### DOCKET NO: A-98-49

Item: II-B3-97



## Emplacement Inspection Report

EPA INSPECTION No. EPA-WIPP-6.06-20c

OF THE

WASTE ISOLATION PILOT PLANT

June 20-22, 2006

U. S. ENVIRONMENTAL PROTECTION AGENCY

Office of Radiation and Indoor Air

Center for the Waste Isolation Pilot Plant

401 M. Street, S. W. Washington, DC 20460

September 20062 Table of Contents

1.0 EXECUTIVE SUMMARY

................................................... ........................................... 3

2.0 INSPECTION PURPOSE AND SCOPE

................................................... ..................... 4

3.0 PERFORMANCE OF THE INSPECTION

................................................... ................ 5

3.1 WASTE EMPLACEMENT/WWIS

................................................... ......................... 6

3.2 MAGNESIUM OXIDE BACKFILL

................................................... ........................ 8

3.3 COMPARISON WITH INVENTORY LIMITS

................................................... ..... 9

4.0 UNCERTAINTIES

................................................... ................................................... ... 10

5.0 SUMMARY OF RESULTS

................................................... ........................................ 10 2006 EPA Emplacement Inspection Checklist

................................................... ...................... 11

Attachment A

................................................... ................................................... ........................ 17

Attachment B

................................................... ................................................... ......................... 18 Inspection Checklist Appendix

................................................... ............................................... 19

Attachment C

................................................... ................................................... ........................ 20

Attachment D

................................................... ................................................... ........................ 21 Figures Illustrating the MgO Safety Factor Evolutio n for Room 3, Panel 3 ......................... 223 

## 2006 Emplacement Inspection Report

1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.21, the U.S. Environ mental Protection Agency (EPA or the Agency) conducted an inspection of the U.S. Dep artment of Energy = s (DOE) Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico, from June 20 to June 22, 2006. The WIPP is a disposal system for defense-related transuranic (TR U) waste as defined by the WIPP Land

Withdrawal Act. 1 EPA certified that the WIPP complies with the Age ncy = s radioactive waste disposal regulations (Subparts B and C of 40 CFR Pa rt 191) on May 18, 1998.

The purpose of this annual inspection was to determ ine if waste sent to WIPP during the past year has been emplaced in the underground faci lity in the manner specified in DOE = s Compliance Certification and Recertification Applic ations and other approvals. A specific focus of this inspection was to determine if Magnesium Ox ide (MgO) continues to be emplaced in the underground and appropriately tracked in the WIPP W aste Information System as required by

EPA = s letters (Docket A-98-49, Item II-B3-68, March 26, 2004 and Docket A-98-49, Item II-B3- 72, May 20, 2004).

EPA examined objective evidence that additional MgO sacks used to control the impact of high CPR (cellulosic, plastic and rubber material) waste in the underground will perform as

intended. A Objective evidence @ is the documentation and observations that EPA can use to verify that DOE is conducting its operation appropriately.

EPA concluded that DOE = s emplacement activities are adequate, that CPR is appropriately tracked and accounted, that additional MgO when nee ded is calculated properly (beginning with Panel 2, Room 1), and that all MgO is emplaced prop erly. While DOE does not necessarily maintain an MgO safety factor above 1.67 for operat ional efficiency while loading waste in a room, DOE does place enough MgO before the closure of a room as is required.

EPA did not identify any findings from this inspect ion. DOE did act on EPA’s recommendation from the 2005 inspection that the Mg O emplacement training manual be made a standard operating procedure

. In November 2005, DOE A back-populated @ the WIPP Waste Information System with the amount of MgO in the re pository, by room, to facilitate future estimates of the total MgO emplaced.

1 WIPP Land Withdrawal Act, Public Law 102-579, Secti on 2(18), as amended by the 1996 WIPP LWA
Amendments, Public Law 104-201.4

2.0 INSPECTION PURPOSE AND SCOPE

The purpose of this inspection was to determine whe ther wastes sent to the WIPP have been emplaced in the underground facility in the manner specified in DOE = s Compliance Certification and Recertification Applications and other approval s for the WIPP. EPA performed the inspection under authority of 40 CFR 194.21, which authorizes the Agency to inspect the WIPP during its operational period to verify continued c ompliance with EPA = s WIPP Compliance Criteria and the certification decision of May 18, 1998 and recertification decision of March 29, 2006. Emplacement of waste, and backfill in partic ular, is relevant to compliance because the emplacement method supports models that DOE used in the WIPP performance assessment to understand the potential for transport of radionucl ides out of the mined rooms.

