement  stipulating the use of passive institutional controls is
included as 40 CFR 191.14(c).  It states:

       "Disposal  sites shall be designated by the most permanent markers, records,
       and other passive institutional controls practicable to indicate the dangers  of
       the wastes and their location."

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One of the principal roles for passive institutional controls is to reduce the probability of
inadvertent humaa-initiated processes and events from affecting the repository at some future
time. Therefore, the possibilities that government control of the repository will be abrogated
at some future date and institutional knowledge of the repository will be lost must be
considered.  Periodic maintenance should not be an element of these passive controls.
6.1.1.2       NRC Regulations


NRC regulations covering disposal of high-level wastes in geologic repositories also require
the use of site markers and records (10 CFR 60).  License applications must contain a Safety
Analysis Report which includes:


       (8) A description of the controls that the applicant will apply to restrict access and to
       regulate land use at the site and adjacent areas including a conceptual design of
       monuments which would be used to identify the controlled area after permanent
       closure (10 CFR 60.21c).


When the repository is ready for permanent closure, a license amendment must be obtained
which provides:


       (2) A detailed description of the measures to be employed - such as land use controls,
       construction of monuments, and preservation of records  - to regulate or prevent
       activities that could impair the long term isolation of emplaced waste within the
       geologic repository and to assure that relevant information will be preserved for
       future generations.  As a minimum, such measures shall include:

              (1) Identification of the controlled area and geologic repository operations area
              by monuments that have been designed, fabricated, and emplaced to be as
             permanent as practicable;	(10 CFR 60.51a).


6.1.2  General Background


A 1984 study conducted by the Human Interference Task Force for the Office of Nuclear
Waste Isolation (ONWI 84) concluded that long term  communication is the  primary  method
for reducing the likelihood of human-initiated processes and events at nuclear waste
repositories (Gillis 85).  Vehicles for such communication can involve both markers and
records.  The two are closely intertwined. A limited  record can be inscribed on a marker, a

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marker can designate the location of an on-site vault containing records, or a marker can
specify off-site archives where records are located.

The ONWI Task Force assorted that, for messages on markers to be communicated, they
must be detectable, durable, comprehensive, conveyed at several levels of sophistication and
imparted by several techniques.  The logic diagram developed by the Task Force to provide a
framework for modeling future communication, taken from ONWI 84, is presented in Figure
6-1.

Assuming the markers  survive and the messages inscribed on them remain legible, several
scenarios can be postulated. If society either continues to advance technically or remains
static, the message may be understood and may serve as a deterrent to intrusion.26
However, it is likely that the inscribed message will be understood at the site only if the
message is periodically updated.   Sebeok relates a widely accepted generalization in the field
of semiotics (communication through signs); namely, all natural language and human
communication systems change over time (Seb 84). An example can be drawn from the
evolution of the English language.  Current comprehension of Middle English' (ca. 1,100 -
1,500 A.D.) is limited and general comprehension of Old English (ca. 400 - 1,100 A.D.) is
virtually non-existent.  It has been estimated that only about 12 % of basic English words and
an even lower percentage of complex  vocabulary items will exist in 12,000 A.D. (Givens
82). The Nordic Committee for Nuclear Safety Research  (NKS) provides an interesting
example of this English language change over the past 600 years by presenting a quotation
from "Sir Gawain and  the Green Knight" written in about 1375 A.D. (NKS  93):

       The stele of a stif staff the stume hit bi gripte
       That was wounden with iron to the wandes ende,
       And al bigraven with grene in  gravios werkes.27

If society regresses, then the message may not be understood. It is possible that such a
society would not have the technology or the motivation to intrude into a deep geologic
repository. However,  a less advanced society might take actions which could represent
   M In the context used here, society refers to modern, technically advanced people. It is recognized that the
current population of the world covers the gamut from stone age to computer literate cultures.

   27 The grim man gripped it by its great strong handle, which was wound with iron all the way to the end,
And graven in green with graceful designs.

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                                                                            Reduce the likelihood of
                                                                            human Interference
                                                                                                                               OBJECTIVE
                                                                                                                           Protect future societies
                                                                                                                           against hum MI Interference
                                                                                                                           in nuclear waste repositories
                                                                                                                                                  I
                                                                                                                               Reduce the consequences
                                                                                                                               of human Interference
                                             Likelihood cm be reduced
                                             by site related considera-
                                             tions to reduce incentives
                                              Likelihood can be reduced
                                              by effective communication
                                              over a long time period
                                           Likelihood can be reduced
                                           by effective communication
                                           over a lon| time period
                                                                   NiiuraJ and engineered
                                                                   barriers to waste migration
                                                                   presently the focus or
                                                                   siting and design siudlei
                                                                   would also mklgate
                                                                   against human Induced
                                                                   re leases
               Effective communication
               requires message
               comprehension
                                              The communkatlon system
                                              rruซt be designed to elicit
                                              the desired response
                                                                             Communication must
                                                                             continue over long
                                                                             time periods
                                                                             (durability)
Mcuages must be Inter^
pretable over long time
periods
Messages must be within
the reader's level of
understanding
Messages must appear
relevant lo the reader
The communication system
must warn of the conse-
quences of interference
activities
Long-lasting techniques
must be used
                                                                                                               Communication system
                                                                                                               must be easily detected
A variety of tnnsmiulon
techniques must be used
Messages must be perceived
by several sensory techniques
(human/Instrument)
                                                                            Messages must contain
                                                                            sufficient Information to
                                                                            produce the desired result
                                                                                                             Redudancy In Individual
                                                                                                             techniques must be used
Remote and local
perception must be
possible
                                                                                                                                       Redundancy in techniques
                                                                                                                                       lo enhance observation/
                                                                                                                                       perception must be used
                                                                                 Figure  6-1  Human  Interference Logic  Flow

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indirect interference with a geologic repository.  One example would be the development of
large scale irrigation or reservoir projects which could disrupt ground water flow patterns
(ONWI 84).  Large scale irrigation has been employed since antiquity.  Durant noted that
extensive irrigation was used by the ancient Sumerians beginning about 4,000 B.C.  This was
the cornerstone upon which the Sumerian culture was built (DUR 54, p. 124).

If society regresses and then advances to a state of civilization akin to today's society, the
new society might not understand any message which survives on the site markers.
Language continuity may be lost.  Future linguists might be able to decipher the marker
inscriptions, but timing and knowledge of such decoding at the repository site might not be
contemporaneous with  the intent to explore for resources. The roles of markers and
messages and the extent to which they  may be expected to persist will be  discussed more
fully in subsequent sections.

Any study  of this kind which deals with human behavior requires a cautionary note
reminding  us of human fallibility.  A quotation from a work by the anthropologist Claude
Levi-Strauss presented in a recent report provides such a humbling reminder about the limits
of our intellectual prowess:

       "Every civilization tends to overestimate the objective nature of its own thought and
       this tendency is never absent. "28

The following sections discuss the four types of passive institutional controls identified in the
40 CFR 191 standards, viz.,  (1) permanent markers, (2) public records and archives, (3)
government ownership and regulations, and (4) other methods of preserving knowledge about
the disposal system. It should be noted that records can be  located either on-site or off-site.
Since on-site records are closely tied to markers, they will be discussed with markers in
Section 2,  while off-site records will be considered in Section 6.3.

€.2    Permanent Markers

Permanent markers are the foundation  of any passive institutional control  strategy. This
section includes examinations of archeological monuments to provide an historical
   28 Quotation is from The Savage Mind by C. Levi-Strauss, Weidenfeld and Nicolson: London, 1966, page 3
and cited in Reference NKS 93 to this report.

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perspective on the persistence and understood purpose of various monuments.  Examples of
monuments and megaliths which have withstood the ravages of time and man and whose
purpose is clearly understood are described. Also, ancient structures which have not
persisted and/or been understood are described here to the extent possible.  There is clearly a
paradox in this type of inquiry.  Those monuments and messages which have disappeared
without a trace are cannot be analyzed.  Programs conducted by various  government
agencies related to the marking of waste repositories are discussed.  The merits of a no-
marker strategy are briefly recounted, although such a strategy would not be acceptable from
a regulatory viewpoint.  As mentioned previously, the discussion of permanent markers also
includes the messages embodied in or contained on the markers.

This section focuses on permanent surface markers.  Underground markers are considered in
Section 6.5.

6.2.1  Archeological Analogues

6.2.1.1      Introduction to the Review of Archeological Analogues

DOE has long recognized that the  study of ancient markers or monuments may provide
insight into the effectiveness of passive markers. At the very least,  WIPP planners can
learn about materials and forms  of construction which are expected  to last for very long
periods of time.  Beyond this, it is conceivable that  the study of ancient monuments can
provide information on how to best encode messages and build markers in order to clearly
convey a message to future civilizations that may be very different from our own.

In 1982, DOE's Human Interference Task Force (HTTP) engaged The Analytic Science
Corporation (TASC) to develop recommendations of marker design  based on a study of
selected archeological sites.  The resulting technical report by Maureen P. Kaplan (Kap 82)
considered the pyramids of Egypt, Stonehenge in England, the Nazca Lines in Peru, Serpent
Mound in the United States,  the Acropolis of Athens, Greece, and the  Great Wall of China.
Kaplan's study of message transmission  and its most enduring vehicles continues  to serve
DOE as WIPP planning proceeds.

Kaplan classified potential messages regarding the WIPP into four levels:
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       • Level I:   Attention getter, i.e., "something is here."

       • Level HI   Attention getter and warning, i.e., "something is here and it is
                   dangerous."

       • Level ffl:  Basic information, i.e., what, who, when, why, what actions to avoid,
                   and where to find information.

       • Level IV:  Full record of information, i.e., plans, drawings, environmental impact
                   statements, etc.

Kaplan pointed out that "the medium of the message  may determine the level of information
the marker can convey." An earthwork, for example, can convey little beyond a Level I or
perhaps a Level n message. On the other hand, the  media usually employed to convey Level
IV messages (paper, plastic, metal, electronic media) are not nearly  as likely to survive the
millennia as is an earthwork.

Kaplan emphasized the importance of identifying the audience to whom a message is
addressed and the undesirable  actions to be warned against.  She went on to discuss such
actions.  She concluded that "the primary emphasis in the marker system design should be on
detection by sight," and noted that "the distance at which the message is  detectable may be
determined, in part, by whether it is desirable to actively call attention to the site or to  warn
people once they have decided to investigate the area."  She discussed various possible
marker designs and message contents, stressing that because "Level IQ and Level IV
information may  only be carried by the written word," it is important to  incorporate written
text into  on-site monuments and to store records elsewhere as well.

Kaplan's study has formed the primary basis for the  analysis of the same monuments that
appears below, so it need not be summarized here. Among her important observations were:

       •  Monuments that require no active maintenance survive best;

       •  Monuments made of stone or earth survive best;

       •  Metals are  not suitable marker materials;  they tend to be recycled;

       •  Markers should be shaped and sized to minimize their potential for reuse;

       •  The majority of ancient monuments were meant to  be detected by sight, at  ground

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           level;

       •   If the component parts of a marker are small, and the public is not excluded from
           the vicinity of the marker, the chance that the marker's message (to say nothing
           of the marker itself) will survive are relatively slim.

A logic diagram formed from these observations concluded that the WIPP marking system
should be comprised of durable, megalithic, monolithic stones with engraved symbols.
Kaplan proposed that if the markers  were to be visible from the air, an earthwork should be
incorporated into the design. A basic design was proposed consisting of outer rings of
monoliths conveying Level I and n information.  The outer rings  surround a tumulus over a
vault in which Level IV information would be stored. Immediately surrounding the vault are
megaliths conveying Level HI information. Kaplan concluded with a discussion of media in
which Level IV information can be encapsulated and of potential designs for the monoliths.

Other HTTP reports relevant to this study include Communication Measures to Bridge Ten
Millennia (Seb 84), Communications Across 300 Generations:  Deterring Human Interference
with Waste Deposit Sites (Tan 84), Reducing  the Likelihood of Future Human Activities That
Could Affect Geological High-Level Waste Repositories (ONWI 84), and Expert Judgement
on Markers to Deter Inadvertent Human  Intrusion into the Waste Isolation Pilot Project
(SAND 93).  The last  report will be addressed in the conclusion of this  section.

In development of the 40 CFR  part 194 proposal, EPA examined a wider range of ancient
monuments than those previously investigated.  Published discussions of twenty-five ancient
monuments and classes of  monuments were examined in an attempt to answer the following
seven questions:

       •   What message(s) were the monument's creators attempting to convey?

       •   Were they trying to convey this message to future civilizations or to their own
           people?

       •   What has been  involved in interpreting the message by  modern scholars?

       •   How sure are we that we have the message right?

       •   If the message  had been "Don't dig here because it is dangerous," is it likely that
           we would have gotten the message before digging there?
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       •  What physical and environmental characteristics have permitted the monument to
          withstand the ravages of time and vandalism?

       •  What physical and environmental characteristics have permitted the monument to
          convey its meaning clearly through the millennia?

In many, if not most cases, the published literature does not contain explicit answers to all of
these questions.  Answers often have to be inferred from the evidence.

In addition to previous monument studies connected with the WIPP (e.g., Kap 82), results
from other studies were used. No new archeological research was conducted which would
most likely would have been  redundant.

Below, each of the 25  monuments and monument classes is discussed with reference to the
seven questions.  Summary observations are made.

6.2.1.2   Pyramids. Mounds, and Other Massive Structures

6.2.1.2.1  The Pyramids of Egypt

Duration:  ca. 4,600 years so far.

Description:   The largest and most famous of Egypt's pyramids are the massive stone
structures  at Giza, near Cairo. The pyramids were built at the direction of three pharaohs,
Khufu, Khafre, and  Menhure (sic. Cheops,  Chephren, and Mycerinus) during the Fourth
Dynasty of Egypt (ca.  2600-2500 B.C.).  They served as tombs for the three rulers.
Associated features include smaller pyramids, temples, other surface structures, subsurface
tombs, and the Sphinx. Some 70 other pyramids exist in Egypt, all  identified as the funerary
monuments of pharaohs,  while many smaller ones were built in Sudan between the eighth
and fourth centuries  B.C. (Kap 82).
•     What message(s) were the monument's creators attempting to convey?

Based on their impressive scale and the results of their long-term study (Kap 82), there is
little doubt that th3 pyramids were intended to convey the greatness of the pharaohs who had

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them built, and probably to honor the gods those pharaohs and their subjects worshipped.
They may also haye been intended to convey the greatness of the Egyptian nation.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

Considering their durable stone construction, the pyramids suggest an  intention to convey the
creators' message to the future. However, there seems to be no reason to think that they had
future civilizations in mind.  It is more likely that the creators anticipated a continuation of
their own civilization.  Future generations of pharaohs would look back and draw inspiration
from the greatness of those who built the pyramids.

•      What has been involved in interpreting the message by modern scholars?

The pyramids  have never ceased to impress visitors with their monumental scale. Therefore,
on one level the message has been  understood automatically, with little need for
interpretation.  Even if one knows  nothing at all about the creators' history, one cannot view
the pyramids without understanding that someone went to a great deal of work to construct
them.  It follows that those responsible must have been "great" in terms of power and
wealth.

Developing  a detailed understanding of the pyramids has required extensive and intensive
study by a tremendous number of scholars over the years (Kap 82).

•      How sure are we that we have the message right?

The message:  "Khufu, Khafre, and Menkure were great" seems so evident in the scale and
setting of the pyramids that it is almost certain  that this very basic message  has come down
to us correctly through the millennia.  There may be other, more subtle, messages that we do
not understand as well, or at all.
•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

In the entrances to some Egyptian tombs, there are explicit warnings against entry, and the

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pyramids themselves, by their massiveness and the way their entrances were disguised and
hidden, were clearly designed to discourage "digging" into them. As far as is known to
date, however, these measures have invariably failed to discourage determined looters and
archaeologists.  Something ~ be it the desire for wealth or the quest for knowledge - has
always overcome the fear of "the mummy's curse."  As society has changed, the belief in
supernatural sanctions  against  entering tombs has diminished.  Even so, the pyramids were
plundered in antiquity  (perhaps 400-500 years after they were built), when such beliefs may
still have been strong (Kap 82).

The plunderers of the pyramids during the First Intermediate Period (2180-2130 B.C.)
presumably did "get the message" that they should not "dig"  into them, but this did not keep
them from digging because, of course, they knew that the tombs contained treasure.
Presumably the warnings would have been more effective had they conveyed both a warning
and an assurance that there was nothing inside.  However, it is hardly credible that people
would  have believed such assurances. Kaplan gives an example  of a Mesopotamian priest's
tomb which was inscribed with not only warnings against committing "an abomination," but
assurances that the tomb contained "no silver..., no gold,  and no jewelry whatever."  When
discovered in modem times, the tomb had long since been looted (Kap 82).

•     What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

Clearly, the shear scale and impermeability of the pyramids have allowed them to withstand
the ravages of time. They have not withstood the ravages of vandalism, though, as Kaplan
notes, the tremendous  number of stones  that make them up has helped prevent them from
being entirely reduced (Kap 82).

•     What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The very basic message of the pharaohs' "greatness" (a term that is subject to multiple
interpretations) has been conveyed by the monumental scale of the pyramids.

6.2.1.2.2  Egyptian Funerary and Temple Monuments

Duration:  ca. 3,000-5,000 years so far.

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Description:,  Monumental surface and subsurface tombs and massive temples and monuments
were constructed by the Egyptian pharaohs and emblazoned with carved and painted
messages in both hieroglyphic text and pictographs. The extensive monumental constructions
of Rameses H (Rameses the Great, ca. 1302-1212 B.C.) are good examples (Gor 91). A
colossal stone bust of the great Pharaoh, removed from Thebes to the British Museum in
1817, was the inspiration for Shelley's sonnet "Ozymandias," which is often quoted in the
WIPP literature (e.g. SAND 93):

       I met a traveller from an  antique land
       Who said:  Two vast and trunkless legs of stone
       Stand in the desert... Near them, on the sand
       Half sunk a shattered visage lies, whose frown
       And wrinkled lip, and sneer of cold command,
       Tell that its sculptor  well those passions read
       Which yet  survive, stampted on these  lifeless things,
       The hand that mocked them, and the heart that fed:
       And on the pedestal these words appear:
       "My name is Ozymandias, king of kings:
       Look on my works ye Mighty and despair!"
       Nothing beside remains.  Round the decay
       Of that colossal wreck, boundless and bare
       The lone and level sands  stretch far away.

Rameses n left very extensive "works," bearing messages that have survived to the present.

•      What message(s) were the monument's creators attempting to convey?

Egyptian funerary and temple monuments usually convey messages depicting the (often
exaggerated) exploits of the  pharaohs, major events during their reigns, and important events
in  Egyptian religious tradition.

•      Were they  trying to convey this message to future civilizations, or to their own
       people?

Many temple  and  tomb monuments may  have been intended to communicate with the
Egyptian gods.  The architecture of the monuments was  also presumably designed to

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impress, inform, and awe contemporary native and non-Egyptian populations.  Tomb art and
texts, buried away out of mortal sight, may have been intended to communicate respect for
the deceased, to the creators themselves, or to the gods.  These buried treasures may have
also been intended to memorialize in perpetuity the life and deeds of the deceased.  Thus,
there must have been an intention to communicate with the future, but there is nothing to
indicate that the creators of tomb art and texts envisioned communicating with future
civilizations different from their own.

•      What has been involved in interpreting the message by modern scholars?

Egyptian tombs and temples have been subjected to intensive archeological study for some
two hundred years.  A pivotal event in interpreting the messages left by the ancient
Egyptians was the discovery of the Rosetta Stone — a slab of basalt containing the same text
inscribed in hieroglyphics, a later Hieratic script, and Greek — by soldiers of Napoleon's
Egyptian campaign in 1799.  The linguist Jean Francois Campollion required fourteen years
to decipher the hieroglyphic characters; his translation was the break-through that opened
communication between ancient Egypt and modern scholarship.

•      How sure are we that we have the message right?

Understanding the explicit message  of ancient Egyptian texts is obstructed only by the often
incomplete nature of the monuments on which they are inscribed. Since most paintings and
engraved pictures are accompanied by texts, their interpretation is usually fairly certain as
well.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before  digging there?

Excavations, both for purposes of scholarship and for plunder, were conducted in Egypt long
before the Rosetta Stone was translated. Indeed, many tombs were apparently plundered
within a generation or two after they were sealed, often despite explicit warnings not to do so
on pain of supernatural sanctions.  However,  if archaeologists today were to come upon an
Egyptian monument inscribed with a warning  against digging, it is certain that the message
would be understood promptly.

•      What physical and environmental characteristics have permitted the monument to

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       withstand the ravages of time and vandalism?

To the extent temples and other surface monuments have survived, they have done so
because of the massive stones of which they were built and Egypt's arid environment.
Tombs and other subsurface monuments, including wall paintings, have also survived
because of these factors.  In addition, their buried condition protected them from erosion.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The same characteristics that have preserved the monuments have preserved the paintings and
inscriptions that convey messages from ancient Egypt to the present.

6.2.1.2.3 Monuments  of Mesopotamia

Duration: Up to ca. 6,000 years so far.

Description:  The ancient Sumerians, Babylonians,  Assyrians,  and other civilizations of
Mesopotamia (roughly, modern Iraq) constructed major urban centers with extensive
fortifications and religious and secular buildings. Emblematic of the Sumerians, and to some
extent, their successors was the ziggurat, virtually a constructed mountain made of brick,
topped with a religious structure.  Some ziggurats rivaled the Egyptian pyramids in scale.
Most Mesopotamian buildings were made of mud brick, so their upper parts have  tended to
collapse, forming mounds or "tells." Foundations and lower rooms are often preserved
within these tells, as are the remains of older buildings that were covered by later
construction.  Fired clay tablets containing written material in  cuneiform script are commonly
found in Mesopotamian tells, as are elaborately carved statuary and bas-relief panels
portraying rulers, wars, rituals, and aspects of daily life (Woo 63; Mai 65).

•      What message(s) were the monument's creators attempting to convey?

Cuneiform writing, both on tablets and on monuments,  transmitted historical data, religious
observations, proclamations of law, and political propaganda.  Tablets also contain more
humble  writings such as inventories, financial accounts, textbooks, and student's essays.
Huge structures such as palaces and ziggurats were presumably intended to impress the
viewer and, in the case of the ziggurat,  to convey a sense of religious awe.

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 •     Were they trying to convey this message to future civilizations, or to their own
       people?

