SAFEGUARD RADIOASSAY MEASUREMENTS – DOES THE ASSOCIATED DATA SATISFY THE QUALITY ASSURANCE REQUIREMENTS OF WASTE MANAGEMENT?

The criteria for the certification and re-certification of the Waste Isolation Pilot Plant’s (WIPP’s) compliance with Title 40 Code of Federal Regulations (CFR), Part 191, Disposal Regulations, is promulgated in 40 CFR Part 194. Per Subpart 194.22, Quality Assurance, “As soon as practicable after April 9, 1996, the U.S. Department of Energy (DOE) shall adhere to a quality assurance program that implements the requirements of ASME NQA-1-1989 edition, ASME NQA-21-1990 addenda, part 2.7, to ASME NQA-2-1989 edition, and ASME NQA-3-1989 edition (excluding Section 2.1 (b) and (c), and Section 17.1).” For any information collected by Safeguards prior to the implementation of such a quality assurance program, the data must be qualified in accordance with an alternate methodology that employs one or more of the following methods: peer review, corroborating data, confirmatory testing, or an equivalent quality assurance program. Application of these alternative methodologies to Safeguards radioassay data taken on radioassay instruments not qualified in accordance with Subpart 194.22 is discussed. Reassessment processes and procedures necessary to qualify the pre-existing Safeguards data are identified. Significant benefits derived from the implementation of one or more of these methodologies to pre-existing Safeguards radioassay data include reduced exposure to workers, increased throughput, and reduced characterization costs. Limited application of 40 CFR 194.22 to Safeguards data at Rocky Flats Environmental Technology Site (RFETS) and Los Alamos National Laboratory (LANL) are discussed.