The WIPP site is operated by Washington TRU-Solutio ns (WTS) under contract to DOE. The majority of waste related activities onsite are described by or controlled through WTS procedures. A list of primary WTS procedures exami ned for this inspection is provided in Table A. Additional materials were collected during and after the inspection.

Table A Listing of WTS Procedures Examined During Inspectio n

$ Specification for Repackaged MgO Backfill , Waste Isolation Pilot Plant Procedure D-0101, Revision 7, ECO Number 11280; Effective Date May 12 , 2005

$ CH Waste Processing , Technical Procedure WP 05-WH1011, Revision 23; Ef fective Date January 3, 2006

• Waste Stream Profile Form Review and Approval Progr am , WP 08-NT.03, Revision 7, June 15, 2005

• WIPP Waste Handling Operations WWIS User’s Manual, WP 05-WH.01 Revision 0; Effective Date September 16, 2005. Drafts of Revis ions 1 and 2, with no effective date

were also examined.

$ WIPP Waste Information System User's Manual WWIS Ve rsion 5.0 , DOE/CBFO 97-2273, Rev. 9, December 12, 2005

Activities within the scope of this inspection incl uded:

$ demonstration of the site = s ability to receive, process, and emplace TRU wast es within the repository,

$ the use of magnesium oxide (MgO) backfill in appro priate amounts to fulfill CCA commitments,

$ tracking of CPR and MgO, and calculation of the MgO safety factor,

$ verifying that waste handling staff are trained and qualified to perform waste emplacement,5

$ maintenance of relevant waste packaging records, i ncluding the electronic WIPP Waste Information System (WWIS).

The inspectors observed waste being emplaced in th e underground and waste that had been recently placed in the repository. The inspec tors also reviewed records documenting that waste emplacement and MgO tracking were conducted i n accordance with procedures. To date, the waste received at the repository is contact-han dled (CH) transuranic wastes from Argonne National Laboratory- East (ANL-E) in Illinois, Los Alamos National Laboratory (LANL) in New Mexico, Idaho National Laboratory (INL), Hanfor d Site in Washington, Rocky Flats Environmental Technology Site (RFETS) in Colorado, Savannah River Site (SRS) in South Carolina, and the Nevada Test Site (NTS) in Nevada. These wastes are in one of several configurations: Standard Waste Boxes (SWBs), 55-ga llon (208 liter) drums assembled in groups of seven called a Seven Pack, and Ten Drum Overpack s (TDOP). In 2005 WIPP began receiving supercompacted waste in 100-gallon (416 l iter) drums from INL. The SWB and Seven Pack have the same “footprint” — that is, they occu py equivalent floor space — and can be

stacked in vertical columns as described in this re port. The TDOPs have a different footprint and must be placed at the bottom of a column. A list o f waste containers emplaced in the repository as of the date of this inspection is provided in At tachment A.

3.0 PERFORMANCE OF THE INSPECTION

The EPA inspectors were Chuck Byrum and Tom Peake from the Office of Radiation and

Indoor Air. Nick Stone and Barnes Johnson from EPA were observers. Steve Casey, DOE/CBFO, was the chief DOE contact for the inspect ion. A list of inspection participants is provided in Table B.

The inspection took place on June 20-22, 2006, at DOE’s Carlsbad Office and at the WIPP facility, which is located approximately 26 mi les south east of Carlsbad, New Mexico. The opening meeting with CBFO and WTS personnel was held in the morning of June 20, 2006. Several DOE and WTS staff provided an overview pres entation.

The EPA inspectors accompanied CBFO and WTS person nel into the underground repository on the afternoon of June 20, 2006 in ord er to view waste packages that had been emplaced. Inspectors selected several shipments an d noted their numbers; the records for these containers were examined later in the WWIS computer database to verify correct waste information. The WTS personnel explained how waste packages are handled and emplaced and answered questions from the EPA inspectors. The in spection continued the next day at the WIPP

site with an examination of records and an intervie w with Hardy Bellows (WTS).