 Some Mesopotamian monuments were rather explicitly addressed to the future. For
 example, around 500 B.C. the Persian emperor Darius had the following inscribed in
 cuneiform script in three languages (Old Persian, Elamite, and Akkadian) on the Rock of
 Bihistun along the caravan road  between Babylon and Ecbatana:

                                Saith Darius the King:
                               Thou  \vho shall hereafter
                                Behold this inscription
                                  Or these sculptures,
                               Do thou not destroy them
                                  (But) thence onward
                                 Protect them as long
                           As thou shall be in good strength.

 Having at the time some three thousand years of rising and falling civilizations to look back
 upon, and having extensive contact with cultures other than his own (e.g. the Greeks),
 Darius may certainly have contemplated the idea of communicating with other civilizations in
 the distant future. For the most part, however, Mesopotamian monuments appear to  have
 been designed to communicate information, ideas, directions, and impressions  to both the
 people of the communities in which they existed and to surrounding contemporary groups.

 •     What has been involved in interpreting the message by modern scholars?

 Archeological research, including major excavations,  has been conducted extensively  in
Mesopotamia for over a century. One major breakthrough occurred in the late 1830s, when
Henry  C. Rawlinson was successful in translating the cuneiform script on the Rock of
Bihistun. An excavation uncovering the library of Nineveh in the 1850s produced some
25,000 tablets that provided a rich source of messages from the ancient  Assyrians.
Increasing scholarly fluency in reading cuneiform script has been the key to interpreting such
messages.

 •     How sure are we that we have the message right?

Scholars can be quite certain that they understand  straightforward written messages correctly.

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Religious parables and the propaganda of warriors and rulers, however, are less firmly
understood.

•      If the message had been "Don't dig here because it is dangerous,11 is it likely that we
       would have gotten the message before digging there?

Because of increased fluency in reading cuneiform script, this message would certainly be
understood.  However, many excavations took place in Mesopotamia before scholars became
familiar with cuneiform.  Moreover, since most cuneiform records are buried, it is
impossible to read their messages without digging.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

Since the mud-brick structures of the Mesopotamian cities have collapsed, they have not
entirely withstood the ravages of time.  They have also been the victims of extensive
vandalism.   Their massive scale has protected their lower rooms, however, as upper walls
have settled  down over them and become stabilized. Monuments carved on hard stone have
survived well, as have tens of thousands of fired clay tablets of cuneiform script.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The fact that cuneiform texts were both inscribed on stone monuments and imprinted on
fired-clay tablets has been the key to understanding the messages of the ancient
Mesopotamian.

6.2.1.2.4  Great Wall of China

Duration:  ca.  2,200 years so far.

Description:  Begun by Emperor Ch'in Shih Huang Ti between 221 and 210 B.C. and
significantly  rebuilt during the Ming Dynasty (1568-1644 A.D.), the Great Wall winds across
some  1,850  miles of northern China.  It is a massive linear structure with a tamped earth
interior faced with cut and dressed stone (Kap 82).
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•     What message(s) were the monument's creators attempting to convey?

The Great Wall Was a defensive structure, designed to help protect China from northern
invaders (Kap 82). While the Great Wall was designed to meet a specific defensive need
rather than to convey a message, it was doubtless assumed that the Great Wall would convey
a very accurate message of invulnerability to those who might be tempted to assault it.
•     Were they trying to convey this message to future civilizations, or to their own
      people?

There appears to be no reason to think that the Chinese emperors were trying to convey any
kind of message to future civilizations. They were simply trying to discourage invaders.

•     What has been involved in interpreting the message by modem scholars?

The Great Wall has appeared since the beginning of Chinese literature (Kap 82).  The written
and oral historical record of Chinese history  has survived through the centuries, so the
function and history of the Great Wall have never been altogether lost.  Modern
archeological research has elucidated details of its history and the methods employed in its
construction (Kap 82).

•     How sure are we that we have the message right?

Since the Great Wall was not explicitly designed to convey a message, this question is of
marginal relevance.  However, the Great Wall is a  good example of a monument that
conveys what Kaplan refers to as a Level n message:  "Something is here and it is
dangerous." At least, that was certainly the  message the Great Wall was intended to convey
to would-be invaders.

•     If the message had been "Don't dig here because it is dangerous," is it likely that we
      would have gotten the message before digging there?

The Great Wall was designed to convey a Level n  message to would-be invaders, not to
future civilizations.  It no longer conveys the same message,  because the relevant bits of
information that made up the message -- fighters on the parapets with weapons at the ready -

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are no longer there.  The modem visitor is typically a local resident or a tourist, not an
invader.  Modern potential invaders (e.g., the Japanese in World War H) have not perceived
a Level n message of the Great Wall because modem technology has virtually eliminated the
wall's defensive utility. Nothing in the Great Wall's message has kept it from being
subjected to quarrying  for building material, broken down for agricultural purposes, and
pierced by transportation projects, archeological excavation, and other indignities.  There
appears, to be no reason to think that if the Great Wall had been designed to discourage
digging,  it would have been effective in doing so.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

Its massive character has played a crucial role in the Great Wall's preservation. However, it
has suffered serious deterioration at many points along its length because it is made up of
millions of individual stones (Kap 82).

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The "message"  of the Great Wall remains clear  today because of the written record, but it is
likely that even if that record did not exist — it would be readily interpreted as a defensive
feature.  A wall with battlements and towers can be interpreted - by the human mind, at
least - as little other than a defensive structure.

However, this ease of interpretation may result from the contemporary world's temporal
proximity to the pre-industrial age, vis-a-vis the world of 10,000 years in the future.  Today
we understand a massive wall to be a defensive  structure because our traditions embrace the
time when such walls served real defensive purposes.  A modern military installation is
typically  not massively walled.  Its defence lies in its firepower and the firepower (terrestrial
and aerial) that backs it up.  Whether a wall would be understood as a defensive feature
10,000 years in the future is questionable, particularly considering all the non-defensive
"walls" our civilization has built (e.g., expressways elevated on fill).

Its extensive treatment in written Chinese history and literature also has permitted us to
understand readily the purpose of the Great Wall. Like the pyramids of Egypt, a good deal
is known about the purpose of the Great Wall because of the writings of those who built it

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and of those who followed. Luckily, these writings have survived to the present day
(Kap 82).

Kaplan makes an important point about how the Great Wall has continued to convey its
message when she notes that "the Great Wall is an example of a marker which has been
maintained and rebuilt for two millennia because it served a purpose."  She goes on  to point
out that "as such it shows the potential survival of the repository markers, since they also
serve a protective function" (Kap 82).  The Great Wall has not been an entirely passive
marker.  It has been repeatedly rebuilt and at least sporadically cared for. This is an
important reason that its message has survived for over two thousand years.

6.2.1.2.5  Pyramids and Related  Monuments of Mesoamerica

Duration:  Up to ca.  3,000 years so far.

Description:  Pyramids were common in the urban centers of prehistoric Mexico, Guatemala,
and Belize.  The oldest known date back to the Olmec, whose  civilization developed some
3,000 years ago  along the Bay of Campeche (Stu  93). The largest known, the Pyramid of
the Sun at Teotihuacan in the Valley of Mexico, is over 60 meters high and over 200 meters
square at the base (Mil 73).  Mesoamerican pyramids tend to have been built in stages,
beginning as relatively modest structures that were covered up  by subsequent constructions.
Typically  each such pyramid has  a core of rubble (and smaller pyramids), faced with cut and
dressed stone. They  are invariably parts of planned urban areas made up of numerous
smaller pyramids and other structures laid out according to strict geometric principles.   These
structures are often associated with monolithic stone stelae, other statuary, carved and
painted wall art and convey information approximating Levels  HI and IV (e.g. Stu 89).  By
about 200 A.D., the Maya had a well-developed calendrical system associated with extensive
astronomical and mathematical knowledge. They had a well-developed glyphic writing
system that included elements of  ideographic, phonetic, and morphological writing.  Texts
and ideograms were often engraved, painted, and  expressed in  bas-relief on temples,
pyramids, stelae, and altars (Par  86; Ivan  75).

•      What message(s) were the monument's creators attempting to convey?

The pyramids and related monuments were almost certainly intended to convey a message of
grandeur and power both to the resident populations of the surrounding areas and to potential

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foes.  The overall plans of the cities and the detailed designs of the pyramids and other
structures were defined significantly by astronomical, topographic, and geometric principles.
These principles were probably encoded in ritual "and served as metaphors for the social
structure and power hierarchy of the community.  The richness of the message was enhanced
by stelae and other art forms with hieroglyphs conveying information about precisely dated
historical events.  A number of the stelae appear to record great feats or the history  of a
ruler or a site.   They frequently contain information regarding events related to the  Mayan
calendric cycle, as well as information of historical and religious natures.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

The astronomical nature of many Mesoamerican monuments suggests an intent to
communicate with celestial gods.  Other messages, such as historical records, were
presumably for the benefit of those using the monuments as places of study and worship.
There may also have been an intent to discourage enemies. The preoccupation of many
Mesoamerican societies with chronology, reflected in the detailed historical records bound up
in their art forms, suggests that they might have had an interest in conveying messages to the
future, but there is no evidence to  suggest that they conceived of the future as being  anything
other than a  continuation of what was then the present.

•      What has been involved in  interpreting the message by modern scholars?

Deciphering  the messages bound up in the pyramids and other structures of Mesoamerica has
required very extensive archeological, historical, and ethnohistorical research spanning over a
century.  Pyramids have been extensively excavated, bored into, and reconstructed.  Stelae
and other sculptures have been removed for study and display.  Less destructive methods
have included photography and making tracings and rubbings.

•      How  sure are  we that we have the message right?

There is a considerable  amount of scholarly controversy over the interpretation of many
messages from Mesoamerican prehistory.  For example, there is controversy over whether
many of the  apparent urban  centers were in fact residential loci or if they functioned purely
as religious and political centers.   Extensive research into Mesoamerican calendric and
numerical systems and glyphic writing has made the Maya  better known than most

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prehistoric groups in the Americas. However, much room remains for debate about what the
messages on the stelae and pyramids mean.

•     If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

Extensive digging has been a basic component in understanding Mesoamerican messages.
Digging went on long before Mayan glyphic writing was deciphered.

•     What physical and environmental characteristics  nave permitted the monument to
       withstand the ravages of time and vandalism?

The use of hard stone, large blocks, and cement mortar have all contributed to survival.  The
very density of many structures has protected interior features.  All Mesoamerican
monuments have experienced substantial erosion, but this has tended to stabilize after an
initial period of major deterioration, allowing a great deal of information about the structures
to be preserved.  The very speed with which local vegetation swallows up even large features
has protected some monuments from weathering. It has been possible to restore many
pyramids to something approximating their original condition.  Mesoamerican sites have
experienced and continue to experience tremendous vandalism, primarily by treasure-seekers
and looters serving the international art market.  Petrochemical  industrial pollution is also
taking  a serious toll on Mesoamerican monuments today.

•     What physical and environmental characteristics  have permitted the monument to
       convey its meaning clearly through the millennia?

To the extent that the message has been conveyed clearly, six factors seem to be involved.
First, the massive character of the pyramids and other structures both permitted them to
survive and protected the stelae and other objects associated with them. Second, stelae and
other sculptures were often carved from very hard stone, which has tended to survive the
onslaught of the elements (though not those of human beings).   Third, the high level of
redundancy represented by the scores of urban centers, hundreds of pyramids and other
structures, and thousands of information-bearing stelae and sculptures has provided a rich
basis for comparative research.   Fourth, the fact that many "messages" were related  to
unchanging phenomena such as numbers and astronomical phenomena has made it possible
for modem scholars to relate current knowledge with the messages. Fifth, the Mayan and

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other cultures of the area were still using their writing systems when the Spanish invaded.
This resulted in some records being preserved and translated (though the vast majority of
written records were burned as works of the Devil). Finally, in many cases, modem
populations of the area are directly related  to the builders of the cities.  Therefore,
substantial information from the past  has been encoded in modern ritual and tradition.

However, it must be stressed that contemporary scholarship still has only an inkling of what
the monuments of Mesoamerica meant to those who built and used them.  This amount of
understanding has required a colossal amount of research by thousands of scholars around the
world.

6.2.1.2.6 Adena and Hopewell Mounds

Duration: Up to ca. 3,000 years so far.

Description: The prehistoric Adena and Hopewell cultures of the Ohio Valley and its
environs built large earthen mounds in many locations.  Uses for these mounds included
housing log tombs,  serving as the base for  temples and other structures, and serving as
effigies.  Kaplan provides details on one of the best known Adena mounds, Serpent Mound
in Ohio (Kap 82).

•     What message(s) were the monument's creators attempting to convey?

The messages that mounds like Serpent Mound were intended to convey (if any) are
unknown, though a variety of interpretations have been advanced (Kap 82).  Like other
constructed high places (e.g. the pyramids  of Egypt), Adena and Hopewell burial mounds
and temple mounds were presumably  intended in part to impress people with their scale and
grandeur.

•     Were they trying to convey this message to future civilizations, or to their own
       people?

Aside from the relative permanence of the  mounds, there is no evidence to suggest that their
builders were trying to communicate with the future, and certainly none to suggest that they
had civilizations other than their own  in mind.

•     What has been involved in interpreting the message  by modern scholars?

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Adena and Hopewell mounds have been extensively excavated by archaeologists and others in
efforts to decipher their function.

•     How sure are we that we have the message right?

Since the message of the mounds is not known, it follows that contemporary scholars do not
have it right.

•     If the message had been "Don't dig here because it is dangerous," is it likely that we
      would have gotten the message before digging there?

As noted, Adena and Hopewell mounds have been extensively excavated, precisely because
they are prominent features on the landscape and people are interested in determining what
they mean.

•     What physical and environmental characteristics have permitted the monument to
      withstand the ravages of time and vandalism?

The Adena and Hopewell mounds have survived because of their massive earthen
construction. However, they have not survived without damage, and some have been
destroyed altogether by erosion,  earth quarrying, and artifact digging.

•     What physical and environmental characteristics have permitted the monument to
      convey its meaning clearly through the millennia?

The mounds have not conveyed their meaning clearly through time.

6.2.1.2.7 Mississippian Mounds

Duration: ca. 1,000 years so far.

Description:  During the Mississippian Period, Native American populations created
substantial urban centers featuring complexes of pyramidal earthworks along the Mississippi,
Illinois, and Ohio Rivers and their tributaries. The largest known is Monk's Mound at
Cahokia in East St. Louis, Illinois (Fow 78).  Moundville in Alabama is another well-known
Mississippian urban complex (Wei 91). Mississippian civilization and its construction of

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mounds reached an apex during the 13th century A.D., when its influence was felt
throughout eastern North America.  The large, flat-topped mounds are thought to have been
the bases for temples or for the residences of chiefs or priests.

•      What message(s) were the monument's creators attempting to convey?

Like the Mesoamerican pyramids that are thought to have influenced Mississippian mound
builders, the mounds were presumably places of worship, designed to communicate with the
gods as well as to awe both the local populations and potential enemies.

•      Were they trying to convey this message to  future civilizations, or to their own
       people?

While the construction of such huge edifices suggests an intent to create something long-
lasting, there is nothing to suggest that the Mississippians were seeking to communicate with
future civilizations.

•      What has been involved in interpreting the message by modem scholars?

Mississippian urban centers have been subjected to  extensive archeological survey and
excavation.  Historical data are also helpful in interpreting them, because Mississippian-
related cultures were still intact and using mounds at the time of the European invasion.

•      How sure are we that we have the message right?

Although much is known about Mississippian settlement patterns, trade systems,  status
organization, and economics, it cannot be said that  contemporary scholarship understands the
messages (if any) that the Mississippians embedded in their mounds.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

No.  The Mississippian mounds have been subjected to extensive excavation and vandalism.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?
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Like other massive earthworks, the Mississippian mounds have survived simply because of
their size and density. However, many have succumbed to land-leveling, earth quarrying,
agriculture and urban expansion.

•     What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The Mississippian mounds have not conveyed their meaning clearly.

6.2.1.2.8  Wisconsin Effigy Mounds

Duration:  400-1,900 years so far.

Description:  The earliest known  effigy mounds in Wisconsin date from about 100 A.D.,
while others were built as late as  1400 A.D.  Most were constructed between about 670 and
1100 A.D.  Most of these mounds are in the shape of an animal, including birds, bears,
turtles, and panthers.  Some are found in groups and are associated with other mound shapes
— conical, linear, and irregular.  Most mound groups show evidence of at least short-term,
seasonal human occupation, and some are associated  with substantial prehistoric villages.
Many of the mounds appear to have been built in stages, and some show evidence that they
were maintained over time. Burials, artifact clusters, and other features are found in the
mounds, but do not seem to be central to their function (Hur 75).

•     What message(s)  were the monument's creators attempting to convey?

Because of the debatable nature of the meaning of the effigy mounds, many archaeologists
tend to avoid the question altogether.  Generally, the mounds are believed to be symbolic
representations, not just  expressions of artistic design. They are thought to have ceremonial
functions,  but what these may have been is unknown. The mounds may be associated with
particular social groups,  such as clans or ritual societies.  The specific messages they were
intended to convey, if any,  are not known.

•     Were they trying to  convey this message to future civilizations, or to their own
       people?

The mounds tend to be interpreted as attempts to communicate with the gods,  spirits,  or

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ancestors, but this theory is largely speculative.  Their relatively permanent character
suggests a desire to communicate a message of some sort to people in the future, but there is
nothing to indicate an attempt to communicate with cultures other than those of their builders
and surrounding groups.

•      What has been involved in interpreting the message by modern scholars?

Remote sensing, archeological survey and excavation, coring of mounds and excavation of
associated living sites have all been involved in interpreting the mounds.

•      How sure are we that we have the message right?

Demonstrably, contemporary scholars do not have the message right.

•      If the message had been  "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

No. it is difficult to see how earthworks could convey such a message.  Excavations have
been fairly extensive in and around the mounds.

•      What physical and environmental characteristics have permitted the monument to
       withstand'the ravages of time and vandalism?

Like other massive earthworks,  the effigy mounds  have survived largely because of their
scale and stability.  Some show  evidence of accretion, suggesting that they were  maintained
over time, thus  contributing to their survival.  The mounds  are also quite abundant, so  sheer
redundancy has permitted many  to survive even though many have been lost to agriculture,
erosion, and other agents of destruction.

•      What physical and environmental characteristics have permitted the monument to
       convey its  meaning clearly through the millennia?

The messages of the mounds (if any,- have not been clearly  conveyed.
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6.2.1.2.9  John East Mound, Virginia

Duration:  ca. 1,000 years so far.

Description:  The John East Mound is  an accretional earth/stone burial mound on the left
bank of the Middle River in Augusta County, Virginia (Val 86). It is representative of
numerous burial tumuli constructed by a variety of prehistoric cultures in eastern North
America.

•      What message(s) were the monument's creators attempting to convey?

The mound appears to have been intended to convey the message that  important people were
buried here; this is conveyed by its scale (ca. 45 x 55 feet) and the association of "marker"
stones on  and near the site. The marker stones have been interpreted  as indicating the
mound's continuing use (ca. 1240-960  A.D.) as a burial place.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

There is no evidence to suggest that the builders of this and other similar burial  mounds
intended to convey a message to  anyone other than their contemporaries and descendants.

•      What has been involved in interpreting the message by modern scholars?

Interpretation has relied on the excavation of the mound and comparisons of excavations of
similar mounds.

•      How sure are we that we  have the message right?

Interpretation is based on analysis of the archeological evidence. One can be reasonably sure
that the basic message ("This is a burial place") has been correctly interpreted, but beyond
that, interpretation is largely speculative.

•      If the message had beeij "Don't dig here because it is  dangerous," is it likely that we
       would have gotten the message  before digging there?

If the mound was intended to discourage digging, it has certainly not succeeded. On the

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contrary, it has attracted excavators.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

Earthworks like this one are fairly stable.  They erode slowly over time, but retain their
essential form.  It is unlikely that an  earthwork of this scale would last 10,000 years,
however.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

Mounds like this have conveyed only their most basic messages into the present.  Earthworks
are inherently incapable of conveying more than the equivalent of a Level n message.

6.2.1.3   Megalithic Monuments

6.2.1.3.1  Stonehenge

Duration:  ca.  4,500 years so far.

Description: The most complex of Britain's roughly 900 known stone circles, Stonehenge is
composed of standing megaliths, capstones, and earthworks on the Salisbury Plain in
England.  It is thought by many (though not all) scholars to  have been used to make
astronomical observations, probably in order to predict events of importance to the
prehistoric agricultural economy and  to the religious beliefs and practices of the community
(Kap 82).

•      What message(s) were the monument's creators attempting to convey?

It is not altogether certain that Stonehenge's builders were trying to convey any message at
all. If its  purpose was to serve as an astronomical observatory (Haw 63), this utilitarian
function may have been  predominant. If Stonehenge's purpose is religious (which is
certainly likely, and not  inconsistent with its astronomical functions), then its structure may
have been intended to convey some sort of ideological message to worshippers, but scholars
are uncertain about what the message was  (cf. Bur 76).
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•      Were they trying to convey this message to future civilizations, or to their own
       people?

That the builders of Stonehenge intended the structure to last into the distant future is
strongly implied by the effort put into its construction.  It is built of very durable stone,
much of it brought in from considerable distances (Kap 82).  There is nothing to suggest,
however, that Stonehenge was built in order to convey a message to civilizations other than
their own.

•      What has been involved in interpreting the message by modern scholars?

Stonehenge has been the subject of intensive research and speculation for at least 800 years
(Kap  82). Only in the last 30 years,  however, have scholars deciphered its probable
astronomical functions (e.g. Haw 63, Hoy 66).  The "messages" that convey this function are
not necessarily interpreted in the same way by all who "read" them (e.g. Atk 66).

•      How sure are we that we have the message right?

The weight of evidence suggests that Stonehenge did have an astronomical function, probably
among other functions that were then related conceptually to the observation of heavenly
bodies. There is no indication that the full "message" of Stonehenge, as it was understood
by those who built it, is understood correctly — or at all — today.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

Since the actual full meaning of Stonehenge is not understood, there is no reason to think that
it would have been understood if it had been intended to convey the message "don't dig
here."  Stonehenge has been excavated on  several occasions,  besides being vandalized in
various ways (Kap 82), but this is of little relevance since the monument does not  convey
any warning against excavation or vandalism.

•      What physical and environmental characteristics  have permitted the monument-to
       withstand the  ravages of time  and vandalism?

