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 2006
2

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 Evolution for Room 3, Panel 3......................... 22 
3

2006 Emplacement Inspection Report

1.0 EXECUTIVE SUMMARY 

 In accordance with 40 CFR 194.21, the U.S. Environmental Protection Agency (EPA or 

the Agency) conducted an inspection of the U.S. Department 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 (TRU) waste as defined by the WIPP Land 

Withdrawal Act.1 EPA certified that the WIPP complies with the Agency=s radioactive waste 

disposal regulations (Subparts B and C of 40 CFR Part 191) on May 18, 1998. 

The purpose of this annual inspection was to determine if waste sent to WIPP during the 

past year has been emplaced in the underground facility in the manner specified in DOE=s 

Compliance Certification and Recertification Applications and other approvals. A specific focus 

of this inspection was to determine if Magnesium Oxide (MgO) continues to be emplaced in the 

underground and appropriately tracked in the WIPP Waste 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. AObjective 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 needed is calculated properly (beginning with 

Panel 2, Room 1), and that all MgO is emplaced properly. While DOE does not necessarily 

maintain an MgO safety factor above 1.67 for operational 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 inspection. DOE did act on EPA’s 

recommendation from the 2005 inspection that the MgO emplacement training manual be made 

a standard operating procedure. In November 2005, DOE Aback-populated@ the WIPP Waste 

Information System with the amount of MgO in the repository, by room, to facilitate future 

estimates of the total MgO emplaced. 

 

1WIPP Land Withdrawal Act, Public Law 102-579, Section 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 whether 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 approvals 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 compliance 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 particular, 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 radionuclides out of the mined rooms. 

The WIPP site is operated by Washington TRU-Solutions (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 examined 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 Inspection

$ 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; Effective Date 

January 3, 2006 

• Waste Stream Profile Form Review and Approval Program, 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 Revisions 1 and 2, with no effective date 

were also examined. 

$ WIPP Waste Information System User's Manual WWIS Version 5.0, DOE/CBFO 97-2273, 

Rev. 9, December 12, 2005 

Activities within the scope of this inspection included: 

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

repository, 

$ the use of magnesium oxide (MgO) backfill in appropriate 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, including the electronic WIPP Waste 

Information System (WWIS). 

 The inspectors observed waste being emplaced in the underground and waste that had 

been recently placed in the repository. The inspectors also reviewed records documenting that 

waste emplacement and MgO tracking were conducted in accordance with procedures. To date, 

the waste received at the repository is contact-handled (CH) transuranic wastes from Argonne 

National Laboratory- East (ANL-E) in Illinois, Los Alamos National Laboratory (LANL) in 

New Mexico, Idaho National Laboratory (INL), Hanford 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-gallon (208 liter) drums assembled in groups 

of seven called a Seven Pack, and Ten Drum Overpacks (TDOP). In 2005 WIPP began 

receiving supercompacted waste in 100-gallon (416 liter) drums from INL. The SWB and Seven 

Pack have the same “footprint” — that is, they occupy equivalent floor space — and can be 

stacked in vertical columns as described in this report. The TDOPs have a different footprint and 

must be placed at the bottom of a column. A list of waste containers emplaced in the repository 

as of the date of this inspection is provided in Attachment 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 inspection. 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 miles 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 presentation. 

 The EPA inspectors accompanied CBFO and WTS personnel into the underground 

repository on the afternoon of June 20, 2006 in order to view waste packages that had been 

emplaced. Inspectors selected several shipments and 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 inspection continued the next day at the WIPP 

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

 Lastly, EPA inspectors reviewed the WWIS with Steve 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 panel consisting of seven (7) rooms. At 

the time of the inspection , waste was being emplaced in Room 3 of Panel 3. 

 Waste containers are stacked in columns (waste stacks) 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 being 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 Seven Packs are emplaced in no particular 

order with most wastes emplaced as received. The waste columns are in a series of staggered 

rows, with a row consisting of three columns that span 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 stack of MgO takes up one payload location. 

 

Some (1-2 feet) space between the repository wall and the waste column may be left open, 

however, waste packages may be placed touching or nearly 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 unusable 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 column on BRTs (big red things). See Figure 2. 

Figure 2. Additional MgO is placed in stacks five supersacks high 

in BRTs in order to assure an MgO safety factor above 1.67 before 

room closure. (Figure is from the 2005 inspection).