Lastly, EPA inspectors reviewed the WWIS with Stev e Offner, a Data Adminstrator with

WTS and Mike Strum also a WWIS Data Adminstrator. These discussions took place at the Carlsbad Field Office. A closeout meeting was held on June 22, with no findings identified at

that time.6 Table B Inspection Participants

INSPECTION TEAM

MEMBER POSITION AFFILIATION

Chuck Byrum Inspector EPA ORIA

Tom Peake Inspector EPA ORIA

Nick Stone Observer EPA Region 6

Barnes Johnson Observer EPA ORIA

CBFO / WTS PERSONNEL POSITION AFFILIATION

Steve Casey General Engineer DOE/CBFO

Daryl Mercer Physical Scientist DOE/CBFO

Dave Kump WTS WWIS Manager WTS

Hardy Bellows Waste Operations Program Manager WTS

Steve Offner WWIS Data Adminstrator WTS

3.1 WASTE EMPLACEMENT/WWIS

The repository is subdivided into panels, each pan el consisting of seven (7) rooms. At the time of the inspection , waste was being emplac ed in Room 3 of Panel 3.

Waste containers are stacked in columns (waste sta cks) combining SWBs, drum packs, and TDOPs. TDOPs are always placed on the floor of the room, using the bottom and middle position of a waste column. When only TDOPS are be ing emplaced because of the lack of waste in other waste containers, empty dunnage drums are placed on top of TDOPs and the MgO sacks are then placed on the dunnage drums. SWBs and Se ven Packs are emplaced in no particular order with most wastes emplaced as received. The w aste columns are in a series of staggered rows, with a row consisting of three columns that s pan the distance of a disposal room from left to right [Figure 1].7

Figure 1 . Example of Rows of Waste. Source: Attachment 2, Payload Assembly Positioning, CH Waste Processing , Technical Procedure WP 05-WH1011, Revision 23, Attachment 2; Effective Date January 3, 2006. A st ack of MgO takes up one payload location.

Some (1-2 feet) space between the repository wall a nd the waste column may be left open, however, waste packages may be placed touching or n early touching the repository wall. A second row of three columns is emplaced parallel to the first, with each column placed between two columns from the previous row to minimize unusa ble space. MgO is placed on top of each column in 4,200 pound super sacks. When additional MgO is needed before room closure, DOE will place stacks of five MgO supersacks in a colum n on BRTs (big red things). See Figure 2.

Figure 2 . Additional MgO is placed in stacks five supersac ks high in BRTs in order to assure an MgO safety factor abo ve 1.67 before room closure. (Figure is from the 2005 inspection).

While underground in Room 3, Panel 3, the EPA insp ectors selected recently emplaced waste packages for later review. These shipments i ncluded one type of each waste package. The inspectors read the shipment identification numbers directly off the emplaced containers. The

containers selected are identified in Table C below

.8 Table C Waste Containers Reviewed During Inspection

Site of Waste Container Origin Identifier Container Type

INL BN10103189 Standard Waste Box INL BN10103086 100-gallon drum SRS SRTP01508 Ten Drum Overpack LANL LAS851751 55-gallon drum

The EPA inspectors examined the following modules:

• Characterization Module, linked to the Waste Cont ainer Data Report • Certification Module, linked to the Acceptance/Re jection Report • Shipping Module, linked to the Shipment Summary R eport • Inventory Module, linked to the Nuclide Report, W aste Emplacement Report and the MgO safety factor calculation on the Emplaced Container s Underground Form 0420.

All records were found to contain the required inf ormation.

3.2 MAGNESIUM OXIDE BACKFILL

Magnesium oxide (MgO) is used in the repository as backfill, as specified in DOE’s Compliance Application (CCA) and most recent applic ation. EPA requires DOE to maintain an MgO safety factor of 1.67 or greater, which means t hat at least 1.67 times the needed MgO will always be in the repository to control chemical con ditions and remove carbon dioxide gas. Only since 2005 has DOE had the capability to track the MgO and determine the safety factor on a room basis. Since EPA required DOE to track MgO in the WWIS, DOE has found out that many of disposal rooms have MgO safety factors greater t han three, although some rooms with INL supercompacted waste have had to have significant a mounts of MgO added to maintain the required safety factor. When average CPR amounts a re included in the waste, the safety factor is well above the minimum. In the opening presentatio ns, Hardy Bellows (WTS) identified that Room 1, Panel 2 required 30 MgO columns to achieve an MgO safety factor of 1.72 while Room 7, Panel 3 had an MgO safety factor of 4.03. DOE s tarted specific tracking of MgO emplaced in Room 1, Panel 2 and Room 7, Panel 3.