The size, weight,  and strength of the individual  stones that make up Stonehenge have allowed
them to successfully resist the ravages of time.  Human misuse, however, has resulted in
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significant damage (Kap 82).

•     What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

Stonehenge has not conveyed its meaning clearly into the future, despite its relative
invulnerability to deterioration.  As Kaplan notes, "Stonehenge is a prime example of the
difficulties in marking a site with only Level I information"  (Kap 82).

6.2.1.3.2 West Kennet Long Barrow

Duration: ca. 4,500-5,000 years so far.

Description:  The West Kennet Long Barrow is a complex of stone, chambered tombs under
an earthen tumulus, near West Kennet in Wiltshire, England.  At their entrance is a stone-
walled forecourt which archeological evidence indicates was filled and blocked with large
boulders in about 1600 B.C. (Pig 62).

•     What message(s) were the monument's creators attempting to convey?

The barrow  itself was almost certainly designed to house the physical remains and
possessions of high-ranking deceased individuals.  It contains no overt message in the form
of graphic art or writing. The labor that went into its construction suggests that the barrow
was intended in part  to convey the  importance of those buried  in it to future generations.

Various period pottery styles found in the chambers suggest  that access to the tombs was
possible for  approximately a thousand years.  Bones may have been removed from the tombs
for ritual usage (Pig  62).  Around 1600 B.C., however, the  forecourt was filled and blocked
with large "sarsen" boulders. The  size of the boulders suggests the message:  "Keep Out!"
Based on available evidence, it is less likely, though not impossible, that the filling of the
forecourt was motivated by the desire to confine  something inside the barrow  - perhaps
some malevolent spirit - that those who moved the sarsen stones did not want released.

•     Were they trying to  convey  this  message  to future civilizations, or to their own
       people?
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There is no evidence to allow one to judge whether anyone involved gave thought to future
civilizations different from their own.

•      What has been involved in interpreting the message by modem scholars?

The barrow has been extensively inspected, excavated, measured, and otherwise recorded.
Analogies with similar sites have also been important in its interpretation (Pig 62).

•      How sure are we that we have the message right?

There seems to be general agreement on the general purpose of the barrow, and, to some
extent, on the message it was intended to convey.  The message conveyed by the filled
forecourt, however, is a little more problematical.

•      If the message had been  "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

There is every evidence that quite the contrary is the case, since the barrow has in fact been
repeatedly excavated.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The massive size of the stones and its earth covering have preserved the barrow from major
damage by erosion.  Its location, high on a down, has kept it from being buried.  During the
first thousand years  after its construction, the barrow was routinely "vandalized" by the
culture that had built it.  The blockage of the forecourt and the overall presence of the
barrow, much less assuming than either Stonehenge or Avebury, apparently deterred
vandalism between 1600 B.C. and the modem era. In recent times it has again been opened..

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

Since the barrow's "message" is rather uncertain, it cannot be said that it has conveyed its
meaning clearly to the present.
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6.2.1.3.3  Knowth Passsage Tomb, Ireland

Duration:  ca. 5,000 years so far.

Description:  Like the West Kennett Long Barrow, Knowth is representative of passage
tombs throughout England and Europe.  It is one of three major passage graves at the bed of
the River Boyne.  The site consists of a large tumulus, 80 by 80 meters on a side, covering
two stone-walled back-to-back passage graves, one entered from the east, the other from the
west.  It is surrounded by 127 kerbstones, many of which have carved decorations that have
survived (Eog 86).

•     What message(s) were the monument's creators attempting to convey?

Eogan speculates that the tombs may have been built as an expression of spiritual
commitment towards the community by its members, and that afterwards the site served as a
ritual locus. The positioning of certain decorated stones  to capture sunlight may have been a
channel  of communication with those in the tombs. Features of construction unearthed
during excavation suggest a desire to block access to the  tombs, and the carved kerbstones
may have  been not merely decorative; they may have conveyed warnings not to disturb the
contents.  In the passage leading into the tombs, archaeologists encountered a carved
anthromorphic stone figure with large staring  eyes, which "suggested danger" (Eog 86).

•     Were they trying to convey this message to future civilizations, or to their own
      people?

The tombs clearly were intended to convey a message to  members of the community that
built and presumably worshipped at them, and perhaps  to similar communities who built and
used similar edifices throughout Britain and Brittany.  There is nothing to suggest an
intention to communicate with unrelated civilizations in the future.

•     What has been involved in interpreting the message by modern scholars?

Extensive  excavation and comparative analysis of Knowth and other tumuli have been
required to reach a basic understanding of the purpose  of these structures.

•     How sure are we that we have the message right?

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Interpretation of the messages intended to be conveyed by monuments like Knowth is largely
speculative, or is based on deductions that cannot be tested experimentally.  Still, it seems
certain from the elaborate arrangement of stones blocking the way into the tombs, and from
the decorated entrance stones, that the builders intended it not to be dug into.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

The anthromorphic figure that suggested danger, together with the stones blocking the
entrance, strongly suggests that something akin to this message was encrypted in the structure
of the tombs.  Eogan, the first modern violator of the tomb, recounts seeing the figure and
getting the message of implied danger.  This did not stop him from  digging, however.
Earlier Christian settlers in the region, if they received the same message, were not deterred
either.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The huge scale of the structure and the massiveness of its component parts have impeded
natural erosion  and deterred human intrusion as well. During the early Christian period
(ca. 400-1,000 A.D.), however, settlers dug a trench around the mound, uncovered its
entrances, and achieved access to its chambers, probably removing some of the contents.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

While the tomb's meaning is not clearly conveyed, the anthromorphic figure clearly gave  the
message of warning to Eogan.  The use of the human face proves to be a more effective
warning icon than an abstract symbol whose meaning would long since have been forgotten.

6.2.1.3.4  Avebury  Stones

Duration:  ca.  4,500-5,000 years so far.

Description: The Avebury Stones are a circle of standing megaliths and associated stone  and
earthen features in the town of Avebury, England.

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•      What message(s) were the monument's creators attempting to convey?

Michael Dames proposes that the Avebury Stones, were meant to form the stage upon which
a year-long religious drama was played out.  Each stone edifice may have offered a special
setting for the celebration of a particular event in the farming year, matched to the
corresponding event in human life (Dam 77).  Alternative interpretations are possible,
however.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

If Dames is correct, it would seem that the message of the Stones was meant for
contemporary interpretation, though the builders doubtless expected that their social and
religious practices would continue into the future. If the Stones were intended to serve some
other purpose, it might be that they were intended to convey a message to future
civilizations, but this is entirely speculative.

•      What has been  involved in interpreting the message by modern scholars?

Dames based  his interpretation on extrapolation from modem Christian practices that are
generally agreed to be rooted in the pre-Christian past, and on an interpretation of the
Avebury Stones by the English scribe Byhtferth of Ramsey (A.D. 1011).  There have also
been numerous archeological surveys and excavations of the site.

•      How sure are we that we have the message right?

Dames' interpretation is somewhat speculative. It cannot be said that anyone can
demonstrate precisely what the "message" of Avebury is.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would  have gotten the message before digging there?

There have been extensive excavations around the Avebury Stones.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

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The massive character of the Stones has kept them from being significantly reduced by
erosion.  Their location has protected them from flooding and sediment deposition.  Many of
the Stones were removed by residents of Avebury for use in construction of homes, walls,
and other structures.  Therefore, the site cannot be said to have fully withstood the ravages
of vandalism.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

There is no universal agreement as to the implied message of the Avebury Stones. If
Dames' interpretation of the Stones' meaning is correct, it is particularly interesting in terms
of the repository, because it is an example of the transmission of a message via oral history
and traditional practice over some 5,000 years.

6.2.1.3.5 Maltese Temples

Duration:  ca. 5,000-6,000 years so far.

Description:  The Maltese Temples are complexes of semi-subterranean megalithic temples
and tombs on the island of Malta in the Mediterranean Sea.

•      What message(s) were the monument's creators attempting to convey?

There is no clear evidence to  show that the builders of Malta's temples and tombs were
trying to convey any message to the future.  The temples and tombs probably served social
and religious functions in the  then-contemporary society (Bon 90).

•      Were they trying to convey this message to future civilizations, or to their own
       people?

There is no apparent reason to think that the builders of the Maltese monuments were trying
to  communicate with future civilizations.  Bonanno et al. (Bon 90) suggest that intra-
community rivalry provided the motivation for the construction of the monuments.

•      What has been involved in. interpreting the message by modern scholars?
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The Maltese structures have been the subjects of intensive archeological research over the
last many decades.

•     How sure are we that we have the message right?

The precise function of the Maltese monuments remains the subject of debate.

•     If the message had been "Don't dig here "because it is dangerous," is it likely that we
       would have gotten  the message before digging there?

Archeological excavations and illicit digging have been common around the Maltese
structures.

•     What physical and  environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The megalithic nature of their architecture, and in some cases their semi-subterranean
construction, have tended  to preserve the monuments.

•     What physical and  environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The monuments have not conveyed their meaning clearly to modern scholarship.

6.2.1.3.6 Easter Island Statues

Duration: Between 300 and 700 years  so far.

Description:  Easter Island, an isolated volcanic island that forms the southeast corner of the
"Polynesian triangle"  (the  triangular space containing the islands of Polynesia, Hawaii and
New Zealand),  is sprinkled with megalithic human torsos carved from the island's black
volcanic rock.  These statues are often topped with headdresses of red stone and typically
stand on platforms built of dry-laid masonry  called "ahu" (Ste 86).  The functional
equivalents of ahu are widespread in Polynesia and parts  of Micronesia, but such platforms
elsewhere are typically not associated with megalithic statuary.
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•     What message(s) were the monument's creators attempting to convey?

The statues have regularly been referred to as "enigmatic," and the message they were
intended to convey remains at issue today.  One recent and systematic study interpreted ahu
and their statues as shrines dedicated to the ancestors of those who built them.  These shrines
marked  the territories of ranked lineages (Ste 86).  The intended message about each
lineage's ancestors remains unclear, however.

•     Were they trying to convey this message to future civilizations, or to their own
      people?

There is no evidence to suggest that the Easter Islanders were attempting to communicate
anything at all to future civilizations.

•     What has been involved in interpreting the message by modern scholars?

Extensive historical, ethnographic, ethnohistorical, and archeological research has been
involved in determining the message of the statues.  Much of this work has involved
excavation.

•     How sure are we that we have the message right?

Modern scholarship has yet to determine what message the statues are designed to convey.

•     If the message  had been "Don't dig here because it is dangerous," is it likely that we
      would have gotten the message before digging there?

Scholarly research of the statues has regularly involved excavating (cf. Hey 58, McC 76).
The presence of the statues has not been reported to have  deterred anyone from drilling for
purposes of geological research or construction planning.

•     What physical and environmental characteristics have permitted the monument to
      withstand the ravages of time and vandalism?

The relatively hard stone from which the statues are carved has allowed them to  withstand
the elements.
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•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The statues have not conveyed their meaning clearly to modern scholarship.

6.2.1.3.7 NanMadol

Duration: ca. 700 years so far.

Description:  Nan Madol is an extensive complex of megalithic artificial islets on the coral
reef flats along the southeast shore of Pohnpei Island, Federated States of Micronesia. Each
islet was constructed in log cabin fashion.  Columnar basalt "logs" weighing up to several
tons and massive basalt boulders, some weighing over 20 tons were used to build the islets.

•      What message(s) were the monument's creators attempting to convey?

Nan Madol is believed to have been the prehistoric ritual and administrative center of
Ponhpei Island.  The highly stratified society of Ponhpei was governed by a single ruler with
the title of Saudekur.  When centralized social structure of the island broke down, Nan
Madol was abandoned.  The structure, however, figures prominently in Pohnpeian oral
tradition (e.g. Mor 88). The overall complex seems to have been designed to convey the
power and authority of the Saudeleur, while individual structures are said to have had special
meanings.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

There is no evidence that the builders of Nan  Madol were trying to communicate with other
civilizations in the future.  The Saudeleurs, however, may have had some interest in
perpetuating the perception of their greatness.

•      What has been involved in interpreting the message by modern scholars?

Nan Madol's interpretation rested almost entirely on oral history until the Smithsonian
Institution conducted studies there in the 1960s.   Since the late 1970s, there have been a
number of archeological surveys and excavations that have contributed to scholarly

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understanding of the site.

•     How sure are we that we have the message right?

It is impossible to be sure that the builders of Nan Madol were trying to convey any message
at all to the future. Therefore, there is no realistic basis for judging whether contemporary
scholarship has gotten the message right.

•     If the message had been "Don't dig here because it is dangerous," is it likely that we
      would have gotten the message before digging there?

Some of Nan Madol's chiefly tombs were plundered in the early 20th century.  Extensive
excavations have been conducted there since the late 1970s.

•     What physical and environmental characteristics have permitted the monument to
      withstand the ravages of time and vandalism?

Massive basalt construction is the key to Nan Madol's staying power.

•     What physical and environmental characteristics have permitted the monument to
      convey its meaning clearly through the millennia?

Without the testimony of oral history, modern knowledge would have been inadequate in
interpreting Nan Madol's  "message." It is not the character of the site itself, but the
traditions associated with it, that convey its message.

6.2.1.4     Ground Figures

6.2.1.4.1  Nazca Lines, Peru

Duration:  ca.  2,000 years so far.


Description: The Nazca Lines are an extensive complex of lines and geometric, zoomorphic,
and anthropomorphic figures scraped in the desert floor in southern Peru. They are
associated with the prehistoric Nazca culture.
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•      What message(s) were the monument's creators attempting to convey?

The meaning and purpose of the Nazca Lines are unknown.  Hawkins (Haw 63) has
demonstrated that they do not have a recognizable astronomical function. Hypotheses about
their function range from having various religious connotations (Kap 82) to being landing
strips for alien spacecraft (Von 68, 70).

•      Were they trying to convey this message to future civilizations, or to their own
       people?

This question cannot be answered based on current data.

•      What has been involved in interpreting the message by modem scholars?

The Nazca Lines have been studied extensively.  No interpretation thus far has attained
universal agreement (Kap 82).

•      How sure are we that we have the message right?

Since the message is not understood, this question is not applicable.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

Because the Lines are most visible from the air, they would have been ineffective in
deterring intrusion  from the ground. Their effectiveness with respect to intrusion from above
would depend on how well their message was conveyed.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The location of the Nazca Lines in a desert environment has minimized the damage from
erosion.  Their remoteness has minimized damage from human beings.   They are, however,
extremely fragile (Kap 82).

•      What physical and environmental characteristics have permitted the monument to

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       convey its meaning clearly through the millennia?

Since the Lines have not conveyed a widely understood message, this question is not
applicable.

6.2.1.4.2  Intaglios of the California, Arizona, and Nevada Deserts

Duration:  Up to 10,000 years (or more?  (Dav 80)).

Description:  The intaglios consist of gigantic geometric, anthropomorphic, and zoomorphic
figures scratched into a "desert pavement."  This hard surface is created by soil deflation in
arid areas  or by aligning rocks which become cemented in as part of the pavement.  While
they  are most commonly found in the California desert west of the Colorado River,  others
have been discovered east of the river in Arizona, in Nevada, and elsewhere.

•      What message(s) were the monument's creators attempting to convey?

There is no widespread agreement about what messages the intaglios were intended  to
convey. They have been interpreted as reflecting shamanistic symbols, messages about
water, astronomical observation points,  maps, gaming facilities, and "random, perverse
behavior"  (Dav 80, Hud 79, Rav 85).

•      Were they trying to convey this  message to future civilizations, or to their own
       people?

There is no evidence that the builders of the intaglios were trying to communicate with future
civilizations.

•      What has been involved in interpreting the message by modern scholars?

Contemporary scholars have used vertical and oblique aerial imaging, intensive surface
survey and mapping, and test excavation to interpret the intaglios.

•      How sure are we that we have the message right?

There is no general agreement among scholars about the message of the intaglios.

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•     If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have, gotten the message before digging there?

Because of the hardness of the desert pavement, the intaglios are not particularly conducive
to digging.  On the other hand, there is nothing in their character that discourages digging.

•     What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The extreme aridity of the desert and the stability of the desert pavement have tended to
preserve the intaglios.  Their remoteness has also been crucial in their preservation.
Recently,  however, "they are among the most fragile of prehistoric records.  They are highly
visible and have therefore become targets and slalom gates for bikers and ORVs (off-road
vehicles).  It is questionable if any can survive the next hundred years..." (Dav 80).

•     What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

One of the few things that can be said with certainty about the intaglios is that they have not
conveyed  their meaning clearly through the millennia.

6.2.1.4.3  Chacoan Roads

Duration:  ca. 1,000 years so far.

Description:  The Chacoan road system was constructed by the  Anasazi occupants of Chaco
Canyon in the San Juan Basin of northwestern New Mexico.  The roads radiate out from a
concentration of Anasazi ruins at the basin's center to outlying communities.  Major roads
are about  seven meters wide and run straight across the desert,  virtually without regard to
topography.  Lesser roads are about four meters wide and are also laid out in straight lines.
The roads are difficult to see from the ground surface, but well-preserved  segments are
easily visible from the air (Pow 82; Trom 91).

•     What  message(s) were the monument's creators attempting to convey?

The "message"  of the roads is  a subject of intense debate among archaeologists.  Some argue

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that the roads were simply the fastest ways to get people and goods from point A to point B.
Some suggest that they were built for the specific purpose of transporting timber from the
highlands to the basin for pueblo construction. Others feel that the roads had ceremonial
functions, while others pr. x>se a military purpose. Still others argue that the roads were
meant to convey a message of power — that the Chacoan people were powerful enough to
engineer, construct, and maintain a formal road system that ignored topographic obstacles
and required major organized labor expenditures.  Finally,  some feel that the term "road" is
a misnomer that has misled interpretations of the features.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

If the roads were intended to represent the power of Chacoan society, that message was most
likely intended for surrounding populations.  If the roads were used for ceremonial purposes,
their organization may have reflected the organization of Chacoan cosmology, and thus may
have been intended to communicate with the Chacoan people themselves or  with their deities.
There is no reason to think they were intended to communicate anything to  future
civilizations.

•      What has been involved in interpreting the  message  by modern scholars?

Study of the Chacoan roads to date has relied largely on remote sensing.  There is little
about the roads to tempt excavation, though minor test trenching has been performed to study
their structure.

•      How sure are we that we have the message right?

As previously noted, there is much debate about the roads.  After some 90 years of study,
modem scholarship has yet to  determine what message, if any, the roads were intended to
convey.

•      If the message had been "Don't dig here because it  is dangerous," is it likely that we
       would have gotten the message before digging there?

No, but the Chacoan roads do have something to say about digging.  Unlike virtually every
other archeological analogue discussed here,  they have not  significantly inspired anyone to

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dig.  Since they are shallowly incised into the desert floor, sometimes into the bedrock itself,
and show no promise of covering anything of value commercially or to science, there has
been little temptation to dig through them. Instead, their study has relied primarily on non-
intrusive remote sensing.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The arid environment of the San Juan Basin has contributed to the survival of the roads,  but
erosion, sand and soil deposition, and human-initiated processes and events (road
construction, mineral extraction, etc.) have taken their toll.  Many portions of the roads are
now very difficult to discern. Some have disappeared  completely. Road alignments have
been extrapolated in most cases from numerous discontinuous segments.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The Chacoan roads have not conveyed any message clearly, therefore this question is not
applicable.

6.2.1.5    Rock Art

6.2.1.5.1  Lascaux Cave, France, and Similar Paleolithic Painted Caves in Europe

Duration: ca. 10,000 to 30,000 years so far.

Description:  Lascaux is representative of a number of caves in France and Spain (e.g.,
Altimira, Niaux, Quercy, Cosquer) in which paintings  from the paleolithic period are
preserved.  Although not surface "monuments" analogous in structure to those that will mark
the WEPP, these caves are the only known archeological sites that have conveyed messages
through a time period greater than that for which the WIPP marking system  must be
designed.  Like other caves containing paleolithic rock paintings, Lascaux displays vivid,
multicolored pictures of game animals, geometric figures, and human handprints (Tar 62).

•      What message(s) were the monument's creators attempting to convey?
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While the precise message of paleolithic paintings is unclear and is the subject of lively
debate (Lew 93), it is agreed that the hunt is the main theme.  Game animals are portrayed,
often pierced with what appear to be spears.  Association with hunting magic was the first
interpretation given the paintings by modern scholars, though in recent years a number of
alternatives have been proposed.  It is widely agreed that Lascaux and similar caves (e.g.,
the Salon Noir at Niaux) were sacred places where ceremonies related to the hunt were
performed, a group's social organization was reinforced, or relationships to the visible world
and its invisible correlates were affirmed.

•     Were they trying to convey this message to future civilizations, or to their own
      people?

Almost certainly, the painters of paleolithic rock art intended their work to communicate with
members of their own society or to supernatural beings. There is no reason to think that
they were trying to communicate with future civilizations.

•     What has been involved in interpreting the message by modern scholars?

The apparent messages of the paintings — that bulls, horses,  and other game animals were
powerful and were hunted, and that success in the hunt was desirable — were comprehended
by viewers without any particular effort.  Much archeological and art-historical research  has
gone into interpreting the paintings  in greater detail, dating them,  and understanding the
social context in which they were created.  On the whole, this research has resulted in more
controversy than clear interpretation.

•     How sure are we that we have the message right?

Modern scholarship does  not understand the messages encoded in  paleolithic rock art.
However, it seems certain that  the basic message that success in the hunt was  desired and
was sought through some kind  of ritual has been correctly understood.  The geometric
figures that accompany the animal paintings are much less clearly understood.  They are
thought to be the symbols of specific social groups (clans, tribes), but this is largely
speculative (Tar 62).

•     If the message had been "Don't dig here because it is dangerous," is it likely that we
      would have gotten the message before digging there?

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It is possible that a Level n message of this character could be conveyed by paleolithic rock
art, although there is no evidence that any such message was  intended. Lascaux and other
painted caves have conveyed certain low-level messages clearly through the millennia
because they employ forms that have remained widely familiar.  Most people today know
what a bull looks like, though few have experienced creatures as magnificent and dangerous
as those painted at Lascaux. A bull with a spear protruding from its side is clearly one that
has been attacked by a hunter.   On a similar level of abstraction, one can imagine a series of
paintings depicting a human being digging, looking into the hole, and then lying dead.  After
viewing such a depiction, a 20th century observer would most likely be careful before
digging.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

Because the paintings were made on the walls of deep caves,  they have been protected from
the elements.  The inaccessibility of the caves has also protected them from vandalism.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

Although much of the message of paleolithic rock art has been lost, the importance of game
animals and the desire of their hunters for a successful hunt has been successfully conveyed.
This is due to  the simplicity and universality of the images employed.