 While underground in Room 3, Panel 3, the EPA inspectors selected recently emplaced 

waste packages for later review. These shipments included 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 Container Data Report 

• Certification Module, linked to the Acceptance/Rejection Report 

• Shipping Module, linked to the Shipment Summary Report 

• Inventory Module, linked to the Nuclide Report, Waste Emplacement Report and the MgO 

safety factor calculation on the Emplaced Containers Underground Form 0420. 

 All records were found to contain the required information. 

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 application. EPA requires DOE to maintain an 

MgO safety factor of 1.67 or greater, which means that at least 1.67 times the needed MgO will 

always be in the repository to control chemical conditions 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 than three, although some rooms with INL 

supercompacted waste have had to have significant amounts of MgO added to maintain the 

required safety factor. When average CPR amounts are included in the waste, the safety factor is 

well above the minimum. In the opening presentations, 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 started 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 Engineer is to verify that the safety factor is 

greater than or equal to 1.67. Attachments to WP 05-WH1011 have been developed for 

recording the emplaced MgO underground or later entry into the WWIS. At the end of each shift 

the Waste Handling Engineer (WHE) inputs the emplaced waste and MgO information into the 

WWIS according to the WIPP Waste Handling Operations 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 needed. 

 Checklist items 8-10 deal specifically with the issue of MgO management and the 

objective evidence that demonstrates DOE has the appropriate process for ensuring that the MgO 

is properly emplaced. In addition to the requirement 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 MgO safety factor evolution is provided for 

Room 3, Panel 3 in emails from DOE staff to EPA staff and in Figures 4-7. 

 

Figure 3. DOE is emplacing waste stacked 2-3 containers high topped with MgO Supersacks. 

This picture shows all container types being shipped to date. Large drums are Ten Drum 

Overpacks (TDOPs), black barrels are 100-gallon drums 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 waste 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 approximately 3.22 x 106

 kg of the 2 x 107 kg needed by 

closure, but steel provides an additional 7.99 x 106 kg, so that WIPP has attained over two-thirds 

of the iron needed. With over 270,000 kg of aluminum and other non-ferrous metals, the WIPP 

has already exceeded the minimum amount for the limit 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 and rubber materials (CPR). In the CCA, DOE 

identified that the limit for CPR was 2.2 x 107 kg. However, during the first WIPP recertification 

process, DOE added packaging materials to the calculations, so that the CPR limit for WIPP is 

now 2.4 x 107 kg. 

 As of July 31, 2006 the WIPP contained 2.1 x 106

 kg of CPR in waste and 0.8 x 106 kg 

of CPR in packaging material for a total of approximately 2.9 x 106 kg of CPR (from WWIS 

query in Attachment B). Most of this is split between the cellulosic and plastic materials; the 

mass of rubber materials accounts for about 7% of the 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 could 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 point estimates for waste components (i.e., CPR) 

was acceptable for now, and identified that DOE needs to better demonstrate knowledge of the 

measurement uncertainty for the next recertification and include these uncertainties into the PA 

process. In the waste characterization process, radionuclide measurement errors are noted and 

included in the WWIS. CPR is an important component, 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 issue to currently be a finding and is discussing 

the issue with DOE outside of the inspection process. 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 determines 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 that DOE’s emplacement activities are 

adequate, the CPR is appropriately tracked, the safety 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 factor 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 into 

Panel 3, Room 3 (See Figure 3 of main report) verify 

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 into 

Panel 3, Room 3 (See Figure 3 of main report) verify 

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, panel, 

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) 

Satisfactory 
12

# 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 waste 

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). 

Satisfactory 
13

# 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, MgO 

Emplacement Process and Safety Factor Calculation, 

Revision 0, March 2, 2005 verifies that the WWIS software 

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 safety 

factor > 1.67. 

Screen shots below indicate that the MgO safety factor 

fluctuates with time. At the time of inspection, Panel 3, 

Room 3 had an MgO safety factor 1.51. Over a period of 

several weeks, the MgO safety factor changed. As of July 

30, 2006, the safety factor had been increased to 1.79 with 

an excess of 20 MgO supersacks (see emails from Steve 

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

 MgO
14

# 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 the 

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 approval 

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 WWIS 

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. 

Satisfactory 
15

# 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 viewed 

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 handling 

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 room 

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 Factor 

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.