WTS Technical Procedure WP 05-WH1011, CH Waste Processing , Section 5 requires MgO placement on top of the waste. Section 6.2 of the CH Waste Processing (WP 05- WH1011 ) document states the Waste Handling Enginee r is to verify that the safety factor is greater than or equal to 1.67. Attachments to WP 0 5-WH1011 have been developed for recording the emplaced MgO underground or later ent ry into the WWIS. At the end of each shift the Waste Handling Engineer (WHE) inputs the emplac ed waste and MgO information into the WWIS according to the WIPP Waste Handling Operation s WWIS User’s Manual (WP 05-9

WH.01 Revision 0). The EPA inspectors observed that MgO had been placed properly in each row that was visible. The MgO is placed on top of each waste column in supersacks [Figure 3] or on the BRTs [Figure 2] when additional MgO is ne eded.

Checklist items 8-10 deal specifically with the is sue of MgO management and the objective evidence that demonstrates DOE has the ap propriate process for ensuring that the MgO is properly emplaced. In addition to the requireme nt in WTS Technical Procedure WP 05- WH1011, CH Waste Processing, DOE uses training notes that describe the decision process on how, when and where additional MgO is placed. DOE plans to put this training information in a revised WIPP Waste Handling Operations WWIS User’s Manual (WP05-WH.01, Revision 2). The training notes are provided as Attachment C and the draft decision tree/flowchart is provided as Attachment D. In addition, and example of the M gO safety factor evolution is provided for Room 3, Panel 3 in emails from DOE staff to EPA sta ff and in Figures 4-7.

Figure 3 . DOE is emplacing waste stacked 2-3 containers hi gh topped with MgO Supersacks. This picture shows all container types being shippe d to date. Large drums are Ten Drum Overpacks (TDOPs), black barrels are 100-gallon dru ms with supercompacted waste, standard waste boxes, and standard 55-gallon drum 7-packs.

3.3 COMPARISON WITH INVENTORY LIMITS

EPA has established limits for certain important w aste components at WIPP by approving a performance assessment. Some limits, such as for iron and other metals, are minimum limits. The amount of iron base metal alloys is approximate ly 3.22 x 10 6 kg of the 2 x 10 7 kg needed by closure, but steel provides an additional 7.99 x 10 6 kg, so that WIPP has attained over two-thirds of the iron needed. With over 270,000 kg of alumin um and other non-ferrous metals, the WIPP has already exceeded the minimum amount for the lim it DOE identified in the CCA and CRA.10

Other waste component limits are maximum limits. Of special concern is the maximum limit on the total amount of cellulosic, plastic an d rubber materials (CPR). In the CCA, DOE

identified that the limit for CPR was 2.2 x 10 7 kg. However, during the first WIPP recertificatio n process, DOE added packaging materials to the calcu lations, so that the CPR limit for WIPP is

now 2.4 x 10 7 kg.

As of July 31, 2006 the WIPP contained 2.1 x 10 6 kg of CPR in waste and 0.8 x 10 6 kg of CPR in packaging material for a total of approxi mately 2.9 x 10 6 kg of CPR (from WWIS query in Attachment B). Most of this is split betw een the cellulosic and plastic materials; the

mass of rubber materials accounts for about 7% of t he total mass of CPR. Thus, the WIPP

contains about 13% of the CPR limit with two of the ten planned panels complete.

4.0 UNCERTAINTIES

In the March 2006 recertification decision, EPA cou ld not identify that DOE characterized the uncertainty in the CPR amounts in the inventory (CARD 194.24). EPA stated in the recertification decision that the use of poi nt estimates for waste components (i.e., CPR) was acceptable for now, and identified that DOE nee ds to better demonstrate knowledge of the measurement uncertainty for the next recertificatio n and include these uncertainties into the PA process. In the waste characterization process, ra dionuclide measurement errors are noted and included in the WWIS. CPR is an important componen t, but in this inspection, EPA confirmed that DOE does not track the uncertainty in the CPR amounts according to the requirement in 40 CFR 194.24 (c)(1). EPA does not consider this issu e to currently be a finding and is discussing the issue with DOE outside of the inspection proces s. However, EPA will be looking to DOE for an appropriate resolution of this issue.