6.2.1.5.2  Australian Rock Art

Duration:  ca.  25,000 years so far (possibly 35,000 years).

Description: Australian rock art includes paintings, engravings, and peckings.  Subjects and -
styles vary over time and space and contain both simple and complex representations. Most
are polychromatic.  Many pictures overlap or are superimposed on one another.  Some of the
art includes  symbols that appear to convey information on direction, movement, the act  of
speaking, and  events in the time known today as  "the dreamtime."  Australian rock art is
found in rock  shelters and overhangs; presumably more exposed surfaces were also decorated
in the past, but such paintings have been.destroyed by the elements (Chal 84).  Aboriginal
Australians continue to create rock art.

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•      What message(s) were the monument's creators attempting to convey?

The messages encoded in Australian rock art have been the subject of intense debate.
Chalapka asserts that the art portrays a wide variety of human experiences which reflect the
artist's physical, social, and cultural environment. For example, many motifs relate to
hunting, plant gathering, and swamp life. Dominant plant and animal figures may represent
the local subsistence base.  Paintings reflect economic and socio-cultural activities, as well as
"mythic" events and spirits (Chal 84; Gra 93).  Some intent to record contemporary events,
and possibly to  influence them, is suggested by such sites as the Emu Dreaming and Pig
galleries on the Cape York Peninsula. At this site, "a half dozen white men with rifles are
depicted.  In the Pig Gallery,  birds are shown standing atop the bodies of two of the men,
beaks thrust into their armpits" (Gra 93).

•      Were they trying to convey this message to future civilizations, or to their own
       people?

The intended recipients of the messages are also the subject of considerable debate. There
is, however, nothing to suggest an intention to communicate with future civilizations.

•      What has been involved in interpreting the message by modern scholars?

Since aboriginal Australian culture remains alive today, ethnography, oral history,  studies of
folklore, and consultation with Aboriginal experts have been primary bases  for what is
known about Australian rock art. Archeological research and comparative analysis of artistic
elements have also made important  contributions.

•      How sure are we that we have the message right?

The messages of Australian rock art are not yet thoroughly understood by non-Aboriginal
scholars.

•      If the message  had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the  message before digging there?

Although much Australian rock art  is very  abstract, much of it is also highly
representational.  Often both the external and internal characteristics of animals are

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portrayed.  It is conceivable that a representational pictograph warning against digging would
be understood.   It js also conceivable that a pictograph representing a human's internal
structure becoming afflicted would be understood as well.


•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?


Although the painted pictures are especially fragile,  they have been protected from the
weather and preserved by their location in rock overhangs.  Some paintings  may have also
been maintained over the years, because they have continued to figure in the ceremonial life
of Aboriginal communities.


Chalapka identifies five variables that affect the survival of the Australian rock art:

       1.  Degree  of protection. The less moisture present, the greater the isolation from
           humans and animals, and the greater the distance from the exterior of the shelter,
           the  more likely the paintings will survive.

       2.  Type and matrix of host  rock.  The harder and more stable the rock, and the
           greater  its ability to  absorb pigment, the more likely the art will  survive.

       3.  The properties of the pigment.  The pigment's ability to be absorbed is a variable
          ' of survival.   Hematite-based pigments  survive best.

       4.  The method of application.  If the pigment is applied directly to  the rock, rather
           than onto a clay base, the painting will survive longer.

       5.  Climate at the time of execution. If the  climate  is dry, the pigment is more likely
           to be absorbed  and has a better chance of having a protective mineral coating
           form over it.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

To the extent that Australian rock art has conveyed its meanings, it has done so because of
the physical survival factors listed above. Also, Aboriginal Australians are  still living today
and are able to interpret the paintings.
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6.2.1.5.3 African Rock Art

Duration: Up to ca. 6,500 years.

Description:  Saharan and sub-Saharan Africa has rich and varied mural art in caves and rock
shelters, as well as large numbers of petroglyphs, both engraved and pecked.  Images are
typically of both wild and domestic animals and humans. Human images often are depicted
with bows, axes and other weapons and are engaged in hunting, dancing, and other activities.
Petrogylphs in the Sahara and its vicinity are thought to be associated with a period between
ca. 4000 and 2500 B.C. when the area was considerably wetter than it is today (Sea 93).
Most of the painted art in  sub-Saharan Africa is thought to be more recent, ca.  400 to 1,200
years old (Scho 71).

•     What message(s) were the monument's creators  attempting to convey?

A wide variety of messages appear to have been embedded in the art.  While some motifs
depict hunting, cattle, armed battle, and dancing rituals, others reflect trade and forms of
interaction between different tribes and ethnic groups.   Some symbols have been linked to
fertility and personal magic. Ethnographic evidence suggests that western South African
mural art reflects the rich story telling traditions of local aboriginal populations.

•     Were they trying to convey this message to future civilizations, or to their own
       people?

Although there is an inherent historicity in the portrayal of a society's life and times in rock
art, there is nothing in the art to  suggest an attempt  to communicate  with future civilizations.

•     What has been involved in interpreting the message by modem scholars?

Interpreting African rock art has  involved ethnographic and historical research,  excavation of
associated archeological sites, and the removal and testing of pigment samples for radio-
carbon age determination.

•     How sure are we that we  have the message right?

Where there is a fairly clear connection between rock art sites and living groups who have

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been subjected to ethnographic study, scholars are confident in their interpretations of the art.
There is also strong evidence that rock art reflects a long, evolving continuum throughout
much of the region; some shelters contain rock art reflecting hundreds of years of painting,
with a great deal of superimposition.  This permits extrapolation into the distant past. Many
styles and elements are still poorly understood, however, and extrapolation into the past from
contemporary and  recent ethnographic reality assumes a level of cultural stasis within local
groups over time that may not be justified.

•     If the message had been "Don't dig here because it is dangerous," is it likely  that we
      would have gotten the message before digging there?

Since much of the art is highly representational, it is possible that  such a message would
have been understood. The effectiveness of message transmission  would be enhanced if the
same message were encoded in associated living traditions.

•     What  physical and environmental characteristics have permitted the monument to
      withstand the ravages of time and vandalism?

Remoteness,  aridity, and the hardness of the rock on which  it is engraved or pecked have
contributed to the preservation of North African rock art. Sub-Saharan rock art, particularly
painted art, does not tend to preserve well. The weather, especially the wet-dry cycles,  is
particularly damaging to  such art.  The types of stone available in  this region tend  to
exfoliate, and pigment tends to oxidize.  Vandalism has also had a profound effect; many
pictures have been deliberately scratched over and chipped,  and portions  of murals have been
chiseled out for collection, sale, display, and/or study.  This has been reduced in recent
years by enforcement of  stringent laws.

The most important factors that lead to art preservation in the region are:

      1.   The stability and hardness of the rock.  Granite  and  hard sandstone are found in
           some regions.

      2.   The degree of protection from weathering and casual touching.   Art is  more
           likely to be preserved in deep shelters  above the level likely to be rubbed by
           animals using such shelters.

      3.   Isolation from areas of heavy human use. Art is more likely to be preserved if it

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           is above the level likely to be brushed by human hands or bodies when moving
           around the shelter.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

It cannot be said that African rock art has clearly conveyed its meaning. However, the
greatest confidence in understanding its meaning arises from two factors:  its often highly
representational character, and its association with the traditions and beliefs of living
communities.

6.2.1.5.4 Adamgarh Paintings, India

Duration: ca. 7,500 years so far.

Description:  The Adamgarh Paintings consist of at least ten sets of superimposed paintings
on cave walls in the Hashangabad district of India. The earliest painting features an
elephant, while later paintings depict warriors on horseback and other human figures
(Pan 93).

•      What message(s) were the monument's creators attempting to convey?

Other than their observations and experiences, the messages the artists may have intended to
convey is unknown.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

There appears to be no reason to think that the painters of Adamgarh were trying to
communicate with civilizations other than their own.

•      What has been involved in interpreting the message by modern scholars?

Research has focussed on the superimposition of images which reflect change through time.
Each layer reflects a distinctive painting style.  Some of the layers of painting are associated
with particular stratigraphic  levels in the. archeological deposits of the rock shelter floor

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(Pan 93). Therefore, studying these relationships has required excavation.

•     How sure are we that we have the message right?

Since the content of the messages is not really known, it is impossible to tell if modern
scholarship has them "right."  The chronological association between painting styles and
stratigraphic levels appears to be substantiated, however.

•     If the message had been "Don't dig here because it is dangerous,"  is it likely that we
       would have gotten the message before digging there?

As noted above, understanding even the chronological placement of the paintings has
required excavation.

•     What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The paintings have survived because they are found in overhangs or "rock shelters." In such
a shelter, the overhead projection from the cliff protects the "canvas" from rain. The hard
sandstone that forms the shelters is also resistant to erosion.  The site is protected from
vandalism today by government regulation.

•     What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

Because  the message is not understood,  this question is not applicable.

6.2.1.5.5 Rock Art in the Western United States (General)

Duration: ca.  10,000 to 100 years so far.

Description: Many Native American groups of the western United States  produced both
pictographs (painted rock art) and petroglyphs (pecked, ground, scratched, or incised rock
art).  Such art,  particularly pictographs, has been produced in recent times and is probably
being produced today.  However, the rock art tradition dates back at. least several millennia,
and rock art sites up to  10,000 years old have been reported (Hed 83).  Styles and motifs
vary widely from tribe to tribe, region to region,  and through time, but geometric,

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anthropomorphic, zoomorphic, and abstract styles are common.

•     What message(s) were the monument's creators attempting to convey?

Much of the rock art in California, particularly pictographs in the Chumash area along the
south coast, is thought to represent astronomical phenomena (e.g. Hed 83, Hud 78).  Some
sites are ethnographically associated with specific rituals, such as the initiation of girls into
womanhood (e.g. Tru^88).  Some petroglyphs are identified as trail markers and other
mnemonic devices, vision quest location markers, and hunting ritual depictions (e.g.
Mur 87).  Several scholars see representations of sexual parts and acts in rock art as part of
fertility rituals. Others identify elements of rock art as vehicles to telling and remembering
of origin stories and other traditions. Rock art may also serve as markings for social group
boundaries (Hed 83).  Petroglyphs in the form of Hopi clan symbols in the Southwest are
thought to have marked the route to sacred sites, and as reflecting the journeys of the Hopi
ancestors recorded in tribal tradition (Jud 50).  In short, western North American rock art
probably was intended to convey a wide array of messages, most of which are not completely
understood today.

•     Were they trying to convey this message to future civilizations, or to their own
       people?

Rock art was  probably intended to communicate messages with the artist's fellow religious
practitioners,  or hunters, other members of the artist's family, clan, or tribe, and (in the case
of boundary markers  and some trail markers) with other groups.  Some rock art may have
been intended for communication with the supernatural. There is no evidence to suggest an
attempt to communicate with future civilizations,

•     What has been involved in interpreting the message by modern scholars?

Interpretation of rock art in the American west has involved ethnographic consultation,
excavation of rock art sites, photography, rubbings  and tracings,  and a wide range of
comparative analyses.

•     How sure are  we that we have the message right?

There is little agreement about what messages are embedded in western American rock art.

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In a few cases, the testimony of ethnographic consultants has generated a fair amount of
certainty about the meaning of particular rock art sites (e.g. Tru 88).

•     If the message had been "Don't dig here because it is dangerous," is it likely that we
      would have gotten the message before digging there?

In cases where rock art is representational, it is possible to imagine that such a message
could be transmitted. However, the highly abstract, presumably symbolic,  forms that
dominate much western American rock art would not be likely to convey such a  message
readily.

•     What physical and environmental characteristics have permitted the monument to
      withstand the ravages of time and vandalism?

Pictographs survive  best when well protected from exposure to the elements.  Petroglyphs
often survive on exposed surfaces, but do erode and weather. Petroglyphs deeply pecked or
polished into very hard rock, like granite, survive best.  Pecked and polished petroglyphs
survive more readily than scratched or engraved forms.  Burial under sand'or .silt can
preserve petroglyphs in almost pristine condition (Tur 94).  Since human vandalism is a
major cause of petroglyph destruction, remoteness from human settlements promotes
survival.

•     What physical and environmental characteristics have permitted the monument to
      convey its meaning clearly through the millennia?

On the whole,  the meaning of western North American rock art has not been clearly
conveyed.

6.2.1.5.6  North Fork Petroglyphs,  California, and  Jeffers Petroglyphs, Minnesota

Duration:  ca.  5,000 to 300 years so far.

Description:  These  sites were examined in great detail as representatives of prehistoric
Native American petroglyphs throughout North America.  Petroglyphs represented are
geomorphic, zoomorphic, anthropomorphic, and other figures scratched, pecked, or incised
into the living  rock.  The North Fork complex includes some 46 individual sites  along the

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American River in Placer County, California.  The figures depicted are mostly geometric
forms, with the "rake" or "bear paw" predominant (Gor 84).  The Jeffers site consists of
nearly 2,000 carvings on a quartzite outcrop in southeastern Minnesota (Lot 76).  Two
periods of carving are represented: ca. 3000 to 500 B.C. (indicated by the appearance of
nearly 100 depictions of spear throwers, which were the dominant hunting tools and weapons
during this period), and ca. 900-1750 A.D. (indicated by glyphs resembling motifs and
symbols used by early historic people of the northern Plains).

•      What message(s) were the monument's creators attempting to convey?

.rtoth sites are interpreted as relating to magic.  The North Fork sites, with their emphasis on
' i^ear paw" figures as well as human stick figures, are thought to have magical connotations
which today are obscure. Some markings also suggest a "trail map" function.  The Jeffers
site, which features game animals,  hunting weapons, and hunters, is also interpreted as
related to hunting magic. Depictions of religious and magical symbols (eagle, thunderbird,
bison) suggest this. The depictions of humans  wearing bison horn headdresses, throwing
spears at one another, and having projectiles in their backs suggest that an attempt was being
made to record events in the lives of warriors,  shamans, chiefs, and society.

•      Were they trying to convey this message to future civilizations, or to their own
       people?

Religious and magical symbols were presumably intended to convey messages to supernatural
beings and religious practitioners.  "Trail markers" may have been intended to convey
messages to others of the same or similar societies.  Glyphs depicting historical events may
have intended to convey the importance of these events to future generations.

•      What has been involved in interpreting the message by modern scholars?

Interpretation of the petroglyph  sites has required extensive historical, ethnographic, and
archeological research. Dating the Jeffers petroglyphs,  for example, requires  the knowledge
that the atlatl (spear thrower)  was in use between 3000 and 500 B.C. before it was replaced
by the bow and arrow. This knowledge has been gained through extensive archeological
excavations in  the area, though not necessarily  at the Jeffers site itself.

•      How sure are we that we have the message right?

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Scholars are by no means sure that the messages of the petroglyphs have been correctly
interpreted. To the extent they have been interpreted, they are understood only at rather
basic levels; much detailed information has been lost.

•      If the message had been "Don't dig here because it is dangerous," is it likely that we
       would have gotten the message before digging there?

The messages conveyed do not  seem to have anything to do with digging; however, a "don't
dig" message being conveyed clearly in this medium can be conceived. Just as people
throwing spears at each other can be clearly (and probably correctly) understood today as a
battle scene, a depiction of a person digging a hole and then lying dead would almost
certainly be understood as a  warning not to dig.

•      What physical and environmental characteristics have permitted the monument to
       withstand the ravages of time and vandalism?

The hardness of the rock surfaces and  remoteness from human settlement have protected the
petroglyphs sites. Many petroglyphs not protected by these have been lost to erosion and
vandalism, however.

•      What physical and environmental characteristics have permitted the monument to
       convey its meaning clearly through the millennia?

The petroglyphs have not conveyed their messages very clearly.
6.2.1.6    Summary Observations on Archeological Analogues

The review of archeological analogues to the WIPP marker system suggests that there are
few specific analogues which address all the questions posed in this section. There is little
evidence to suggest that the monuments, structures, and other markers discussed above were
explicitly intended to convey much -- if any - information into the distant future.   Even
highly permanent and seemingly message-rich structures like the various pyramids and the
megalithic structures  of England and Europe have contemporary functions such as housing
the dead, supporting  temples,  making astronomical observations, and impressing the
population with the power of the government or the awesomeness  of religious  rites.  To the

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extent messages were encoded in the structures, they seem for the most part to have been, or
at least are today understood as, fairly simple Level I or n messages, on the order of "the
pharaoh who built this structure was very powerful."

Some of the monuments were certainly intended to mark historical events for future
reference.  The stelae of the Maya and other Mesoamerican civilizations  are an example, as
are the painted tombs of the Egyptian pharaohs, Australian rock art, and  such Mesopotamian
monuments as the Rock of Bihistun. With the exception, perhaps, of markers like the Rock
of Bihistun, there is little reason to  think that these monuments were meant to convey
information to future civilizations that their creators thought would be substantially different
from their own.  In other words, there is little reason to believe that anyone who created a
monument in the past designed it with an eye to communication across thousands of years of
cultural and linguistic change.

Some monuments do communicate warnings against disturbance, but these have been notably
ineffective.  Tombs explicitly marked as protected by supernatural sanctions have routinely
been looted by treasure seekers and excavated by archaeologists. Of course, no one in the
past warned against deep drilling, so the possible effectiveness of such a  warning cannot be
assessed.

The review of archeological analogues has produced some useful information, however,
which can be summarized as follows:

1.    The "monuments" that have  managed to convey fairly detailed information over
      millennia (e.g., paleolithic rock art, Australian rock art, Egyptian tomb paintings and
      carvings, Mesopotamian cuneiform inscriptions, and Mesoamerican stelae) have done
      so because they  have been inside something very protective, like a cave, rock shelter,
      or excavated tomb,  or because they have been buried.

2.    In some cases of European paleolithic and Australian rock art, images have survived
      for possibly up to 35,000 years.  These images are often portrayed in the very fragile
      medium of paint.

3.    Certain graphic images communicate clearly through the millennia.  Anthropomorphic
      and zoomorphic figures painted on cave walls during the paleolithic period in Europe
      and Africa and by Australian aborigines and prehistoric Native Americans are easily
      recognizable as such today.  Geometric figures that presumably had symbolic meaning
      when they were produced, such as intaglios, the Nazca lines, and prehistoric rock art,

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       convey their meaning much less reliably, if at all.

4.     Detailed (ca. Level IV) information on ancient monuments has for the most part
       transcended to the present because it was inscribed or otherwise written on the
       monuments themselves (e.g., Mayan stelae, Egyptian tombs, Mesopotamian
       monuments), embodied in a literature that has survived or been recovered (Great Wall
       of China, pyramids of Egypt, Mesopotamian monuments),  or embodied in the oral
       history and cultural practices of a population that remained resident in the vicinity
       (Mesoamerican pyramids and other structures).

5.     The other major source of information on ancient monuments has been archeological
       research.  This has almost always involved excavation.  Excavations conducted in and
       around such monuments have never gone to depths that would be dangerous if
       conducted at the WIPP site. Future excavations may be taken to such depths,
       however, if archaeologists believe there is something important to be learned and do
       not realize the danger of doing so.

6.     Most ancient monuments have attracted people to dig into or around them in search of
       treasure, recyclable material, or for purposes  of scientific research.  An exception is
       the Chacoan road system, which although it has not deterred anyone from digging,
       has not particularly tempted them to do so. This is because the roads do not convey
       the impression that anything would be gained  by digging  in their vicinity.


6.2.1.7   The WIPP Markers Panel Report


DOE has recently released the report of two expert panels assembled by Sandia National
Laboratories to offer advice about the WIPP marker system (SAND 93). The
recommendations of the panels can be  summarized as follows:


Team A

1.     Warnings should be conveyed through a gestalt sense of place, through written
       languages and scientific symbols, and through the use of the human face with
       expressions.

2.     The WIPP and a buffer area should be surrounded by earthen berms, jagged and
       threatening in shape, to create a threatening sense of place.

3.     Within the "keep"  created by the berms there  should  be multiple "message kiosks"
       containing Level n messages in some seven languages — the languages of the United
       Nations plus a local indigenous Native American language.  The messages should be
       inscribed on a  granite wall protected by a partially encircling "mother wall."

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4.     Also, a world map should be constructed within the "keep" showing other disposal
       sites, together with the original WIPP buildings, which should be left to decay.  The
       map should be visible from the tops of the berms.

5.     Level IV information should be contained in concrete rooms buried at the four
       corners of the berm system, designed to permit access but preclude the removal of the
       information.  The information should be inscribed on redundant layers of stone tablets
       in multiple languages, each tablet being too large to be removed intact through the
       entryway, which would be blocked by a sliding stone plug.

6.     Construction should employ materials that are too large, too difficult, and too
       worthless to tempt recycling or relocation to museums.

7.     Message design should include the use of inscribed pictographs29 of human faces
       expressing shock and disgust.

Team B

1.     The marking  system should employ both surface and buried markers.

2.     The messages must be truthful.

3.     The outer extent of the marker system should be visible from the center.

4.     The area  marked should be surrounded by berms,  which should not include a buffer
       area.  The berms should be spiked with materials having anomalous properties (e.g.
       magnetic, radar reflective, dielectric).

5.     The warning messages  should be conveyed in number  of ways so that if one message
       is not completely understood, the message in another form can be used  to fill in the
       gaps. Messages should be conveyed in multiple languages, scientific symbols, and
       pictographs.  They should be inscribed on stone monoliths and buried in "time
       capsules."

6.     The original WIPP buildings should be left in place for future archeologieal study,
       which will preserve knowledge of what was done there.

7.     Detailed information should be stored off-site.
   29 The word "pictograph" is often used to mean painted rock art, as opposed to incised, pecked, or inscribed
"petroglyphs." Following common WIPP practice, the term is used in a more general sense here, to mean
pictures on stone — in this case, inscribed.
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8. •    The marker system should include a map showing other disposal sites around the
       world, and perhaps an international radiation warning symbol.

9.     In the center of the marked area there should be a granite structure containing detailed
       information about the WIPP and its dangers, in both textual and pictograph form,
       inscribed on large  stone slabs.

10.    Testing marker designs for durability and cross-cultural understanding should be
       undertaken between now and the time of implementation.

The expert panels' recommendations are well developed and should be of great use to DOE
in making final decisions about marking.  The differences between the teams should not be
difficult to resolve; ideas for some resolutions are included in  the recommendations that
follow. (Additional detail regarding the WIPP Markers Panel is included in Section
6.2.5.2.1.)