Satisfactory 
16

# 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 WWIS. 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 

satisfactory 
17

Attachment A 

Number of Contact Handled TRU Waste Containers 

Underground at WIPP As of July 31, 2006

Site 100-

gallon Drums 

55-

gallon 

Drums 

Pipe 

Overpack S100 Pipe Overpack SWB TDOP 85-Gal Overpack Dunnage Drums Dunnage SWBs 

ANL-E 0 318 0 0 0 12 0 4 0 

Hanford 0 3772 2093 0 8 208 0 78 0 

INL 4842 16044 0 0 753 1400 0 525 0 

LANL 0 4025 218 11 168 0 0 618 0 

LLNL 0 678 0 0 2 0 0 8 0 

NTS 0 1805 0 0 14 0 0 8 0 

RFETS 0 15460 21174 0 3910 4 0 529 0 

SRS 0 2268 0 0 350 1555 0 0 0 

WIPP 0 2 0 0 0 0 2 2989 13 

Total 4842 44372 23485 11 5205 3179 2 4759 13 

NOTE: The drums listed for WIPP consist of two drums of site generated waste, two drums from RFETS that were overpacked on site, wit

drums 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) 
18

Drums = 55 gallon (208 liter or 0.208 m3) steel drums Pipe Overpack = 55 gallon drum pipe overpack except for 

SWB = Standard Waste Box TDOP = ten drum overpack Dunnage = inert drums used to complete waste assemblies 
19

Attachment B 

Weight (Mass) of Materials Emplaced in WIPP as of July 31, 2006* 

HA WASTE_MATL_PARM TYPE DESCRIPTION M-- ---------------------------------------- -------------------- --------------------------------------------------  16 Emplacement MAGNESIUM OXIDE  18 Emplacement CELLULOSIC EMPLACEMENT MATERIAL  20 Emplacement PLASTIC EMPLACEMENT MATERIAL CH 1 Waste IRON BASE METAL ALLOYS CH 2 Waste ALUMINUM BASE METAL/ALLOYS CH 3 Waste OTHER METAL/ALLOYS CH 4 Waste OTHER INORGANIC MATERIALS CH 6 Waste CELLULOSICS CH 7 Waste RUBBER CH 8 Waste PLASTICS CH 9 Waste SOLIDIFIED INORGANIC MATERIAL CH 10 Waste SOLIDIFIED ORGANIC MATERIAL CH 12 Waste SOILS CH 13 Steel Packaging STEEL CONTAINER MATERIALS CH 14 Plastic Packaging PLASTIC/LINERS CONTAINER MATERIALS CH 15 Cellulosic Packaging CELLULOSICS PACKAGING MATERIALS *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 Room 3, Panel 3 

7/31/06 email from Steve Casey (DOE) to Tom Peake (EPA) 

Tom, 

The decision is still a human judgment determination - the two documents WP 05-WH.01 and WH1011 are used 

as standard practices for most situations. Prior to making the call on whether or not to add additional MgO, it is 

important to know the next two weeks or more of shipments from the various sites. As we stated previously, 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, with a calculated MgO SF= 1.79 (20 excess sacks; no BRTs 

emplaced). 

Steve 

7/12/06 email from Steve Casey (DOE) to Tom Peake (EPA) 

Attached is a screen shot from the WWIS showing where we're at as of last night... 

SF = 1.64 

Sacks needed = 4 

Room 3 is still being filled - today we're emplacing 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 not need to 

emplace a "BRT" any time soon. 

Steve 
21

Attachment C 

2005 Training Notes For Waste Handling Engineers

 The purpose of this training is to provide information for Waste Handling Managers, 

Superintendents and Engineers to effectively evaluate changes in repository room Safety Factor (S.F.),

and make informed decisions related to Magnesium Oxide (MgO) emplacement activities required for 

the disposal of Supercompacted Waste, including: 

1) Requirements related to the EPA mandated Safety Factor 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 maximizing 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 Processing, 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 conditions: 

 Room Safety Factor (S.F.) ≥ 1.67

1) Activities continue for emplacement of waste and MgO. 

 Room Safety Factor (S.F.) < 1.67 

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

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

B) Near future waste stream expectations for CPR content, 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 immediately, or be planned for future 

shifts. 

3) If additional MgO is emplaced, it is performed utilizing the existing emplacement racks for 

purposes of personnel safety related to stacking the supersacks. MgO will normally be 

emplaced in complete rows to obtain the most efficient 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 necessary or operations may continue to 

emplace additional waste. 

 
22

Attachment D 

Draft Procedure Flowchart for Adding MgO 
23

Figures Illustrating the MgO Safety Factor Evolution for Room 3, Panel 3 

Figure 4. Room 3, Panel 3 MgO Safety Factor Calculation for June 5, 2006 
24

Figure 5. Room 3, Panel 3 MgO Safety Factor Calculation for June 21, 2006 
25

Figure 6. Room 3, Panel 3 MgO Safety Factor Calculation for July 11, 2006 
26

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