5.0 SUMMARY OF RESULTS

The inspectors reviewed the TRU waste emplacement operation and the associated documentation for selected shipments. EPA determin es that DOE is adequately emplacing waste in the repository as specified in DOE’s procedures and EPA requirements. EPA also determines that DOE is fulfilling commitments made in the CCA and CRA related to waste and MgO emplacement. EPA concluded from this inspection th at DOE’s emplacement activities are adequate, the CPR is appropriately tracked, the saf ety factor is calculated properly along with the additional MgO needed (since DOE began to track the MgO), and that the MgO is emplaced properly. DOE calculated that the current safety f actor is above the mandated 1.67 for closed rooms since the tracking officially began with Room 1, Panel 2 and Room 7, Panel 3. EPA did not identify any findings during this inspection.11 2006 EPA Emplacement Inspection Checklist

#IIt # Question : Waste

Emplacement Comments and Objective Evidence Results

1 Is waste being emplaced in the underground facility in the manner specified in DOE’s Compliance Certification Application (CCA)? Yes. Procedure WP 05-1011, Rev. 23, CH Waste Processing , steps 4 -7, pages 21 through 26 describe the emplacement process.

Our visual observation of actual waste being put in to Panel 3, Room 3 (See Figure 3 of main report) verif y that waste is being emplaced appropriately. Satisfactory

2 Are waste containers stacked in columns appropriately given the type of container? Yes. Procedure WP 05-1011, Rev. 23, CH Waste Processing , Attachment 2, Payload Assembly Positioning.

Our visual observation of actual waste being put in to Panel 3, Room 3 (See Figure 3 of main report) verif y that waste is being emplaced appropriately. Satisfactory

3 Are records adequate? Randomly select three waste containers to verify records for waste approval, shipment, and receipt. Shipment Number

IN060376

IN060381

SR060038

LA060070 Container Number

BN10103189 (SWB)

BN10103086 (100-gal)

SRTP01508 (TDOP)

LAS851751 (55-gal) Satisfactory

4 Does the WWIS adequately document waste shipment and emplacements information for

waste containers selected item 3

above? Yes. In the Waste Emplacement Report, the WWIS adequately documents waste shipment and emplacement information. DOE produced a Waste Emplacement Report (TP_WEP_6_21_2006) indicating container number, shipment number, and emplacement information in the underground (emplacement date, site generator identification, p anel, room, row, column, and location within a column).

Also, the information used in the WWIS is from the underground emplacement data and Attachment 4 of WO 05-WH1011 which is how the emplacement staff records the location in the underground. (TP_CHWPDS_6_21_2006) Satisfactory12

# Question : Waste Emplacement Comments and Objective Evidence Results

5 Verify documentation for the

containers listed in item 4 - waste generator site transmittal of waste to WIPP, WIPP approval, shipment certification for transport to WIPP, shipment initiation documentation, shipment received at WIPP records, waste emplaced in the underground, and placement of backfill [MgO]. Procedure WP 05-1011, Rev. 23, CH Waste Processing Attachments 3, 4, 5, and 6 document how waste containers and MgO are actually emplaced underground.

Waste Stream Profile Form Review and Approval Program

Inspector examined shipment reports and container reports generated by the WWIS computer based database system. Inspector verified that the WWIS documented that the generator site transmitted wast e information to WIPP, WIPP reviewed and approved the waste for shipment, that waste was placed underground, and that MgO was properly emplaced. Satisfactory

6 Is DOE properly emplacing backfill material (magnesium oxide [MgO]) with the waste packages? Yes. Visual observation (See Figure 3 of main report).

Procedure WP 05-1011, Rev. 23, CH Waste Processing Section 5.0, page 25, requires MgO to be emplaced. Satisfactory

6a Is the acceptance of the MgO

backfill material from the supplier documented? Yes. DOE gets a bill of lading and a chemical determination of content. (TP_MGO_1) Satisfactory

7 Are Super Sacks placed on top

of waste stacks as described in Volume 1, Section 3.3.3 of the CCA; approximately 4,000 lbs,

multi-wall construction with a vapor and moisture barrier? Yes. Visual observation (See pictures below). Satisfactory

8 For the MgO needed for high CPR, are there procedures or

documentation for the WHE or WHM (or other appropriate personnel) identifying when additional MgO is needed? In the WIPP Waste Handling Operations WWIS User’s Maual, WP-WH.01, Revision 0, 9/16/05. Data is input and then the MgO factor is calculated

. Deficits (safety factor < 1.67) are highlighted in red, and surpluses are highlighted in green.

2005 Training notes address this. See Attachment C

. The training notes will be superseded by the update WIPP Waste Handling Operations WWIS User's Manual (Attachment D). Satisfactory13

# Question : Waste Emplacement Comments and Objective Evidence Results

9 Is there documentation that identifies, for the WHE or WHM (or other appropriate personnel), where the additional MgO should be placed? DOE uses Big Red Things (BRTs) to hold columns of MgO when extra is needed. BRTs are noted in the underground map as a stack of 5 MgO layers as diagrammed below.