6.2.1.8    .Observations from Archeological Analogues Review

•     Marker protection

Messages are most likely to  be preserved through millennia if they are enclosed in protective
material, as in a cave.  This supports the  recommendation of WIPP Expert Team A that the
message-bearing stone pylons should be partially enclosed by protective concrete "mother
walls." It might be desirable, in fact, to partially or wholly roof each mother wall, or to
encircle the message pylon on all but one side with triangular  granite slabs leaning together
to form a sort of tepee,  thus creating an artificial cave.  If designed to appear to lean
somewhat in different directions, such protective structures could help create the sort of
jagged, threatening landscape that Expert  Team A considered desirable.

•     Universal, representational figures

The fact that anthropomorphic and zoomorphic figures have most reliably transmitted
information through the  millennia in rock art suggests that similar figures should be
employed in marking the WIPP site. Both Expert Teams A and B have provided  examples
of how this can be done (e.g. SAND 93 pages G-19 and G-20).  The fact that abstract
symbols have on the whole not conveyed  messages accurately  from the distant past to the
present suggests  that symbols like the radiation trefoil and even the skull and crossbones may

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have limited utility as markers, unless they are combined with more graphic pictographs.

•      Paint or other graphic media experimentation

The fact that Australian and European cave paints have survived in some cases for far longer
than the design life of the WIPP marking system suggests that painted or drawn messages
could be used to convey Level IV information, if the messages were properly protected.
Since this might be less costly than making detailed inscribed tablets, DOE may wish to
experiment with ways of protecting painted surfaces in the Level IV information chambers.

•      Updating Provisions

Since Level IV information about ancient monuments has most often been conveyed because
the monuments have been referred to in historical accounts or oral history, every  effort
should be made to keep the WIPP in human memory through the millennia, rather than
simply marking it and walking away.  This supports WIPP Expert Team B's recommendation
for a visitor center,  and Expert Team A's recommendation that people in the future be
invited to  add their own inscriptions, translating those that have become difficult to
understand with the passage of time. It also leads to the recommendation that more be done
than simply to invite future people to add their own interpretations, in their own languages.
It is suggested that the U.S. Congress adopt legislation requiring that, at fifty-year intervals
for as long as the United States exists, the effectiveness of the WIPP marking  system be re-
evaluated  and new markers added to convey its message in then-contemporary languages and
idia.  The legislation should specify that this responsibility will be passed on, to the extent
possible, to any successor in interest to the U.S.  government.   One certainly cannot rely on
such legislation being effective for 10.0QO years, but it will certainly be effective for some
time into the future, and it would be a better exercise in responsibility than would simply
marking the site and leaving it alone.

It is recognized that this observation superficially contradicts the long-held position that the
markers should be designed to require no maintenance.   The rationale for this observation, in
Kaplan's words, is that "maintenance cannot be guaranteed and to require it would be
contradictory to the idea that the generation which receives the benefit of nuclear power
should place no burdens on future generations for its disposal" (Kap 82).  Without debating
the morality of placing burdens on future generations, it is suggested that although
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maintenance cannot be guaranteed, and although the marking system certainly should not be
designed to require it, it is not inappropriate to strongly encourage future generations to
maintain the currency of the marking system's message.  A "defense in depth" strategy for
the disposal system can lead to development of many features which go beyond minimum
legal requirements.

•      Designing for archaeology

Assuming that a discipline equivalent to archeology continues to exist in the future, or that
people just want to dig around monuments out of curiosity, the history of ancient monuments
suggests that archeological excavations or their equivalents could become ways for the
message of the WIPP to be conveyed to people in the distant future.  This underscores the
Team A's recommendation that vaults containing Level IV information should be buried
under the berms at the four comers of the "keep," as well as near (but not at) the center.  It
may also be desirable to bury  a sample of pylons under tumuli, so that in the event the
exposed pylons are destroyed or carried away, others will become exposed over time by
erosion or archeological excavation.  Finally, using archeological excavation as a means of
communicating with the future underscores  Team B's recommendation that "time capsules"
be scattered over the site to be discovered by future excavators, and Team A's equivalent
recommendation about small buried markers.

•      Consideration of a depressed center

The fact that the Chaco road system is one of the very few ancient "monuments" that has not
attracted people to dig in its vicinity suggests that depressed  structures may be less inviting to
excavation  than elevated structures.  This in turn suggests that it may be worth considering
marking the center of the WIPP  "keep" with a depression created by scraping the soil to
bedrock. Since such a depression would rapidly fill up again with sand, it might be well to
fill it with rubble, creating a variant on Expert Team A's "rubble landscape."  This would
eliminate creating an elevated  structure that might tempt people to drill under it to see what
is there.

•      Languages of world religions

Finally, the fact that many, if  not most, long-lasting ancient monuments are religious in
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nature suggests that in addition to the languages of the United Nations (and perhaps Japanese)
and one or more Native American languages30, messages at the WIPP should also be in-
scribed in Latin, Hebrew, and Arabic.  It is certainly conceivable that in the distant future,
one of these ancient languages will continue to be the language of religion and scholarship,
long after languages used primarily for secular purposes have changed beyond recognition.


6.2.2  NRC Studies

No NRC work on markers has been uncovered in the development of the 40 CFR part 194
proposal.

6.2.3  NASA Studies

Four NASA deep space probes which have left the solar system contained symbolic messages
for other possible civilizations in the universe.  These included the Pioneer 10 and 11 and the
Voyager 1 and 2  spacecraft.  A gold-anodized plaque on Pioneer uses various symbols to
depict the position of our sun relative to various pulsars, the  relative size and physiognomy
of male and female compared to the spacecraft, and the track of the spacecraft from Earth
past Jupiter (NGS 75).

Each Voyager spacecraft included a copper disc (protected by an aluminum cover) with
greetings from  Earth people in 60 languages.  The record  also contained samples of music
from different cultures and ages ranging from the 1958 recording of "Johnny B. Goode" by
Chuck Berry to Beethoven's Fifth Symphony and various Earth sounds (NGS 90, NASA 77).
The record also contained digitized pictures describing the blue planet.  Instructions and
equipment were included in the spacecraft for retrieving the contained information.

6.2.4  NEA/OECD Studies

In 1990, a Working Group on Future Human Actions at Radioactive Waste Disposal Sites
was established by the Nuclear Energy Agency (NEA) of the Organization for Economic
Cooperation and Development (OECD). This group's purpose was to review and summarize
work of OECD member countries regarding treatment of future human actions on post
closure safety assessments of geologic repositories (NEA 93). In discussing site marker
systems,  the Working Group noted that some markers have already survived for 5,000 years
and; consequently, the task of devising  markers which will persist and be understood
   30  Expert Team A recommends Navajo, which makes sense as the Navajo are the most populous Native
American group in the vicinity. Expert Team B recommends Mescalero Apache, since the Apache are the actual
pre-contact residents of the area. The question of which Native American language to use should be worked out
through consultation with all the tribes of the area.  To use Navajo in the ancestral territory of the Apache would
be inadvisable without discussing the matter with the Apache first.

                                         6-64

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"appears daunting but feasible."  The Working Group described surface marker studies
conducted by DOE in the United States and ANDRA in France.  The DOE work will be
documented in Section 2.5.  The French approach is based on concern that on-site messages
may be misunderstood.  Site markers may arouse curiosity and thereby encourage intrusion.
The elements of this  approach as presented by the Working Group are:

       •   Markers should not be located directly above the repository, but rather 10 to
           20 km away. This distance should limit direct intrusion due to curiosity and
           allow the markers to be located in the same political and geographical region as
           the repository itself.

       •   Markers should be sufficiently large enough to be recognized by any people
           living in the vicinity of the site.

       •   Markers should contain redundant messages indicating the exact position of the
           disposal site. This information should be in a form recoverable by a civilization
           knowing the basic elements about radioactivity; otherwise, the situation would be
           equivalent to that for a marker built directly above the repository.  Thus, the
           messages and particularly the location of the disposal site should be encoded, for
           example, using  the symbols and quantities used in nuclear physics.


The Working Group concluded as follows:


       "In summary, the Working Group considers that marker systems can form a
       useful part of a system of warnings to future generations about the location and
       contents of the repository. While well-designed markers may be durable and
       interpretable for long periods of time, the Working Group notes that it will be
       difficult to take credit for marker longevity for periods much beyond one
       thousand to several  thousand years from repository closure and
       decommissioning."


The NEA Working Croup also met with the WIPP Markers Panel to hear presentations on
the expert judgments rendered by the Panel and to audit the probability elicitation session of
one of the Markers  Panel teams (SAND 93).
6.2.5  DOE Studies

DOE has done a significant amount of work on markers for geologic waste repositories.
This work falls broadly into two categories:
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       •  Studies in the early 1980s under the aegis of the Office of Nuclear Waste
          Isolation (ONWI) directed toward repositories for high-level waste (Kap 82,
          ONWI84)

       •  Studies beginning in the late 1980s  and continuing today on markers for the
          WIPP site (SAND 91a)

Some of the concepts developed in the  ONWI work were subsequently considered for
application at a low-level waste disposal site being studied at Hanford, Washington (Adams
86).  Further information from these two DOE programs is presented in the following
sections.

6.2.5.1   ONWI Program

A Human Interference Task Force operating under the direction of ONWI conducted
extensive studies on reducing the likelihood of  human-initiated processes and events affecting
geologic waste repositories. The multi-disciplinary Task Force included members with
expertise hi law, sociology, political science, nonverbal communication, nuclear physics,
environmental science, archeology,  climatology, linguistics (and semiotics), behavioral
psychology,  materials science, nuclear  waste management and engineering (ONWI 84, Seb
84, Tan 84).

Assuming a remote, flat, non-glacial site, the Task Force proposed that granite markers
about seven meters high and spaced at  intervals no greater than 1000 meters should be used
to define the perimeter of the site.   The monolithic triangular pyramids would be inscribed
with appropriate messages  and warnings in several languages, supplemented with symbols
and pictograms.  The site would also be centrally  marked with three large triangular
monuments defining the  location of three granite storage vaults where site records would  be
stored.

The Task Force suggested  that these markers could be supplemented with earthworks and
anomalies capable of being detected by remote sensors.  Recommended earthworks included
an arrow-shaped central  plaza about 100 meters across and several meters high on which are
located the central markers and storage vaults described above and a segmented berm located
several hundred meters from the central plaza as shown in Figure 6-2.  To enhance the
durability of these earthworks, the Task Force suggested that they be covered with 0.15 to
                                         6-66

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         Periphery ii Stabilized With
           Indlgenoui Vegetation
                                                                           Document Vaults (3)
                                                                           Central Markers (3)
                                                                       	R Enforced Concrete
                                                                           Bate Mat
                                    Peripheral Earthen Berm
                                                                     Raited Earthwork Plaza
                                                                     with 15-30 cm Surface of
                                                                     Aggregate Aiphalt Mixture
Figure 6-2.  ONWI Conceptual Design of Site Markers for Geologic Repository

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0.30 meters of an aggregate asphalt mixture.  This proposal was based on the fact that
natural asphalts have been used since antiquity.  This protective layer would also hinder
growth of vegetation on the earthworks.  Because various materials would be used in
constructing the central plaza, it should create an anomaly which would remain recognizable
by several remote sensing techniques.

The Task Force reached no conclusions as to  the effectiveness of markers and other measures
to deter human-initiated processes and events.  The Task Force noted that any such
conclusions must be based on site-specific analysis.  These analyses should use probabilistic
assessment techniques to estimate the effectiveness of a highly redundant system even though
some elements may fail. The Task Force observed that the expected longevity of earthworks,
monuments and vaults was a subject requiring further investigation.

6.2.5.2    WIPP Program

In a  1979  study conducted by the WIPP Technical Support Contractor (WTAC) for DOE,
crude probabilistic estimates were made of the times which monuments and records would
persist beyond the period of effectiveness for active institutional controls (WTAC 79). The
probabilistic estimates were based on considerations  such as  the observations that records of
land  ownership and transferral in the U.S. can be traced back to the 1700s and grave stones
in U.S.  cemeteries are still legible after about 300 years.  From this type of anecdotal
evidence, it was estimated that there was a 50% probability  that markers  would persist for
200 years  beyond active institutional controls.  There was also a 50% probability that
accessible  records would be available for 110 years after markers were lost.  The study
assigned a 95 % probability to the postulate that active institutional  controls would last for
100 years.  It was also assumed  to be likely that economically recoverable hydrocarbon
resources would be depleted by the time that active and passive institutional controls were
lost.  However, it was presumed that a 50% probability of drilling at the WIPP still existed
for a 50 year period beyond loss of institutional controls.  Based on these assumptions, the
time  of isolation was calculated to be at least 450  years with 50% probability.  Probabilities
of various isolation periods are summarized in Table 6-1.

The credit for active and passive institutional controls estimated in  the WTAC study is
relatively short compared  to the  10,000 year containment period required by 40 CFR 191.
                                        6-68

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            Table 6-1.  Isolation Times Prior to Drilling in the WIPP Site Area
Probability*
0.50
0.90
0.95
0.98
0.99
Time of Isolation
(years)
450
300
250
200
150
                    " Probability that Time of Isolation beyond active
                    institutional controls is at least this duration.
More recently, in support of its WIPP-related performance assessment activities, DOE and
SNL organized four teams of experts (the Futures Panel) to provide judgments on the
probability of future human-initiated processes and events.  The Southwest Team of experts
cited an instance in their summary report where marking of a radioactive location near WIPP
has been vitiated (SAND 91a, p. D-15).  Under the aegis of the Plowshare Program (see
2.5.3 for more detail), an underground nuclear detonation was conducted in 1961 at the
Gnome Test Site, about six miles from the WIPP.  The test was performed in a bedded salt
formation at a depth of about 1,250 feet as compared to the WIPP repository depth of 2,150
feet.  The Gnome Site was marked with a single monument which, according to the
Southwest Team, already shows signs of weathering and has shifted from its original
location.

6.2.5.2.1  WIPP Markers Panel.31 Using formalism similar to that involved in setting up
the Futures Panel,  Sandia organized an expert judgment panel called the Markers Panel 1991.
The panel served the following two purposes:

       •   Qualitative - to develop design guidelines for markers and messages needed to
           communicate with future societies concerning the location and dangers associated
           with buried TRU wastes at WIPP.

       •   Quantitative - to estimate the probability that markers would survive for the
           required time period and convey the intended message.
   31 See also Section 6.2.1.7.
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The Markers Panel was divided into two multi-disciplinary teams with expertise in such areas
as anthropology, materials science, architecture, linguistics, environmental engineering,
astronomy, semiotics, archeology, and communications.  Each team developed a total marker
system design which addressed architectural design, material properties, linguistics, message
levels, message media, and other marking components (e.g., international symbols and
standards).  Based on the conceptual marker systems, each team was asked to estimate
probabilistically:

       •   the durability  of the marker system for various periods up to 10,000 years

       •   the ability of future societies to understand the message embodied in the marker
           system

The teams were asked to  assume three different levels of technology in future society; higher
than current levels, at current levels, and lower than current levels. In assessing these
probabilities, Team A divided the regulatory future into time periods of 200; 500;  1,000;
5,000; and 10,000 years after closure of the WIPP repository while Team B considered
periods of 500, 2,000 and 10,000 years after closure.  Each member of Team' A developed
individual probability estimates while Team B developed a consensus estimate. Results of
these expert elicitations, reproduced from Reference SAND 93, are included as Tables 6-2
and 6-3.

Team A's estimates that the marker system would persist for 500 years ranged from 0.85 to
0.99. The lowest probability estimates are for a society where a high level of technology is
dominant.  Some Team A members felt that such a society might be able to remove the
entire WIPP repository markers. Presumably,  they would understand the consequences of
such action. Team B estimated the probability of marker persistence after 500 years to be
0.9, independent of the state of technology.

While both teams estimated that there was a high level of probability that the marker system
would persist for a considerable period, it should be noted that the Panel was directed to
exclude cost as a factor in the conceptual marker system designs (SAND 93, p. F-21). The
extent to which the elicited probabilities would be reduced if a cost perspective was included

is unknown, but interviews with some of the members of the Markers Panel suggest that this
should not have a significant effect. The materials proposed for the marker systems are of

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            Table 6-2. Probabilities of Marker System Persisting - Team A

Expert
Ast


Brill


Goodenough


Kaplan


Newmeyer


Sullivan


Dominant
Technology
High
Medium
Low
High
Medium
Low
High
Medium
Low
High
Medium
Low
High
Medium
Low
High
Medium
Low
Years After Closure
200
.99
.99
.99
.99
.99
.99
.99
.99
.99
.9S-.99
.9S-.99
.9S-.99
.90
.95
.95
.90
.95
.95
500
.98
.98
.98
.98
.98
.98
.98
.98
.98
.9S-.99
.95-.99
.9S-.99
.85
.90
.90
.85
.90
.90
1,000
.95
.95
.95
.95
.95
.95
.90
.95
.98
.90-.95
.90-.95
.90-.95
.70
.85
.85
.80
.85
.85
5,000
.75
.75
.75
.70
.70
.85
.85
.90
.95
.80
.80
.90
.65
.80
.85
.70
.80
.80
10,000
.50
.60
.60
.50
.50
.80
.70
.75
.80
.70
.70
.85
.60
.60
.65
.50
.70
.70
Source: Table 5-1 SAND 93
       Table 6-3.  Consensus Probabilities of Marker System Persisting - Team B
Dominant
Technology
High
Medium
Low
Years After Closure
500
.90
.90
.90
2,000
.85
.80
.70
10,000
:85
.60
.40
         Source:  Table 5-2 SAND 93
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intrinsically low cost. What is not clear is whether the design and construction are also of
relatively low cost.  They may not be.32 One member of Team A observed that a
successful marker.system at WIPP "will have to be one of the greatest public works ventures
in history." This statement was predicated upon more elaborate earthworks than the Team A
consensus recommendation. If DOE is to take credit for a marker system capable of
persisting for several millennia, DOE must be prepared to make a concomitant obligation for
the construction of such a system.  A scenario developed  by one of the Futures Panel teams
posed the possibility that a future bureaucracy functioning hi the year 2020 might become
embroiled in  a major debate on closure costs and choose to authorize only a modest marker
system (LANL 91).  The scenario, as outlined from the perspective of someone recounting
the debate 25 years hence, is as follows:

       "The markers recommended by a panel of experts convened by the now
       defunct Department of Energy in 1990 are widely  viewed as extravagant in
       view of the fact that the WIPP repository has not been used to capacity and is
       such a controversial topic.  It now seems unlikely  that the site could ever be
       forgotten, its potential hazard is thought to be less than originally foreseen,
       and it seems politically dangerous to advocate large sums of money for it in
       view of the pressing current social problems  which followed the costly
       conventional weapons buildup of the 1990s.  After protracted debate lasting
       several years, Congress finally appropriates money for the markers, although
       design compromises must be made because it is not enough to pay for the
       extensive marker system envisioned in 1990."

In eliciting expert judgment as to the probability that the message  contained on/in the
markers would  be correctly interpreted  by future intruders, various levels of technology and
various time periods were considered in a manner similar to that used to assess the
probability of marker persistence.  In addition, five  conceivable motivations for intrusion
were appraised  including drilling for water, mineral exploration, drilling to create injection
wells for waste disposal,  archeological investigation, and  other scientific investigation.
Generally,  the panelists grouped the first three intrusion modes together and treated the last
two as a second group.  Probabilities estimated by the two panels  for intrusion driven by
mineral exploration are summarized in Table  6-4 (SAND 93).

Turning again to Team A's 500 year estimates, it can be  seen that the probability of correct
   32 The NKS Working Group KAN-1.3 indicated that the structures proposed by the WIPP Markers Panel might
cost tens of millions of dollars (NKS 93).

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interpretation of the marker message ranged from 60 to 90% for a technologically less
advanced society to 90 to 98% for a technologically more advanced society.  On the same
basis, the Team  B probability estimates ranged from 70% to 90%.  Higher probabilities were
assigned to understanding the marker message by potential intruders seeking archeological or
other scientific knowledge.

If one averages the individual Team A estimates and then averages Team A and Team B
estimates,  the probability of correct interpretation of the marker message by a future society
conducting mineral exploration with the same level of technology as today is 0.91 at 500
years after closure.  Performing the same type of averaging for marker system persistence,
the probability that the system will persist at the current level of technology after 500 years
is 0.93. The probability that the marker: will persist and that their message will  be correctly
interpreted is therefore 0.84/

The Markers Panel recommended that additional study is warranted in three areas:

       •   Durability of marker materials under the WIPP site conditions including the
           mechanism for attaching or inscribing messages and the interaction of wind, sand,
           and water with marker materials and configurations

       •   Interpretation of graphic or pictorial messages that are independent of culture

       •   Interpretation of written messages that are independent of culture

6.2.5.3    Project PLOWSHARE and  Related Tests

The Atomic Energy Commission (AEC) established the PLOWSHARE program in June
1957, under the technical direction of the Lawrence Radiation Laboratory (LRL),  now known
as the Lawrence Livermore National Laboratory. The program consisted of 27 nuclear
detonations conducted at the Nevada Test Site (NTS) and other sites in Colorado (2) and
New Mexico (2) from 1961 to 1973. The nuclear tests were all underground, either  shaft or
cratering shots,  and had yields of no more than 200 kilotons. The PLOWSHARE nuclear
detonations were designed to explore nonmilitary applications of nuclear explosives.  The
primary potential use envisioned was in large-scale engineering projects such as canal,
harbor, and dam construction, the stimulation of oil and gas wells, and mining.

The ultimate goal of PLOWSHARE, peaceful applications of nuclear explosives, was never

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        Table 6-4.  Probability of Correct Interpretation of Marker Message Intrusion by Mineral Exploration

Expert

Ast
Brill
Goodenough
Kaplan
Newmeyer
Sullivan

Team B

200 Years
Technology ซ
Hป
.99
.99
.99
.99
.99
.95
M
.99
.99
.99
.98
.99
.95
L
.98
.95
.99
.95
.90
.80
500 Years

.90

.90

.80
500 Years
Technology —
H
.98
.95
.95
.98
.90
.90
M
.95
.95
.95
.90
.85
.90
L
.70
.90
.70
.70
.80
.60
2,000 Years
1
.90 1 .85

.70
1,000 Years
Technology =>
H
.95
.95
.90
.97
.80
.85
M
.90
.95
.90
.85
.70
.85
L
.50
.70
.50
.65
.50
.40
10,000 Years

.99

.80

.30
5,000 Years
Technology ซ
H
.90
.95
.65
.95
.70
.70



M
.20
.95
.60
.80
.60
.70



L
.10
.60
.15
.50
.40
.10



10,000 Years
Technology =
H
.90
.95
.50
.90
.50
.40



M
.20
.95
.40
.75
.30
.40



L
.05
.50
.02
.02
.20
.01



* The levels of technology being more advanced than today (H), similar to today's level (M), and less advanced than today (L).