2005 Training notes address this. See Attachment C

. The training notes will be superseded by the update WIPP Waste Handling Operations WWIS User's Manual (Attachment D). Satisfactory

10 Is there documentation that

identifies how the MgO should be placed with high CPR

waste? 2005 Training notes address this. See Attachment C

. The training notes will be superseded by the update WIPP Waste Handling Operations WWIS User's Manual (Attachment D). Satisfactory

11 Is DOE properly tracking the MgO backfill so that the MgO safety factor can be accurately

calculated? Yes. WWIS Version 5.1 Software Validation Test, Mg O Emplacement Process and Safety Factor Calculation, Revision 0, March 2, 2005 verifies that the WWIS so ftware works as expected. Satisfactory

12 Is DOE assuring that the 1.67 safety factor being maintained

on a room basis?

What methodology (equations) are being used to calculate the safety factor? Yes. Procedure WP 05-1011, Rev. 22, CH Waste Processing

Section 5.0 states the requirement that the safety

factor of 1.67 must be maintained. Inspector examined screenshots in Supplemental Instructions for MgO Emplacement in WWIS, for the completed Panel 3, Room 4 that shows room MgO safet y factor > 1.67.

Screen shots below indicate that the MgO safety fac tor fluctuates with time. At the time of inspection, P anel 3, Room 3 had an MgO safety factor 1.51. Over a perio d of several weeks, the MgO safety factor changed. As o f July 30, 2006, the safety factor had been increased to 1 .79 with an excess of 20 MgO supersacks (see emails from Ste ve Casey to Tom Peake).

DOE provided the source code for the calculation of the MgO safety in the file MgO SF Function.pdf. Satisfactory

MgO MgO MgO MgO MgO14

# Question : Waste Emplacement Comments and Objective Evidence Results

13 Is DOE maintaining records of waste shipments and emplacement properly? Yes, through the underground emplacement map and various WWIS reports. Satisfactory

14 Do the characterization module, certification module, shipping module, and inventory module adequately record the required

information? Yes. DOE staff queried the WWIS for this information and demonstrated (via waste container reports, shipment reports and container approval rejection reports) that they adequately recorded th e required information.

Example documents produced: Shipment IN060381.pdf 55G Drum HBL040182.pdf Cntr App Rej 2006-06-18.pdf Satisfactory

15 Characterization Module -

Review a WWIS Waste Container Data Report. Does this report adequately record

the Waste Stream Profile Form

information? Yes. See TDOP SRTP01508.pdf or 55G Drum HBL040182.pdf Satisfactory

16 Characterization Module -

Does the data administrator verify that DOE/CBFO has granted certification and transportation authority to the generator/shipper site prior to review of generator/shipper

characterization data? Yes. DOE provided documentation that the data administrator verifies the waste generator has appr oval to ship waste to WIPP.

The procedure, Waste Stream Profile For Review and Approval Program WP08-NT.03 Revision 7, describes what a database administrator’s duties are, and WWI S Review WSPF BN836.pdf is an example of the implementation of section 5 of that procedure generated by Mike Strum (WTS). Satisfactory

17 Certification Module - Examine an Acceptance/ Rejection Report. Does this adequately record waste

information? Yes. It identifies the container and shipment information and the person who approved the shipment. Satisfactory

18 Is the generator/shipper denied any further write access to

certification information after the data passes the limit, edit check, and a review by the

WWIS data administrator? Yes. Users have different levels of authorization and privileges. WIPP Waste Information System User’s Manual WWIS Version 5.2 identifies multiple processes and data checks. Satisfactory15

# Question : Waste Emplacement Comments and Objective Evidence Results

19 Shipping Module - Review the Shipment Summary Report. Does the report correctly record the containers shipped? Yes. Compared shipment data (from Shipment IN060381.pdf) to Waste Emplacement Report and the

information is consistent. Satisfactory

20 Inventory Module - Review the Waste Emplacement Report. Does this report adequately record the date of receipt, and disposal locations of

containers? Yes. The Waste Emplacement Report records container number, shipment number, emplacement data and underground location, and several other pieces of information. The data for containers vie wed underground appear consistent with the Waste Emplacement Report. Satisfactory

21 Does the WWIS properly track MgO emplaced quantity and

location?