Source:  Table 5-4, SAND 93

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realized. The 1963 atmospheric nuclear test ban treaty caused cancellations of many of the
plans, such as those for dredging canals and excavating harbors.  Other factors contributing
to the failure of PLOWSHARE to fulfill its goal were changes in national priorities,
Government and industry > disinterest in the program, public concern over the health and
safety aspects of using nuclear power for civil applications, and shortages in funding.
Several other underground nuclear tests (Vela Uniform Events and weapons tests) were also
conducted away from the NTS. A total of 11 underground nuclear tests were conducted at
locations other than the NTS since the beginning of testing through December 1973.

Comments on a few of these tests relevant to human intrusion and passive institutional
controls are discussed below.

Project Gnome:

       Project Gnome, a shaft detonation, was fired on December 10, 1961, at a site 40
       kilometers southeast of Carlsbad, New Mexico. The site was in the Salado formation
       of the Delaware Basin.  This geologic formation consisted primarily of halite (rock
       salt), with minor traces of anhydrite,  polyhalite, silt, and claystone.  The top of the
       salt formation was approximately 710 feet below the site surface.  The device was
       buried 1,184 feet underground in bedded rock salt at the end of a  1,116-foot hooked
       tunnel meant to be self-sealing.  A shaft 1,216 feet in depth and ten feet in diameter
       ended in a station room connected to  the tunnel.  The detonation,  which had a yield
       of 3.1 kilotons, resulted in an underground dome-shaped chamber 60 to 80 feet high
       and 160 to 170 feet in diameter.

       All Gnome site decontamination and decommissioning activities were completed and
       terminated on September 23, 1979.  A concrete and bronze monument was erected at
       the Gnome surface ground zero location as an historical marker.  The following
       wording was inscribed on two bronze plates:
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          Historical plate:
                                     United States
                              Atomic Energy Commission
                           Dr. Glenn  T. Seaborg, Chairman

                                    Project Gnome

                                  December 10, 1961

          The first nuclear detonation in the Plowshare Program to develop
          peaceful uses for nuclear explosives was conducted below this spot at
          a depth of 1,216 feet in a stratum of rock salt.  The explosive,
          equivalent to 3,100 tons of TNT, was detonated at the end of a
          horizontal passage leading from a vertical shaft located 1,116 feet
          southwest of this point.  Among the many objectives was the
          production and recovery of useful radioactive isotopes, the study of
          heat recovery, the conduct  of neutron physics experiments, and the
          provision of seismic source for geophysical studies.

          Restrictive plate:

          No excavation and/or drilling is permitted to penetrate Section 34,
          Township 23 South, Range 30 East, New Mexico Principal Meridian,
          at any depth between the surface and 1,500 feet. (DOE 81)

      If Section 34 is  leased, a "special stipulation" is  to be put into the lease by the U.S.
      Geological Survey (USGS). This stipulation would require the drilling operator to
      abide by the lease  stipulation to protect the area  between the surface and 1,500 feet
      below the surface; no exceptions  are to be allowed. The BLM is to ensure that no
      drilling or excavation will occur.
Project Rulison:
       Project Rulison was an experiment co-sponsored by AEC and Austral Oil Co. to
       determine the technical and economic feasibility of using nuclear explosives to
       stimulate the flow and recovery of natural gas from the Mesa Verde formation hi the
       Rulison Field, Garfield County,  Colorado.  The test, conducted near Rifle, CO on
       September 10, 1969, consisted of a 43 kiloton nuclear explosive emplaced at an 8,426
       foot depth.  Production testing began in 1970 and was completed in April  1971.
       Cleanup was initiated in 1972 and wells were plugged in 1976. Some surface
       contamination resulted from decontamination of drilling equipment and fallout from
       gas flaring (burning). Soil was removed during the cleanup operations.


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Project DRIBBLE:

      Project DRIBBLE was comprised of four explosive tests, two nuclear and two gas.  It
      was conducted in the Tatum Salt Dome area of Lamar County, Mississippi, near the
      communities of Baxterville and Purvis, under the Vela Uniform Program. The
      purpose of Project DRIBBLE was to study the effects of decoupling on seismic
      signals produced by explosives tests.  The first test,  SALMON, was a nuclear device
      with a yield of about 5.3 kilotons, detonated on October 22,  1964, at a depth of 2,710
      feet. This test created the cavity used for the subsequent tests, including STERLING,
      a nuclear test conducted on December 3, 1966, with a yield of abou| 380 tons, and
      the two gas explosions, DIODE TUBE, conducted on February 2, 1969,  and HUMID
      WATER, conducted on April 19, 1970.

      The nuclear tests resulted in the release of radioactive elements into the salt rock.
      Although most of these radioactive elements remain in the salt dome, some
      contamination in the form of radioactive drill cuttings, drilling muds, and water was
      brought to the surface during the drilling of boreholes into the shot cavity.  Today,
      the Tatum Dome Test Site has largely returned to its original state. Except for the
      monument the U.S. Department of Energy erected over the location of the actual
      subsurface detonations (called Surface Ground Zero), there is little indication of any
      of the past activities at the site.  The areas where soils were  excavated have been
      backfilled and seeded and now have a well established cover of vegetation. Wildlife
      is abundant at the test site and the area is used for timber production and hunting.

Although the residual levels of radioactivity remaining at most of the test sites are not
extensive enough or high enough to pose an imminent or substantial risk to the environment
or public health, DOE, in conjunction with the EPA and the involved states, has continued to
investigate and monitor the sites. These continued investigations are driven, in part, by the
environmental laws of the states and federal governments and, in part, by the concerns that
have been raised by the public with respect to the safety of the sites.  For example, U.S.
Senator  Lott identified four major issues related to the Tatum Dome Test Site in an October
1989 letter to the U.S. Department of Energy.  One of those issues  was:  "The control of
access to Surface Ground Zero." (DOE 93b)

In addressing Senator Lott's issues, DOE has committed to conducting additional

                                         6-77

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investigations and studies at the Tatum Dome Test Site.  As such, DOE will conduct a
Remedial Investigation at the site to determine if the use of the nonradioactive hazardous
substances at the site has resulted in contamination of the soil, groundw'ater, or surface
water.  A feasibility study will also be performed to determine what measures can be taken
to reduce risks associated with the  site.  One of the measures that will be evaluated is the
need for fencing of the site to maintain institutional control over access to the facility.

The routine annual sites visits by the Environmental Monitoring Systems Laboratory include
groundwater, air, and biological sampling.  Results are reported annually in the EPA's
Offsite Environmental Monitoring Report.

As to how much radioactivity was  released and how much is left, the Nevada Environmental
Restoration  Project (ERP) is presently sponsoring a determination of this for all underground
tests at the NTS.  This work is being performed  by the Lawrence Livermore National
Laboratory and the Los Alamos National Laboratory.  To date,  similar work for NTS off-site
tests has not been funded.  For the NTS on-site tests, ERP personnel are calculating
inventories of fuel, fission products,  and activation products initially and at the end of 1992.
The work and calculations for the NTS on-site Plowshare tests are probably complete by
now; however, the results are classified, but DOE/NV expects to declassify summaries
(DOE 94a).

All NTS off-site PLOWSHARE sites have been decommissioned. This has included
plugging wells into the cavities and cleanup of surface structures and waste sites.  Remedial
investigations/feasibility studies are being conducted. Monuments were erected at Gnome
and the Tatum Dome sites warning against excavating at the sites. Similar warnings were
attached to the property deeds.   Status of site markings at the other NTS off-site sites is not
well documented and is currently being investigated (DOE 94b).

6.2.6  No Marker Strategy

Some have  suggested the possibility that no markers be erected  at the repository site
(SAND 90a, LANL  91).  The presence of markers on which the  meaning of the inscriptions
has been lost might create a desire by future archaeologists to understand the function of the
site. This desire could result in intrusion.  The markers could, in essence, constitute an
attractive nuisance encouraging intrusion,  Kaplan suggests that a marker with a so-called
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Level I message which serves solely as an attention getter might have this result (Kap 82).
She also suggests that such a situation could be avoided if a Level n message is conveyed
which is both an attention getter and a warning ("something is here and it is dangerous").
Kaplan points out that an earthwork marking a site may convey only a Level I  message.
But, if the earthwork were in the form of a recognizable  hazardous/radioactive waste symbol,
the marker would be a deterrent rather than  an invitation to some future intrusion.  However,
Givens remarks that prohibitions, curses, and other dire warnings have been  "sorry failures"
in deterring tomb robbers (Givens 82).

The Southwest Team of the DOE WIPP Futures Panel suggested the possibility of using a
"soft" marker strategy.  The site would be delineated by  surface markers which decay after a
few centuries (LANL 91).  This would encompass the initial period of relatively rapid
radioactive decay and the period when comprehension of the marker message has the greatest
probability of being understood.  The soft surface markers would be supplemented  with
subsurface markers which would serve as a  warning to a technologically advanced future
society.

The no-marker strategy was rejected by the  WIPP Marker's Panel and the NKS Working
Group KAN-1.3 (NKS 93). Team A of the Marker's Panel felt that it would be an
"abdication of moral responsibility" not to warn future generations of the buried potential
hazard (SAND 93). Team B of the markers Panel recommended marking the site as a less
risky approach  than not marking it, because of the current exploitation of hydrocarbons and
potash in  the vicinity.  The NKS working group report did not  elaborate on the basis for
their decision.
 6.3    Public Records and Archives

 This section discusses the use of public records and archives as passive institutional controls.
 The use of such controls would be designed to increase the probability that institutional
 knowledge of the WIPP repository will not be lost by future societies. This section deals
 specifically with records and archives located away from the repository site.  With regard to
 the types of records to be considered for archival purposes, the NKS Working Group has
 suggested the following (NKS 93):

       •   Geographical location of the repository

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       •  Chemical and physical properties of the waste

       •  Design of the repository including physical shape and barriers

       •  Background information and data used in the final safety (risk) assessment

       •  Various background materials including the final safety assessment, laws and
          regulations, general information from and about society, and operational records
          of the repository

6.3.1  Regulations

6.3.1.1   WIPP Land Withdrawal Act (LWA)

Under the terms of the WIPP Land Withdrawal Act (PL 102-579), which was signed into
law on October 30, 1992, 16 square miles of land around the WIPP site are withdrawn from
all forms of entry, appropriation, or disposal under the public land laws.  According to Sec.
3(c), Land Description, of the LWA, the boundaries of the withdrawn land for the WIPP site
are described on  a map issued by the U.S. Bureau of Land Management (BLM) of  the U.S.
Department of Interior entitled "WIPP Withdrawal Site Map," dated October 9, 1990, on file
with the New Mexico  State Office  of the  BLM.  Under the LWA, the Secretary of the
Interior is required to publish a description of the withdrawal  area in the Federal Register
and to file copies of the legal description  of the withdrawal area and the site map with the
U.S. Congress, the Governor of the State of New Mexico, the Secretary of Energy, and the
Archivist of the United States.

On November  24, 1993, the Bureau of Land Management published a description of the
WIPP in the Federal Register as required by the LWA (57 FR 55277). The notice  is
included as Appendix A.  BLM also submitted the required documentation to various
governmental organizations on November 16, 1992. A sample transmittal letter is included
as Appendix B.  (While this information was supplied to the Archivist of the United States
and presumably has been filed, the existence and location within the Archives have  not been
uncovered in spite of numerous inquiries.)

6.3.2  Historical Perspective on Use and Survivability of Records

Although records describing the WIPP  site have been filed with various government

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agencies, the key question to be asked is "Will these records persist and for how long?"  An
essential element in the efficacy of records as a component in a passive institutional controls
strategy is survivability of the records.  Written or pictographic records have endured for
almost 6,000 years.  Sumerian inscriptions have been documented on stone dating from about
3600 B.C. and on clay tablets from about 3200 B.C.  Egyptian hieroglyphics on various
monuments date from about the same time.  The famous Code of Hammurabi was inscribed
on diorite in about 2100 B.C. (Dur 54). Written Chinese, which dates to the Shang dynasty
(1766-1123 B.C.), has remained  substantially  unchanged over the millennia.

Various investigators have suggested that records be located in numerous locations and
include several vehicles such as maps, land-use records,  geological surveys, and archival
facilities (Tan 84, Gillis 85, Givens 82). This redundancy of record keeping will increase
the probability that records will survive at some location.  Even so, Tannenbaum has
observed that storage materials may not last for the required 10,000 years;  therefore, records
must be periodically reproduced and perhaps translated into contemporary  language (Tan 84).
Such reproduction will require the existence of a "responsible institutionalized authority" to
periodically undertake this reproduction and revision. Since the availability of long term
record keeping materials  and the existence of a responsible authority to maintain records are
questionable, the future availability of repository records in useful form  is also questionable.
Arguably, periodic updating of records to insure that they are comprehensible to future
societies is a maintenance procedure beyond the scope of passive institutional controls
envisioned by the EPA in developing the 40 CFR 191 Standards.

Gillis mentions a downside to record-keeping  redundancy (Gillis 85).  Dispersal of the
information to insure its survivability may reduce detectability by persons  at the site for
whom it is most relevant.

A second key question regarding records is whether they will be understood if they do
survive.  These  are the same key questions which must be answered with  regard to markers.
The example of the Rosetta Stone, a three language monument used in unlocking Egyptian
hieroglyphics, is often cited as an example of how maintenance of records in several
languages will promote future understanding (Kap 86).  However, as Givens has pointed out,
translation  may be accomplished "at the expense of years of sometimes painful
decipherments"  (Givens 82). He also notes that some ancient scripts remain undeciphered
even today, citing Mayan, Indus Valley, Minoan Linear A, Germanic and Turkish runes,  and
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certain African scripts. With regard to the use of icons to covey messages, Givens observes
that even the most simple and obvious iconic signals left by antiquity may not be completely
understood by a future society.

Seboek also takes issue with use of the Rosetta stone as a "success story" vis-a-vis language
redundancy as an aid to communication with future societies (Seb 84).  He observes that,
although the stone's importance was instantly identified as a possible key to deciphering
hieroglyphics upon its discovery in 1799, its "mere existence  .... did not make solution
automatic." The puzzle was not solved until 1822.  Kaplan takes a more sanguine view of
the deciphering of the Rosetta stone, noting that one month after the stone was made
available to scholars, the Greek text had been translated and presented at a scientific meeting
(Kap 82).  This certainly argues for a multiple language approach.

The NBA Working Group cited historical examples, drawn from French experience, of lost
records (NBA 93).  In the civil war of 1870, a fire in the Tuileries Palace destroyed archives
relating to Paris.  In World War n, many records were destroyed during bombing raids.
These examples reinforce the need for worldwide, redundant record storage. Despite past
problems, the Working Group felt that it was reasonable to assume maintenance of records
for 500 years.

The Nordic Working Group KAN-1.3  commissioned studies on German archives in the 20th
century and the Vatican archives since their inception (NKS 93).  Both  studies provided
examples of major losses of archival information as well as successful attempts to protect and
shelter the information. In the German study, an observation was made that many losses
occurred after World War  n. The German people,  driven by extreme poverty, found paper
in the poorly guarded  archives to be useful for such basic needs such as fuel or wrapping
groceries.   The NKS Working Group deduced from these studies that loss of archival
information is often engendered by forces different from or external to the institutions which
created the archive. Accordingly, they concluded that  "an international and internationally
respected archive  would represent a robust  strategy."  The Working Group suggested that
IAEA might be a  candidate archive manager.
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6.3.3  Survivability of Land Ownership Records

6.3.3.1    Introduction

The EPA disposal regulations include a requirement that "[disposal sites shall be designated
by the most permanent . . . passive institutional controls practicable to indicate the dangers
of the wastes and their location."33 The term passive institutional controls includes "public
records," which incorporate state and federal land records.  The issue presented in this
section is whether existing state and federal land records will effectively delineate the WIPP
so as to provide the most "permanent .  . .  passive institutional controls practicable."

If the benchmark of "practicable permanence" is the time period over which cumulative
releases are to be limited, there are innumerable complexities and uncertainties. Use of
historical analogues is largely inadequate to determine whether land records of the WIPP
withdrawal would survive for even a significant portion of the 10,000 year period following
disposal.  Writing is believed to have been developed in Mesopotamia as cuneiform only
5,000 to 6,000 years  ago.  Slightly later, hieroglyphics  were developed in Egypt.  Chinese
script is  the oldest writing still in use.   A form of script used from around 1300 B.C. is still
recognizably related to modern Chinese. The fact is, however, that writing itself has only
been in existence for  about 5,000 years. Based upon historical precedent, it would be sheer
speculation to conclude that any written record would last for 10,000 years.

6.3.3.2    Historical Land Records

Land ownership records  were maintained by different civilizations for a variety of reasons.
In most instances, preserving an accurate list of current land owners was not a  high priority.
In many civilizations, alienation of land (i.e.,  disposal)  was not widespread.  In some
societies, it was forbidden (e.g., in 6th century B.C. Athens, alienation of land from the
family was largely prohibited). The legendary Doomsday Book,  compiled in 1086 A.D. at
the behest of William the Conqueror, is the greatest land record of medieval Europe.  It is
currently displayed at the Public Record Office in London.  This book was not intended to be
an ongoing record of land transfers.  It was used as a means of settling feudal controversies
that had  arisen from the Norman conquest  so  that the King could obtain needed assurances
   33 40 CFR ง 191.14(c).
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from all his feudal tenants of substance.

From at least the 2nd century B.C., the Romans had a cartesian system of land records that
was very precise.   To the extent that the records have survived, they demonstrate a concern
with obtaining an  accurate "snapshot" of land ownership from time to time, rather than a
record of land transfers.  This is consistent with the purpose for which the records were
maintained, namely obtaining the correct amount of tribute from each landholder in the
provinces.

Some historical land records showing a "snapshot" of land ownership have survived,  largely
by historical accident.  There is no indication that the keeper of the records considered them
to be of lasting significance.  Thus, there is no way of judging, for example,  how durable
Roman provincial land  records would have been had there been any premium placed  upon
their lasting existence.

Ironically,  the ancient people with the greatest sense of history, the Jews, had no  enduring
need for land records because of political domination by others and a nomadic existence.
This irony  was heightened two millennia later in England.  In medieval England,  an  effective
system of recordation and registration of security interests in lands was developed by the
Exchequer  of the  Jews.  The registration of sealed contracts before officials at the Jewish
Exchequer  in certain towns in England was an effective recording system and provided
necessary notice to all concerned.   It thus fulfilled the chief objectives of livery of seizin34
and was an extremely successful incursion into the feudal  system.  The system was too
successful to suit  those who had a considerable interest in the maintenance of the  feudal
system and ended with  the expulsion of the Jews from England in  1290.

6.3.3.3    State Land Records  in the United States

In this country, real estate recording is usually done at the county  level under state law.  The
systems used generally  resemble the type first used in the Massachusetts Bay  Colony in the
1600s.  Documents which may  affect title to real estate are presented for recording.
Recording  gives legal priority over possible conflicting interests.  Otherwise,  title may be
lost to a  subsequent transferee who has recorded his deed or other document  affecting title.
   34 Ancient ritual involving the giving of notice of land ownership.

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As a rule, recording is not a prerequisite to legal validity between the parties to a land
transaction.  Deeds and other instruments may create interests in property even if they are
not recorded.  Furthermore,  recording a void instrument will not normally make it effective.
Unless there is a land registration system in effect, which is unusual in this country,
acceptance of an instrument for recordation is not an official determination that the
instrument is legally effective.

Recording systems tend to use either a grantor-grantee or tract index, the former being older
and more prevalent. In a grantor-grantee index, instruments are indexed alphabetically
according to the grantor's and grantee's surnames. The grantee index is used to search from
the present back to the beginning of the recording system to establish the chain of owners.
The grantor index is used to find adverse recorded conveyances made by or through each
owner during  the time that the owner was the apparent or actual owner of the property in
question.  This type of index is inexpensive to maintain but difficult to use.

A tract index  organizes instruments according to the property  they affect.  Instruments
affecting each segment of land are indexed for that parcel.  A tract index is easy to use, but
more expensive to maintain than a grantor-grantee index.

Regardless of which type of index is used, the recording system in this country leaves much
to be desired.  It does not necessarily show who the actual owner is of a particular piece of
property. Unrecorded interests may be valid and  recorded interests may be void.  It would
be unusual for these records to show a withdrawal of public land.

A system of title registration, as opposed to  recordation, is used in a few parts of the United
States and throughout the United Kingdom and Scandinavia. Perhaps the most popular
system of land registration is the so-called Torrens system, which is modeled after a title
registration  method used for ships.  Under a system of land registration, the government
actually determines that a valid conveyance has been made. In  other words, each time a
document is registered, there is an administrative  determination analogous to the judicial
determination made in a quiet title action35.  Registration of a conveyancing document is a
    "Quiet title actions are lawsuits that are brought to settle land ownership disputes. The court
 decides  who  owns  the  land and  , after all appeals have  been exhausted, that  decision is
 controlling.  The point being made here is that under a system of land registration, every time
 a document is registered, the administrative body that registers the document has to decide
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prerequisite to its validity in most of those jurisdictions having a registration system.
Therefore, a registration system is much more likely than a recordation system to show who
the actual owner (s of a particular piece of property. However, governmental action, such as
a reservation or withdrawal of public lands,  would not necessarily be reflected in a
registration system.

6.3.3.4    Public Land Records

Public land records are maintained by the Bureau of Land Management (BLM),  which is part
of the United States Department of the Interior.  These records generally consist of a master
title plat, a use plat, mineral lease plats, an historical index, a serial  register, and case files.
The master title plat is a copy of the official survey or a composite of several surveys.  It
contains references to all patents, reservations, withdrawals, rights-of-way, and similar
actions.  The references on the master title plat have generally consisted of weighted lines
and abbreviations and is not always easy to use.

The use plats show  what uses are being made of public lands, with some exceptions, e.g.,
grazing leases.  Oil and gas leases appear on a separate  use plat.  Other mineral leases
appear on  separate plats.

The historical index is a chronological narrative of reservations, withdrawals,  and other
actions that have  affected the use or title to public lands. Much of the same information will
appear on the master title plat and the use plat.