Where is this described? Yes. WO 05-WH1011, CH Waste Processing , Section 5.0 states that the required information is to be

recorded in Attachment 6. Attachment 6 records the actual amount of MgO and its location in the waste room. This information is input by the waste handl ing engineer into the WWIS computer database in the Emplace Containers Underground screen. Satisfactory

22 Does the WWIS accurately calculate the 1.67 safety factor and recommend the proper amount of MgO to emplace?

Where has this been verified? Yes. WWIS Software Validation Test, MgO Emplacement Process and Safety Factor Calculation Revision 0, March 2, 2005 documents the testing of the new modules added to WWIS to track MgO and calculate the safety factor on an ongoing basis roo m by room.

At the time of the inspection (June, 2006), Panel 3

, Room 3 was partially filled. The MgO Safety Factor was 1.51. As of July 31, 2006, the MgO Safety Fact or was 1.79, according to Steve Casey (DOE). See emails and Figures 4-7below. Recently completed Panel 3, Room 4 had a 1.79 MgO Safety Factor as identified in a query performed for the inspectors. Satisfactory16

# Question : Waste Emplacement Comments and Objective Evidence Results

23 Is MgO implementation appropriately documented?

Where is it described? The WWIS MgO SF calculation procedure is in section 6.2, WP 05-WH.01 (WIPP Waste Handling Operations WWIS User's Manual) Satisfactory

24 Is there documentation that

describes how the site will use and implement the MgO

module of the WWIS? WP 05-WH.01 WIPP Waste Handling Operations

WWIS User's Manual identifies that the waste handling engineer is to input MgO data into the WWIS. This MgO safety factor calculation, performed at the end of each shift, is then used to determine whether additional MgO is necessary. (WP 05-1011, Rev. 23, CH Waste Processing ) Satisfactory

25 Does the WWIS capture measurement uncertainty for radioactivity?

How is it calculated? Yes. It is input by the sites and tracked in the WW IS. Satisfactory

26 Does the WWIS capture measurement uncertainty for cellulosic, plastic and rubber

materials? Other materials?

How is it calculated? The WWIS does not capture measurement uncertainty except for radioactivity and container mass.

This checklist item was to confirm EPA’s understanding that uncertainty was only tracked for radioactivity. This was raised in EPA’s 2006

recertification of WIPP.

EPA is separately reviewing this item and will identify, separately from this inspection, the importance of this topic. Not

satisfactory17Attachment ANumber of Contact Handled TRU Waste ContainersUnderground at WIPP As of July 31, 2006Site100-gallonDrums55-gallonDrumsPipeOverpackS100 PipeOverpackSWBTDOP85-GalOverpackDunnageDrumsDunnageSWBs2006Total2005TotalANL-E031800012040334334Hanford03772209308208078061594566INL484216044007531400052502356423564159492356447128LANL040252181116800618050401706LLNL067800200806881376NTS018050014008018271394RFETS01546021174039104052904107782154SRS0226800350155500041733757WIPP02000022989133006731Total484244372234851152053179247591385868171736NOTE: The drums listed for WIPP consist of two drums of site generated waste, two drums from RFETS that were overpacked on site, with primarily empty dunnagedrums but with some salt-filled dunnage drums.Argonne National Laboratory - East (ANL-E) Hanford Site (Hanford)Idaho National Laboratory (INL) Los Alamos National Laboratory (LANL)Lawrence Livermore National Laboratory (LLNL) Rocky Flats Environmental Technology Site (RFETS)Nevada Test Site (NTS) Savannah River Site (SRS)Waste Isolation Pilot Plant (WIPP)18Drums = 55 gallon (208 liter or 0.208 m3) steel drums Pipe Overpack = 55 gallon drum pipe overpack except for the S100SWB = Standard Waste Box TDOP = ten drum overpackDunnage = inert drums used to complete waste assemblies19Attachment BWeight (Mass) of Materials Emplaced in WIPP as of July 31, 2006*HA WASTE_MATL_PARM TYPEDESCRIPTIONMATL_WGT (kg)-- ---------------------------------------- -------------------- -------------------------------------------------- ---------16 Emplacement MAGNESIUM OXIDE15643875.118 Emplacement CELLULOSIC EMPLACEMENT MATERIAL59351.8720 Emplacement PLASTIC EMPLACEMENT MATERIAL224400.35CH 1 WasteIRON BASE METAL ALLOYS3217775.55CH 2 WasteALUMINUM BASE METAL/ALLOYS30779.09CH 3 WasteOTHER METAL/ALLOYS244174.78CH 4 WasteOTHER INORGANIC MATERIALS902337.45CH 6 WasteCELLULOSICS661553.94CH 7 WasteRUBBER141711.42CH 8 WastePLASTICS1336459.69CH 9 WasteSOLIDIFIED INORGANIC MATERIAL3973468.03CH 10 WasteSOLIDIFIED ORGANIC MATERIAL210192.67CH 12 WasteSOILS9156.86CH 13 Steel Packaging STEEL CONTAINER MATERIALS7985540.67CH 14 PlasticPackaging PLASTIC/LINERS CONTAINER MATERIALS460803.85CH 15 Cellulosic Packaging CELLULOSICS PACKAGING MATERIALS822714*From an August 14, 2006 email from Dave Speed (WTS) to Tom Peake (EPA)20 Inspection Checklist Appendix Emails Related to MgO Safety Factor History for Roo m 3, Panel 3

7/31/06 email from Steve Casey (DOE) to Tom Peake ( EPA)
Tom, The decision is still a human judgment determinatio n - the two documents WP 05-WH.01 and WH1011 are us ed as standard practices for most situations. Prior t o making the call on whether or not to add addition al MgO, it is important to know the next two weeks or more of shi pments from the various sites. As we stated previou sly, no room will be closed until the safety factor is at, or above the required amount (currently 1.67).

Steve

7/31/06 email from Steve Casey (DOE) to Tom Peake ( EPA)
Tom, As of July 30, Room 3 of Panel 3 is at Row 102, wit h a calculated MgO SF= 1.79 (20 excess sacks; no BR Ts emplaced).

Steve

7/12/06 email from Steve Casey (DOE) to Tom Peake ( EPA) Attached is a screen shot from the WWIS showing whe re we're at as of last night...

SF = 1.64

Sacks needed = 4

Room 3 is still being filled - today we're emplacin g containers at and beyond row 64. While it shows a 'deficit' of 4 sacks, we anticipate with the lower-CPR waste that is coming in the next two weeks that we will n ot need to emplace a "BRT" any time soon.

Steve21 Attachment C 2005 Training Notes For Waste Handling Engineers The purpose of this training is to provide informa tion for Waste Handling Managers, Superintendents and Engineers to effectively evalua te changes in repository room Safety Factor (S.F.), and make informed decisions related to Magnesium Ox ide (MgO) emplacement activities required for the disposal of Supercompacted Waste, including:

1) Requirements related to the EPA mandated Safety Fac tor of 1.67, waste stream Cellulosics, Plastics, and Rubber (CPR) contents, and impacts to long term repository performance.

2) Administrative steps to be performed to support max imizing the existing disposal volume in the Underground while maintaining compliance with EPAs minimum specified disposal room safety

factor of 1.67.

As stated in WP05-WH1011, section 5.0, CH Waste Pro cessing, once waste/MgO emplacement is performed, the information is uploaded to the WWIS and room safety factors are calculated. The

result of the calculation will be one of two condit ions:

 Room Safety Factor (S.F.) ≥ 1.67

1) Activities continue for emplacement of waste an d MgO.

 Room Safety Factor (S.F.) 

### < 1.67

1) The Waste Handling Manager (WHM) is notified and th e following conditions are evaluated:

A) Current emplacement location and remaining volume i n the disposal room;

B) Near future waste stream expectations for CPR conte nt, including which generator sites are shipping to WIPP at what rates;

C) Number of additional supersacks currently required;

2) From the responses to these questions decisions are made to initiate emplacement of additional MgO. The emplacement of additional MgO may occur i mmediately, or be planned for future

shifts.

3) If additional MgO is emplaced, it is performed util izing the existing emplacement racks for purposes of personnel safety related to stacking th e supersacks. MgO will normally be emplaced in complete rows to obtain the most effici ent repository geometry, but may be emplaced in single columns at the discretion of the WHM.

4) Once the emplacement activities are completed, the data is uploaded to the WWIS. At that point more MgO emplacements may be planned if neces sary or operations may continue to emplace additional waste.22 Attachment D Draft Procedure Flowchart for Adding MgO23

Figures Illustrating the MgO Safety Factor Evolutio n for Room 3, Panel 3

Figure 4. Room 3, Panel 3 MgO Safety Factor Calculation for J une 5, 200624

Figure 5. Room 3, Panel 3 MgO Safety Factor Calculation for J une 21, 200625

Figure 6. Room 3, Panel 3 MgO Safety Factor Calculation for J uly 11, 200626

Figure 7. Room 3, Panel 3 MgO Safety Factor Calculation for A ugust 27, 2006