The serial  register is an index to all filings made with respect to a particular application,
such as an offer to lease.  In the serial register, an offer to lease, for example, would be the
date of issuance of the lease, approval of any assignments, and any applications for
extension.  There is a serial register sheet for each filing.

The case file contains the original instruments that have been filed for an oil or  gas lease, the
land office copy of the lease or application,  and related  correspondence.  Case files are listed
whether the document is valid and whether there has been a conveyance, i.e. who owns the land.
This is similar to what a court does in a quiet title  action, and very dissimilar to what most
county "recording"  offices do when they dimply accept for filing a document that is given them
and make no determination concerning its validity or who actually owns the property.

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under the serial number for the particular offer, application, or lease.

In addition to the records listed above, there are other public land records that are available,
but these are of solely historic significance because they do not necessarily contain current
information. These are the tract books and.the plat books.  The plat book contains plats
arranged by township and range numbers.  The tract book contains entries affecting lands by
land description.

Because the WEPP is located  on public lands, the durability and reliability of the public land
record system is relevant in determining  to what extent there would be permanent, passive,
institutional controls.  The system described  above has not been ideal.  Indeed, the United
States Supreme Court had even attempted36 to define away much of the problem by
excluding from the definition of "public  lands," lands  that were subject to the claim of a
third party, whether or not that claim was valid.37  If lands to which any questions exist
regarding title are excluded from the definition of "public lands," administration of the public
lands becomes easier.

6.3.3.5    Past Problems With Public Land Records

It is possible to describe particular circumstances in which the public land records system has
not proven to be a reliable indication of  land use, title,38 or description.  These have been
recurrent problems that can be examined to see whether or not the pubb'c land records are a
passive institutional control that is permanent and practicable for purposes of describing the
WIPP withdrawal.
    36The  Court has not been consistent in its definition of "public lands."  To the  extent,
 however, that they attempted to define away the problem, as stated in the text, they probably
 succeeded in alleviating some of the burdens associated with administering the public lands, i.e.,
 the federal land management agency's problems,  but  did little to solve  the problems of the
 claimants who may otherwise have had a valid claim to public lands.

    17 Newhall v. Sanger, 92 U.S. 761, 763 (1875); Bardon v. Northern PacificR.R., 145 U.S. 535, 545 (1892).

    M Traditionally the public lands were equated with the public domain obtained by the United States  from the
 1780s until 1867. This definition has been expanded over the years and now includes interests in land and "acquired
 lands." 43 U.S.C.  ง 1702(e). But see, Columbia Basin Land Protection Association v. Scheslinger, 643 F.2d. 585,
 601 (9lh Cir. 1981). Acquired lands were lands that had been in non-federal ownership and, subsequently, were
 granted or sold to  the United States by an individual or a state.

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The previously mentioned approach taken by the Supreme Court over a century ago to define
away the problem of third party claims is indicative of one problem that has beset the public
land record system and the administration of the public lands for many years.  In the Treaty
of Guadalupe Hidalgo in  1848, the United States obtained lands that had previously been
owned by Spain.  The United States was confronted with claims of title based upon Spanish
grants.  Some of these were recognized by the United States; others were not.  However,
this is not a problem that should have any bearing on the public land records accurately and
enduringly depicting the WIPP withdrawal.

Another problem with the public land records system  that was ultimately recognized by
Congress when it enacted the Federal Land Policy and Management Act ("FLPMA")39 in
1976, was  inaccurate surveys.40  Some of the original surveys of the public lands
erroneously omitted entire tracts of land. Omission of these lands from the surveys were due
to simple error, laziness, or, in some cases, outright fraud on the part of the surveyors.
Generally,  it has been held that title to these omitted lands is in the United States and that
they are subject to administration under applicable public land laws.  Although  hypothetical^
this could be a problem in administering the WIPP withdrawal and identifying the lands
withdrawn based upon existing public land  records, this is extremely unlikely.

Until 1976, when FLPMA was enacted, there were no reliable records of unpatented mining
claims.  The holder of the mining claim did not have to file any notice of the location41
with the federal government.  A valid, unpatented mining claim is a property right and BLM
was faced with a serious  problem in administering the public lands without any reliable
indication of where these claims were.  Since enactment of FLPMA, notice of all mining
   39 43 U.S.C. งง 1701-1782.

   * Section 211 of FLPMA authorizes the Secretary to convey omitted lands and unsurveyed islands to states or
their political subdivisions without regard to the acreage limitations contained in the Recreation and Public Purposes
Act.  In some circumstances such lands could also be conveyed to an individual occupying and developing such
lands for a period of five years prior to January 1, 1975. 43 U.S.C. ง 1721.

   41   There is no reason to delve into the refinements of the Mining Law of 1872.   At the  risk of
oversimplification, a mining claim is "located" when the miner stakes out his claim and complies with the Mining
Law of 1872. No action is required by BLM or the Department of the Interior in order for this claim to be valid.
The miner is entitled a patent of the lands containing his claim for which he must make a nominal payment, but he
is not required to obtain a patent. If a miner does "proceed to patent" and the Department of the Interior finds that
there has not been a valid discovery, not only will the miner not receive the patent, but also the claim will be
invalidated.

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claims, past and future, must be filed with BLM.  If the required notice is not filed, the
claim is deemed abandoned.  Consequently, this is no longer a problem.

A problem that BLM has occasionally encountered arises from administering interests, e.g.,
oil and gas  rights, in land that has not been surveyed under the System of Rectangular
Surveys.  In Texas,  for example,  surveys are by metes and bounds and do not always close,
which may  cause the description to be inadequate.  This, however, is not a problem in New
Mexico and should not affect the WIPP withdrawal.

Managing 200 years of paperwork relating to the public lands42 is a daunting task at best.
This is especially true in light of the roughly 3,000 public land laws that have been enacted,
repealed,  or amended at various times in our history.  Furthermore, BLM public land
records are maintained at various  offices in the western states and in an eastern  state office.
This massive paperwork problem  could  easily affect the viability of BLM public land records
as suitable passive institutional control,  i.e., the most permanent passive institutional control
/
practicable.  Fortunately, as  discussed below, the BLM public land records are being
converted to disks and a software has been developed that will make such records readily
accessible.

With regard to land  withdrawal, it should be noted that since 1976 the Secretary of the
Interior has had authority under FLPMA to withdraw federal lands43 from "settlement,  sale,
location,  or entry" under the general land laws.  Prior to 1976, the Secretary  had withdrawal
authority  delegated to him by the  President.

Although there are two cases44 that suggest otherwise, the well-understood rule is that a
    42 One of the first problems confronted by the Continental Congress was how to dispose of the western lands
that the original states had ceded to the new federal government. The Continental Congress responded by enacting
the Land Ordinance of 1785, which established the rectangular system of survey and subsequently,  in 1787, the
Northwest Ordinance, which provided for new states to be admitted into the union on an equal  footing with the
existing states when certain conditions were met.

    43 The term "federal lands" is broader than "public lands" and includes land administered by agencies other than
BLM.

    44 Mountain States Legal Foundation v. Andrus, 499 F. Supp. 383 (D. Wyo. 1980). The court in War 7 Wildlife
Federation v. Wan, 571 F. Supp.  1145 (D.D.C. 1983) assumed that the withdrawal provisions in FLPMA could
be used to prohibit mineral leasing.  Neither opinion is particularly cogent in this regard.  The terms used in
FLPMA — "settlement, sale, location, and entry" — contemplate the transfer of title, not the issuance of a mineral

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withdrawal has no effect upon discretionary disposals, such as oil and gas leases, but simply
upon non-discretionary disposals, e.g., settlements, sales, locations, and entries.  This is
consistent with how withdrawals were defined for the 200 years preceding FLPMA.

The rationale behind this definition is that lands do not need to be "withdrawn" from the
operation of the mineral leasing laws,  for example.  The Secretary of the Interior can simply
refuse to issue a lease.  On the other hand, when someone can acquire rights in the land
without the  Secretary or any other official doing anything, such as "locating a mining claim"
under the Mining Law of 1872, a withdrawal may be necessary to prevent the lands from
passing out  of federal ownership or control.  Mineral leasing would not be an immediate
concern to a knowledgeable BLM employee simply examining New Mexico land records
with a view towards a possible withdrawal of those lands from settlement, sale,  location,  and
entry.

Furthermore,  Congress itself withdrew the lands comprising the WIPP.43  There are
procedures established in FLPMA that may have uncovered any oil and gas leases and any
other "natural resource uses and values of the site and adjacent public and non-public
lands"46 had those procedures been followed. This does not suggest that Congress may not,
or should not,  exercise its  virtually limitless power over public lands and withdraw such
lands when  the need arises.  However, when Congress does so, procedures that Congress
itself has established in FLPMA may be ignored, and existing uses of the lands  to be
withdrawn are not fully assessed or understood.

6.3.3.6    Automation of Public Land Records

BLM is in the midst of an effort to have its public land records placed in a computerized,
lease.  Udall v. Tollman, 380 U.S. 1 (1965). For a Court of Appeals decision, albeit pre-FLPMA, that recognizes
the distinction between a refusal to issue a lease and a withdrawal, see Duesing v. Udall, 350 F.2d 748 (D.C.Cir.
1965), cert, denied, 383 U.S. 912 (1966).

   45  Section 2(22) of the WIPP Land Withdrawal Act defines "withdrawal" to mean an area of land, rather than
in its usual sense, which is removing that land from settlement, sale, location, and entry.

   46 43 U.S.C. ง 1741(c)(2).  Although the Congressional veto provision in 204(c)(l) of FLPMA, 43 U.S.C. ง
1741(c)(l), is probably unconstitutional, Immigration & Naturalization Serv. v. Chada, 462 U.S. 919 (1983), there
is no reason why Congress cannot direct the Secretary to provide it with certain information concerning a proposed
withdrawal as it did in section 204(c)(2).

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"user friendly" data base. The focus of these efforts is the Automated Land and Minerals
Records System (ALMRS), which combines records of ownership, authorizations, and use
affecting the public lands. This information will come from BLM's 400,000 land and
mineral case files.  Also included will be data on legal land parcels defined in the Public
Land Survey System (PLSS).  These data will form the Geographic Coordinate Data Base
(GCDB), which will incorporate the PLSS and will tie map information to points on the
ground by latitude and longitude.

GCDB will allow ALMRS data to be overlaid on discrete parcels and will provide immediate
access to data on land ownership, use, and authorizations.  This data base will probably be
operational by the mid-1990s. In addition, by the year 2000, resource data will be integrated
with the ALMRS data to depict the  resource values and management concerns relevant to
each parcel of public land.

6.3.4  Contemporary Examples of Lost Government Records

The following sections describe several contemporary examples where rectirds have been
"lost" or at least unknown or unavailable to those in  need of them on a timely basis.
6.3.4.1     Oil and Gas Leases Near WIPP

The New Mexico Environmental Evaluation Group (EEG) conducted a detailed analysis of
oil and gas leases in the vicinity of the WIPP.  EEG described a situation in which the U.S.
Department of Energy failed to document the presence of a producing oil and gas well under
the southwest corner of the WIPP Land Withdrawal Area (EEG 92).  A brief history of this
loss in institutional knowledge, derived from the EEG report, is described below.

       May 1952 - Conoco obtains an oil and gas lease NMPM Lease # NM 02953 covering
       all of Section 31, T22S, R31E. (This lease lies wholly within what is now the WIPP
       land withdrawal boundary described in 6.3.1.1 above.)

       February 1959 - Conoco lease is divided.  The southern half assigned to Richardson
       and Bass  as Lease NM 02953-C.

       November 7,  1976 - Bass files for a permit to drill a well  on Lease 02953-C.

       December 10,  1976 - Energy Research and Development Administration (ERDA),

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       now DOE, files notice in the Federal Register of intent to withdraw 17,000 acres of
       public land including Section 31 T22S, R31E for waste disposal site.

       January 20, 1971  U.S. Geological Survey (USGS) approves Bass application to
       drill on Section 31.

       February 9, 1977 and December 7, 1977 - ERDA files suit condemning both oil and
       gas leases on Section 31 from surface to a depth of 6,000 feet.

       February 12, 1979 - The court condemns leases on Section 31  to 6,000 feet and
       awards damages to Conoco, Bass and others.

       1980 - DOE issues the Final Environmental Impact Statement which does not show
       existence of leases on Section 31.

       December 11, 1981 - Bass files an application to drill hole on Section 6, T23S, R31E
       deviating into Section 31.

       December 16, 1981 - The USGS district office transmits the drilling request and
       notes "drillsite not considered politically sensitive area."

       September 13, 1982 - Well deviating under Section 31 is completed and tested.

       August 4, 1987  DOE signs a second modification to the Consultation and
       Cooperation Agreement with State of New Mexico committing to a prohibition of
       "slant drilling from under the  site from within the site or from outside the site," even
       though DOE did not have the  right to make such a commitment.

       May 1990 - DOE reaffirms commitment to prohibit slant drilling under the WIPP in
       Final Safety Analysis Report.

       October 26,  1990 - DOE signs Memorandum of Understanding with Bureau of Land
       Management (BLM) under which "BLM will  prohibit directional drilling underneath
       the WIPP site boundary, except as may be required for the development of two leases
       located under Section  31; drilling may be allowed below 6,000 feet of the surface."


As matters currently stand, nothing precludes the lease holders from drilling additional holes
under Section 31  within the WIPP site as long as the holes penetrate the site at more than
6,000 feet below the surface.


Some observations which may be distilled  from the above chronology include the following:
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       •   In spite of the fact that detailed records as to the existence of the oil and gas
           leases within the WIPP site existed, DOE did not acknowledge such existence
           over a. ten-year period.

       •   Divided, poorly defined,  and/or conflicting responsibilities among various
           governmental agencies and various levels of organization within the agencies
           contributed to selective loss of institutional knowledge.

It can be concluded that the existence of records, per se,  does not guarantee that institutional
knowledge will be retained at the locations and be available to those who "need to know."
The significant events surrounding this oil and gas lease chronology cover a period of less
than 20 years.  If this example is typical, it strains credibility to assume that records alone
can deter adverse actions over a period of 100 years of active controls, to  say nothing of a
period of 9,900 years of passive controls.

The example suggests that considerable attention must be directed to the issue of how  records
are to be retained. The mere existence of records is not adequate.

It could be asserted that the example described  here is a record keeping anomaly. Thus, it is
not relevant criticism of systematized long term record keeping whose goal is to insure that
basic knowledge of the WIPP repository is retained somewhere, somehow. The argument of
"If a good record keeping system was in place, this would not happen," has some merit.  It
is certainly necessary to establish a system  which defines the kinds of records that should be
retained, the retention locations, the  materials used for record keeping, and their potential
availability to those who need them on a timely basis.  There can be no divided
responsibility.

Similar concerns about record keeping were echoed by one of the Futures Panels assembled
by SNL.  The Washington A Team enumerated the following potential problems with  records
(SAND 91a, pp E-7 to E-10):

       •  Records are inadequate

       •  Records exist but are not accessible to intruders

       •  Records are accessible but not understood

       •  Records are accessible and understood but ignored

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       •   Records are accessible and understood but information is lacking regarding effects
           of nearby activities such as large scale mining or water withdrawal

In a total record keeping system, steps can be taken to deal with all of these issues, except
the case where records are accessible and understood, but ignored.  The burden of that type
of conscious action lies on future society, not current society.  Nevertheless, the duration of
the effectiveness of the best record keeping system is highly subjective.

6.3.4.2    Lost AEC Records

Another recent example of the failure of records to maintain knowledge of waste burial
operations pertains to low level nuclear waste buried on U.S. Air Force controlled land
under the authority and purview of the Atomic Energy Commission.

This example in no way establishes or suggests that the sites in question pose an immediate
or long term risk to human health or the environment.  Neither is there any implication of
negligence on the part of individuals or the federal government.  It is merely intended to
illustrate the institutional and social process that can contribute to the success or failure of
passive control.

The information presented here is taken from a document entitled Burial of Radioactive
Waste  in the USAF (USAF 72 and revisions).

Most of the sites in question were created in the 1950s under the auspices of the Atomic
Energy Commission in accordance with accepted  industry waste disposal standards. The
waste materials consisted of radioactive electron tubes, solid and liquid waste from weapons
maintenance, radium oxide paint, and medical research wastes.  Some burials were made in
accordance with specific AEC (now Nuclear Regulatory Commission) license.

"Guidance  on constructing and maintaining typical sites was given technical order procedures
which  included identifying site location on appropriate maps and posting and fencing to
prevent unauthorized entry.  The Air Force switched to disposal at licensed commercial sites
in the  1958-1959 time frame and the technical order  requirements for burial, and site
maintenance requirements was rescinded. Unfortunately,  no  alternate instructions were
provided on maintaining existing sites and a gradual loss  of site records ensued. In 1971, the
Air Force initiated an effort to find and consolidate existing  site records and reestablish site

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maintenance."


A review of the facts regarding these sites are as. follows:


1.     Materials were buried under authorized procedures (Air Force and ABC).

2.     The materials were buried on active duty military reservations that themselves could
       be considered to be under active control. However, the disposal sites were under
       passive control.

3.     The loss of knowledge occurred because of a lapse in institutional reporting and
       maintenance procedures.

4.     The lapse was not longer than 12 years  (1958-1971).

5.     The 12-year lapse resulted in the loss of many radioactive waste burial sites.  Many
       are still unaccounted for in 1994.


The following three scenarios could account for the reported losses:

1.     The facilities at the time of burial did not comply with  the technical directive,
       therefore no location records exist.

2.     Interviews with base personnel  resulted  in an assertion  of a burial site but there is no
       location information.  These sites are then reported as lost. The sites may or may  not
       exist.

3.     The facilities did comply, but when active maintenance was lost the site fence and
       placards were destroyed and the historical records, if any, were not sufficient to
       establish a location.


6.3.4.3    Spring Valley Munitions Dump


The Spring Valley site in Washington DC is a highly  visible example of the burial of
potentially hazardous substances (i.e.,  World War I era chemical munitions) and the
subsequent loss of knowledge of these  activities until accidental discovery during construction
related excavation many years later (Bak 94).


The site history begins in 1916-1917 when the U.S. Bureau of Mines established Camp
Leach to study chemical warfare agents. American University donated land for this effort
during the war emergency.  In 1917-1918, the U.S. Bureau of Mines activity was

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consolidated under military command with the establishment of the American University
Experimental Station, under the Chemical Warfare Service.  By 1918, there were 1800
staffers at the station.

The burial of chemical munitions at the site was not documented by the Experimental
Station.  Burial activities were considered routine and not exceptional in terms of present or
future hazards.  The standing order for burial was that the material must be buried three feet
under the surface and not in contact with groundwater.

In 1921,  the Secretary of American University, Albert Osbome wrote an article describing
the burial of chemical munitions at the site. He did not provide a  location for the burial site.
After this article, knowledge of the site and any dumping conducted there was apparently
lost. Records did exist at American University and at the National Archives in Suitland,
Maryland but there was no general awareness of the records.

In 1986,  a backhoe operator dug up a cache of chemical munitions.  He notified the
authorities and the knowledge of the site was reestablished in the subsequent investigation.
The investigation revealed the prior discovery of a "bomb" in the 1950's on the site of the
Experimental Station.

Personal  memories of the site also existed, but were not part of the institutional memory.
One citizen, Eric Olsen,  was in possession of and had knowledge of photographs  showing
burial activities at the Station, taken by his grandfather.  (BAK 94)

The following key points can be derived from the Spring Valley incident:

       •   There was no real effort or intent of the authorities at the time of burial to retain
           some sort of institutional memory of the activities.

       •   One case of early warning of the activities made by A. Osbome, was apparently
           dismissed as a matter of little interest.

       •   While records of the activities existed in  certain archives, there was no person or
           institution who retained a knowledge of them.

       •   The activities were institutionally rediscovered through  excavation activities.

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       •  It is not known if other chemical munitions were discovered at the site during the
          years of residential development, but not reported.

6.3.5  Format for Records

In order to insure that messages on site markers are understood, it has been suggested that
the message  be recorded in several languages.  For example, the WIPP Markers Panel
recommended that the marker message be recorded in the six official languages of the United
Nations (English, Chinese, Arabic, French, Spanish, and Russian) as well as Navaho and/or
Apache (Kap 86, Givens 82, Adams 86, SAND 93).  For perspective, it is helpful to
recognize that  Chinese is the most widely used language spoken on Earth today (Durant).
Numbers of  people speaking various languages are as follows (Travel 94):

       •  Chinese (Mandarin)    - 907 million
       •  English               - 456 million
       •  Hindi                - 383 million
       •  Spanish               - 362 million
       •  French                - 123 million

While comments on the use of multiple languages have primarily involved markers, the same
logic can be applied to records.  Records should be written in multiple languages as well.
As previously  suggested in this chapter,  consideration of recording information in the major
languages used by religious scholars (i.e., Hebrew, Latin  and Arabic) also warrants
consideration.  The ONWI Human Interference Task Force envisioned that detailed
information  (e.g., 500 to 1,500 pages) in English and a more condensed version (e.g.,  200
pages)  in multiple languages would be archived (ONWI 84).  There may be a question of
institutional  will about the extent to which detailed records will be translated into various
languages for archival purposes.

Again, drawing a parallel with marker considerations, records must be stored on durable
materials.  The ONWI Task Force reported that some types of  acid-free paper may survive a
millennium under reasonable conditions  (ONWI 84).  Paper made from cotton or linen fibers
has lasted for 1,000 years. Papyrus had survived for considerably longer in Egypt.  The
Task Force recommended that conventional paper would be a suitable storage medium for
records which  are periodically updated or maintained, but it proposed that more permanent
records be prepared using special papers and stored in a protected environment. The
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importance of incorporating disposal site information on large numbers of maps widely
distributed in the United States and throughout the world was  stressed.

The NEA Working Group noted that the principal media currently used for conserving
information include paper, microfilm, and magnetic and optical disks (NEA 93).  They
quoted a lifetime of 1,000 years for paper, 200-400 years for microfilm (with one
regeneration cycle), and less than  10 years for magnetic and optical media. On this basis,
NEA felt that paper and microfilm were the preferred media for long term storage. The
same position was  adopted by the  Nordic Committee for Nuclear Safety Research - NKS
(NKS 93).

6.4    Government Ownership and Regulations

6.4.1  General Comments

While government ownership and  regulations regarding land and resource use are embraced
in the definition of passive institutional  controls, substantive questions have been raised as to
the persistence of such governmental controls  over the millennia.  Historical continuity of
governments has ranged from days to centuries. The United States, as an undivided union,
has existed for only about 130 years.

In studying inadvertent human-initiated  processes and events, Sandia National Laboratories
(SNL) convened four expert panels to estimate modes and likelihoods of future intrusion
(SAND 9la).  The teams felt that  the likelihood of continued U.S. political control over the
WIPP was small or non-existent.  Changes in  government control can lead to loss of
information about a repository.  Although physical destruction of information can be
predicted for some scenarios (eg. war, insurrection, and changes in record keeping
practices), the more likely result of change in  governmental control may result in a change in
policies regarding importance of protecting the WIPP site and its records.  There is no
guarantee that continuity of government can be equated to continuity of government policies
or continuity of government control over the WIPP site.  Governmental policies vary
significantly from one administration to the next. A future government might decide it was
no longer necessary to  maintain ownership of  the site or update records for changes in
language or technology. However, if some future government makes a conscious decision to
knowingly take action detrimental  to the repository, it is appropriate that the burden of that
decision  lie with that future society.
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History provides numerous examples of instances where government has changed
dramatically over the centuries, but institutional knowledge has not been lost.  This is
particularly true where symbolic or written language is associated with an artifact.  The
Egyptian pyramids are a classic example.  Built nearly 5,000 years ago by a society not
identifiable today, located in an area subjugated by many conquerors since, documented in a
symbolic language vastly different than today's languages, and desecrated  by thousands of
years of vandalism, the funerary monuments still convey a message understood by modern
society about their design, construction, and function.  The NEA Working Group cited
French experience with institutional controls.  Louis XVI created the Office of Quarries in
Paris to prevent disturbances to buildings constructed over quarry sites (NEA 93).  The
Office is still in existence and maintains control over portions  of the Paris infrastructure, in
spite of historical trauma including passing from an absolute monarchy to a series of
republican governments with interspersed revolution, civil war, invasion, and riot.
Institutions frequently outlive the governments which inaugurate them.

6.4.2  WIPP Land Withdrawal Act

Under Sec. 3(a) of the LWA, a sixteen square mile area was "withdrawn from all forms of
entry, appropriation and disposal under the public land laws, including without limitation the
mineral leasing laws, the geothermal leasing laws, the material sales laws (except as provided
in section 4(b)(4) of this Act47), and the mining laws." Jurisdiction over the withdrawn
lands is assigned to the  Secretary of Energy.  The LWA does  not give  to the U.S.
Government a right to any water which it did not already possess at the time the LWA was
passed.  If the U.S. Government wishes to obtain water rights for purposes associated with
the LWA, it must do so in accordance with the laws of the State of New Mexico.

Sec. 4(b)(5) of the LWA prohibits, in perpetuity, surface and subsurface mining or oil and
gas production, including slant drilling from outside the withdrawal area on the withdrawn
lands.  There is one exception to the drilling prohibition. Rights under two existing oil and
gas leases are not affected, although, if dictated  by regulatory  requirements, the Secretary of
Energy can acquire these leases. As discussed in Section 3.4.1, slant drilling from outside
the withdrawal  area into these two leases, which lie in the southwest corner of the WIPP site,
is currently permitted at depths  below 6,000 feet (EEG 92).
   c Section 4(b)(4) pennies the disposal of salt tailings which were produced during mining of the repository but
are not needed for backfill.

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Sec. 13(b) of the LWA requires that DOE prepare, within five years of the date of enactment
(i.e. October 1997), a plan for the management and use of the withdrawn area after
decommissioning.. This has yet to be done.  However, DOE has prepared a plan for the
management and use of the withdrawn area prior to decommissioning as required by Sec.
4(b)(l) of the LWA (DOE 93a).

It is instructive to examine actions planned by DOE in the current Land Management Plan as
possible precursors to future  actions associated with the post decommissioning plan.  DOE
has specified that drilling and mining activity within one mile of the WIPP land withdrawal
boundary be monitored by DOE in coordination and cooperation with the BLM and/or the
State of New Mexico. These agencies have agreed to forward to DOE for review and
comment all Applications for Permit to Drill in this boundary zone, together with mining and
reclamation plans.  According to the Land Management Plan, "this  review will afford DOE
the opportunity to verify that the proposed oil and gas or mining activities surrounding the
withdrawal area will not encroach  upon the withdrawn lands."  Presumably,  if DOE judges
that a hole is to be drilled close to the WIPP site boundary, they will request that the permit
granted to the operator include a condition that DOE be provided with downhole vertical
deviation surveys contemporaneous with the drilling activity.  If the surveys detect subsurface
deviation which could encroach upon  the WIPP site, the driller would be required to take
corrective measures or cease  drilling.  Enforcement of such a provision  will probably require
continuous monitoring of the drill bit  location and round-the-clock' presence by DOE
inspectors at the drill site.

DOE has yet to negotiate a Land Management Plan Memorandum of Understanding (MOU)
with the Department of Interior (BLM), as required by Sec. 4(d) of the  LWA, to create a
mechanism for establishing specific responsibilities of the various parties and a formal
framework for insuring that the boundary area is protected from mineral-related activities.
EPA may wish to review the MOU between DOE and BLM (and between DOE and the State
of New Mexico) to insure that the concepts outlined in the Land Management Plan will be
implemented and enforced.
6.5    Other Methods of Preserving Disposal System Knowledge

6.5.1  Subsurface Markers

To provide redundancy in the event that surface markers are destroyed by vandalism,

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erosion, other aging processes, or natural disaster, it has been suggested that subsurface
maricers be employed to augment surface markers (Adams 86, LANL 91). If the surface
markers are destroyed or removed, buried markers may still provide a deterrent to intrusion.

6.5.1.1    Passive Markers

Fired clay subsurface markers were proposed specifically for shallow burial grounds at
Hanford based on archeological evidence of longevity for such materials (Adams 86). In the
Hanford study, it was recommended that three layers of subsurface markers be emplaced at
depths of 2, 4 and 16 feet to deter activities such as farming or building construction on the
site.  While such subsurface markers might deter surface excavation, they would provide no
deterrent to exploratory drilling into an underlying geologic repository. It is highly unlikely
that a drilling crew would detect the presence of the markers.  The buried markers would
create no impediment to the drilling process and would probably be destroyed when
contacted by the drill bit.  Emplacement of such markers would involve extensive surface
excavation.

Team B of the WIPP Markers Panel suggested that earthworks at the WIPP site could be
spiked with relatively inexpensive, high dielectric constant materials such as metal sulfides or
magnetite which provide a strong radar signal to anyone exploring the  site by remote sensing
(SAND 93).  The ONWI Task Force felt that the site markers themselves would be readily
visible to remote sensors carried by satellite (ONWI 84).

6.5.1.2    Buried Sensors

Another approach to subsurface markers is to employ buried sensors of various types
(LANL 91).  These could include buried objects or materials which would create an acoustic,
magnetic, or radioactive anomaly.  To create an acoustic anomaly, large granite shapes
whose acoustic signal would define the center of the repository could be buried. Magnetic
markers might include buried iron ore or special high field permanent magnets.  Radioactive
markers could be located outside the boundaries to signal the presence  of the repository to
intruders entering from various directions.  All  of these are simply  concepts proposed by
Southwest Team of the Futures Panel. No work was done to demonstrate feasibility.

6.5.2  Protective Barriers

It has been suggested  in a report by Tolan that the final defensive measure in a defense-in-

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depth strategy for deterring human-initiated processes and events could be a protective
barrier  system (SAND 91b).  In theory, the protective barrier would deter drilling in the
event that markers'and records were lost.  The Tolan study uncovered no published research
on concepts or actual designs of a protective barrier system. Tolan outlined the key features
which a protective barrier system would need to provide.  They are as follows:

        •   "be capable of disabling a drill bit, be impervious to a drill bit or,  at a minimum,
           be capable of deflecting the drill bit safely away from the disposal  system;

        •   be potentially capable of withstanding multiple encounters with a drill bit without
           the loss of function;

        •   be composed on materials  of Little economic value and will not degrade over the
           10,000 year, post closure period; and

        •   not attract unwanted attention to the site or encourage exploration activities."

Possible locations for the conceptual protective barriers included at the surface of the
repository site, just beneath the surface, just above the emplaced waste, and within the waste
panels.  Combinations of these options are also possible. Location of barriers at or just below
the surface would require significant amounts of materials to cover the 0.5 square kilometer
footprint of the repository.  Tolan noted that operators have encountered problems in drilling
into old landfills containing layers of rubber tires (at least 10 meters thick), layers of steel
fencing, and baling wire.  Encounters with these materials resulted in loss of circulation of
the drilling mud, inability to cut through the materials, and difficulty in removing the drill
string from the borehole.  These problems occurred when using small truck-mounted rigs.
There is no information to suggest  that similar problems would be encountered when using a
large stationary rig capable of drilling to depths of 3,000 to 5,000 meters.  The long term
stability of such artificial layers is also open to question.

No suitable materials for protective barriers located just above the wastes have been
identified.  To be an effective deterrent to drilling intrusion, the material would need to be
resistant to attack by the drill bit, have corrosion resistance in the repository environment,
and be emplaced with a sufficient areal density in the case that the probability of contact with
a drill bit is high. Advanced materials such as tungsten carbide composites might meet these
specifications.  However, such an approach would be extremely costly. The buried material
could be of sufficient economic value to represent a recoverable resource to some future
generation.  The impact of further disruption of the natural geologic barriers to accommodate
emplacement of a protective barrier would need to be addressed.

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The same conceptual material problems exist in considering encasing the waste drums with
some sort of armor.  While there are materials which might deter or hinder the encroachment
of a drill bit, such materials are costly and they may be an attractive resource to future
generations. Also, their longevity in the repository environment has not been demonstrated.
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                                        6.6  References


Adams 86    "Marker Development for Hanford Waste Site Disposal," M.R. Adams and
             M.F Kaplan, Paper presented at Waste Management 86, Volume 1, pp. 425-
             431, March 2-6, 1986.

Atk 66       "Decoder Misled," R.J.E. Atkinson, Nature 200:306-08, London, 1963.

Bak 94       "Private Communication from  Mark Baker," U.S. Army Corps of Engineers,
             Baltimore Division, April 5, 1994.

Bon 90       "Monuments in an Island Society: the Maltese Context," Bonanno, A.,
             T. Gouder, C. Malone and S.  Stoddard, in "Monuments and the
             Monumental," World Archaeology 22:2, Routledge 1990.

Bur 76       "The Stone Circles of the British Isles," A. Burl New Haven, 1976.

Chal 84      "From Palaeoart to Casual Paintings: The Chronological Sequence of Amhem
             Land Plateau Rock Art," George Chalapka, Monograph Series 1, Northern
             Territory Museum of Art and Sciences, Darwin 1984.

Dam 77      "The Avebury Cycle," Michael Dames, Thames and Hudson, Ltd., 1977.

Dav 80       "Evaluation of Early Human Activities and Remains in the California Desert,"
             Emma Lou Davis, Kathryn H.  Brown, and Jacqueline Nichols, U.S.
             Department of the Interior, Bureau  of Land Management, California Desert
             District: Cultural Resources Publication, Anthropology-History, 1980.

DOE 81      "Gnome Site Decontamination  and Decommissioning Project:  Radiation
             Contamination Clearance Report March 28, 1979  September 23,  1979,"
             DOE/NV/00410-59, Reynolds  Electrical & Engineering Co., Inc., August
             1981.

DOE 93a     "Waste Isolation Pilot Plant Land Management Plan," DOE/WIPP 93-004,
             U.S. Department of Energy, 1993.

DOE 93b     "Remedial Investigation and Feasibility Study  of the Tatum Dome Test Site,
             Lamar City, Mississippi", vol.1, U.S. Department of Energy-Nevada
             Operations Office, Submitted to Mississippi Office of Pollution Control,
             Hazardous Waste Division, September 1993.

DOE 94a     Communication with Doug Duncan, O/AMEM, DOE/NV, Las Vegas, NV,
             January 14,  1994.
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DOE 94b    Communication with R. Navarro, Nevada Operations Office, Las Vegas, NV,
             January 14, 1994.

Dur 54      "Our Oriental Heritage," Will Durant, Simon and Schuster, 1954.

EEG 92      "Implications of .Oil and Gas Leases at the WEPP Site on Compliance with
             EPA TRU Waste Disposal Standards," EEG-50, M.K. Silva and J.K.
             Channell, Environmental Evaluation Group, June 1992.

Eog 86      "Knowth and the Passage-Tombs of Ireland," George Eogan, Thames and
             Hudson, London 1986.

Fow 78      "Cahokia and the American Bottom:  Settlement Patterns, Melvin Fowler, In
             Mississippian Settlement Patterns, B. Smith,  Editor, Academic Press, New
             York, 1978.

Gillis 85      "Preventing Human Intrusion into High-Level Nuclear Waste Repositories,"
             D. Gillis in Underground Space, Vol. 9, pp. 51-59, 1985.

Givens 82    "From Here to Eternity: Communicating with the Distant Future," David B.
             Givens, Et Cetera, pp.  159-179, Summer 1982.

Gor 84       "Ancient Rock Carvings of the Central Sierra:  The North Fork Indian
             Petroglyphs," Willis A. Gortner, Portola Press, Woodside, 1984.

Gor 91       "Rameses the Great," Rick Gore, National Geographic 179:4:2-31.

Gra 93       "Champion of Aboriginal Art," Denis D.  Gray, Archaeology 46:4:45-47,
             Archaeological Institute of America.

Haw 63      "Stonehenge Decoded," Gerald S. Hawkins, Nature 200:306-08, 1963.

Hed 83       "Rock Art  Papers Vol.  1," Ken Hedges, Editor, San Diego Museum Papers
             No. 16, San Diego Museum of Man, San Diego, 1983.

Hey 58       "Aku-Aku," Thor Heyerdahl, Rand McNally, 1958.

Hoy 66      "Stonehenge -- an Eclipse Predictor," Fred Hoyle, Nature 211:454-56, 1966.

Hud 78       "Crystals in the Sky: An Intellectual Odyssey Involving  Chumash Astronomy,
             Cosmology, and Rock Ar:,' Travis Hudson and Earnest Underhay Ballena
             Press Anthropological Papei  No. 10,  Socorro,  NM, 1978.

Hud 79       "Solstice Observers and Observatories in Native California.'1 Travis Hudson.
             Georgia Lee, and Ken Hedges, Journal of California and Great Basin
             Anthropology 1:39-63.

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Hur 75       "An Analysis of Effigy Mound Complexes in Wisconsin," William M. Hurley,
             Anthropological Papers No. 59, University of Michigan, Ann Arbor,  1975.
Ivan 75      "Monuments of Civilization Maya," Pierre Ivanoff, Cassell & Co. Ltd.,
             Lontion 1975.

Jud 50       Papers of Neil M. Judd, Box 3: Manuscripts of Writings:  "American
             Petroglyphs," Paper No. 61, submitted 5/9/50 for a volume honoring  Dr.
             Gustat Hailstorm on his 70th anniversary.  National Anthropological Archive,
             Natural History Museum, Smithsonian Institution, Washington DC.

Kap 82       "Archeological Data as a Basis for Repository Marker Design," BMI/ONWI-
             354, M.F. Kaplan, The Analytic Sciences Corporation, October 1982.

Kap 86       "Using the Past to Protect the Future," M.F. Kaplan and M.  Adams,
             Archaeology, pp. 51-54, September-October 1986.

LANL 91    "Ten Thousand Years of Solitude?  On Inadvertent Intrusion into the Waste
             Isolation Pilot Project Repository," LA-12048-MS, G. Benford et al.,  Los
             Alamos National  Laboratory,  March 1991.

Lew 93      "Paleolithic Paint Job," Roger Lewin, Discover 14:7: 64-70, July 1993.

Lot 76       "The Jeffers Petroglyphs Site:  A Survey and Analysis of the Carvings,"
             Gordon Allan Lothson, Minnesota Historical Society, St. Paul 1976.

Mai 65       "Early Mesopotamia and Iran," M.E.L.  Mallowan, McGraw-Hill, 1965.

McC 76      "Easter Island Settlement Patterns in the Late Prehistoric and Protohistoric
             Periods," Easter Island Committee Bulletin 5, International Fund for
             Monuments, New York 1976.

Mil 73       "Urbanization at Teotihuacan, Mexico," Rend Millon, University  of Texas
             Press, Austin  1973.

Mor 88       "Prehistoric Architecture in Micronesia," William N.  Morgan, University of
             Texas Press, 1988.

Mur 87       "Rock Art at the Kanaka-Briggs Creek Locality (10 GG 307),  Gooding
             County, Idaho," Kellya Murphey, Journal of California and Great Basin
             Anthropology 9:1:74-99, 1987.

NASA 77    "Voyager Will Carry 'Earth Sounds' Record," NASA News,  Release 77-159,
             N. Panagakos, National Aeronautics and Space Administration, July 1977.
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 NEA 93     "Assessment of Future Human Actions at Radioactive Waste Disposal Sites,"
             Draft report of an NEA Working Group, 92303b-2, compiled by Daniel A.
             Galson, October 4, 1993.

 NGS 75     "Mystery Surrounds the Biggest Planet," K.F. Weaver, in National
             Geographic, Vol.  147, No. 2, Febmary 1975.

 NGS 90     "Neptune - Voyager's Last Picture Show," Rick Gore, in National
             Geographic, Vol.  178, No. 2, August 1990.

 NKS 93     "Conservation and Retrieval of Information - Elements of a Strategy to Inform
             Future Societies about Nuclear Waste Repositories," Nordiske Seminar - og
             Arbejdrapporter 1993:596, Mikael Jensen, August 1993.

 ONWI 84    "Reducing the Likelihood of Future Human Activities That Could Affect
             Geologic High Level Waste Repositories," BMI/ONWI-537, Human
             Interference Task Force, May 1984.

 Pan  93       "Indian Rock Art," S.K. Pandey, Aryan Books International, New Delhi 1993.

 Par 86       "The Origins of Maya Art - Monumental Stone Sculpture of Kaminaljuyu,
             Guatemala, and the Southern Pacific Coast," Lee Allen Parsons, Studies in
             Pre-Columbian Art and Archaeology, No. 28, Dumbarton Oaks Research
             Library and Collection, Washington DC, 1986.

 Pig 62       "The West Kennett Long Barrow Excavations, 1955-56,"  Stuart Piggot, Her
             Majesty's Stationary Office, London 1962.

 Pow 82      "The Outlier Survey: A Regional View of Settlement in the San Juan Basin,"
             Robert P. Powers, William B. Gillespie, and Stephen H. Lekson, Reports of
             the Chaco Center No. 2, Division of Cultural Research, National Park
             Service, Albuquerque 1982.

Rav  85       "A Stone Alignment in the Northern Great Basin with a (Probably)
             Coincidental Astronomical Orientation," Christopher Raven, Journal of
             California and Great Basin Anthropology 7:1:89-98, 1985.

SAND 9la   "Expert Judgement on Inadvertent Human Intrusion into the Waste Isolation
             Pilot Plant," SAND90-3063, S.C. Hora et al., Sandia National Laboratories,
             December 1991.

SAND 91b   "The Use of Protective Barriers to Deter Inadvertent Human Intrusion into  a
             Mined Geologic Facility for the Disposal of Radioactive Waste: A Review of
             Previous Investigations and Potential Concepts,"  SAND91-7097,  T.L. Tolan,
             Tolan, Beeson,  and Associates, June 1993.
                                       6-107

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Appendix 6A:      Federal Resisier Notice Identifying WIPP Land Withdrawal Area
                                      6A-1

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Federal Ragbtar /  VcL 57. No. 227 / TปeKtay. November 24. 13S2 / Notices	S5277

                               [NM-920-4210-06; NMHU 55234}

                               Lagal Description for the Waปtซ
                               Isolation Pilot Plant (WtPf)
                               Withdrawal; MM

                               AGENCY; Bureau of La ad Ma
                               (BLM). Interior.
                                  r Notice of Lefd Dwcriptioa for
                            the WIPP Withdrawal _

                            SUMMARY: On October 30, 1392. Public
                            Law (PL) 102-578. iha Waste Isolation
                            PiJoJ Plaiu Land WUhduwRj.Act wu
                                  into law. Section 3 of Public Law
                                           ihซ< wHfara 30 days
                            after thซ oU/e of t&e enซctn>ent ol the
                            Act, the Secretary of interior shaU
                            pntJigb in the Fvdetal Regis lev a aoiioc
                            contain/eg a iegaJ description of the
                            Withdrawal This ?4ปtice  ooatamc tiut
                            legal dewxip^oa.
                            FOR FUflTWCT INFOflMATTON  CONTACT
                            Clarence F.Houglaad. BLM. New
                            Mexico Stale Qlfice, 505-43&-7S93.

                            8UPPUMCMTA*Y-ซttft>4MiArjOM: Pursuant
                            to Sccttoa 3 of PL 102-5 rfl the JegaJ
                            descripiion foe tfca WS>P Withdrawai is
                            as follows:

                            New Mexico Principal Meridian
                            T. 22S.il.-ME..
                              Sซฃi. 15 to .17 inclusive;
                              Sec.  18. lots 1 to 4. incluซ
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Appendix 6B:       Letter to U.S. Archivist Transmitting WIPP Land Withdrawal
                   Information
                                       6B-1

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             United States Department of the Interior

                       BUREAU OF LAND MANAGEMENT
                            NEW MEXICO STATE OFFICE
                                1474 RODEO RD.
                                P.O. BOX 27115
                         SANTA FE NEW MEXICO 87502-7115
 TAKE ,
 TODCM1
 AMBOCA
   IN REPLY REFER TO:


NMNM 55234
2310 (923)
                                      NOV  I 6  1992
Dr. Don Wilson
Ar-hivist of the United States
National Archives
Rm. Ill
Washington, D.C.  20408

Dear Dr. Wilson:

In accordance with Section 3 of Public Law  102-579,  the Waste Isolation Pilot
Plant Withdrawal Act, enclcsed are the map  and the legal description for the
Waste Isolation Pilot Plan:: Withdrawal.

Section 3 requires that ccpies of the map and  the legal description for the
Withdrawal be filed with the Congress, the  Secretary of Energy,  the Governor
of the State, and the Arcnivist of the United  States.

Please contact Clarence Hougland at  (505) 438-7593,  if you have  questions or
need further assistance.
                                           Larry L.  Woodard
                                           State Director
2 Enclosures:
    1 - Withdrawal Map
    2 - Legal Description  (1 p)
     ftU.S. GOVERNMENT PRINTING OFFICE: 1995-615-003-01091

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