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DOCKET NO: A-98-49 

Item: II-B3-108 

2008 - Monitoring Inspection Report

INSPECTION No. EPA-WIPP-7.08-22b 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 22 to July 24, 2008 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Waste Management and Federal Regulation 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

September 2008
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 Table of Contents 

1.0 Executive Summary...................................................................................................................3 

2.0 Scope..........................................................................................................................................3 

3.0 Inspection Team, Observers, and Participants...........................................................................4 

4.0 Performance of the Inspection ...................................................................................................4 

 4.1 Monitoring of Geomechanical Parameters .............................................................................5 

 4.2 Monitoring of Hydrological Parameters .................................................................................6 

 4.3 Monitoring of Waste Activity Parameters ..............................................................................6 

 4.4 Monitoring of Drilling Related Parameters ............................................................................7 

 4.5 Monitoring of Subsidence Parameters ....................................................................................7 

5.0 Summary of Findings.................................................................................................................8 

Tables

Table 1 Monitor Parameters 

Table 2 Geomechanical Parameter and Values Measured to Confirm Them 

Attachments

Attachment A Inspection Plan and Checklist 

Attachment B Documents Reviewed 
1.0 Executive Summary

 The U.S. Environmental Protection Agency (EPA) conducted an inspection of the 

Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) from July 22 to July 24, 2008 

as part of our continuing WIPP oversight program. The purpose of this inspection was to verify 

that DOE continues to adequately monitor ten parameters listed in the Compliance Certification 

Application (CCA), Volume 1, Section 7.0, in particular Table 7-7 (See Table 1, COB-M2008-

1). Attachment A contains the inspection plan and the checklist used by the EPA inspector, and 

Attachment B lists documents reviewed by the EPA. 

 The inspection examined the implementation of monitoring for geomechanical, 

hydrological, waste activity, drilling related, and subsidence parameters. The EPA inspector 

toured locations where measurements are taken, reviewed parameter databases, and reviewed 

documents and procedures directing these monitoring activities. 

 The inspector found that DOE effectively implemented the monitoring programs at WIPP 

for all areas reviewed. EPA did not have any findings or concerns. The inspector also 

confirmed that the results of DOE monitoring programs are reported annually. 

2.0 Scope

 The EPA WIPP Compliance Criteria (40 CFR Part 194.42(a)) require DOE to “conduct 

an analysis of the effects of disposal system parameters on the containment of waste in the 

disposal system.” The results of these analyses were included in the 1996 Compliance 

Certification Application (CCA), confirmed in the 2004 Compliance Recertification Application 

(CRA), and were used to develop pre-closure and post-closure monitoring requirements. 

 Volume 1, Section 7.0, of the CCA documented DOE’s analysis of monitoring 

parameters. Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the 

disposal system. These parameters are grouped into major categories and listed in Table 1. EPA 

accepted these ten monitoring parameters in the 1998 Certification Decision and confirmed them 

in the 2006 Recertification Decision. 

Table 1 - Monitored Parameters

Geomechanical Parameters- Waste Activity Parameter- 

 -Creep closure, -Waste Activity 

 -Extent of deformation, 

 -Initiation of brittle deformation, and Subsidence Parameter- 

 -Displacement of deformation features. -Subsidence measurements 

Hydrological Parameters- Drilling Related Parameters- 

 -Culebra groundwater composition and -Drilling rate and 

 -Change in Culebra groundwater flow -The probability of encountering a 

 direction. Castile brine reservoir. 
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 This inspection was performed under authority of 40 CFR 194.21, which authorizes EPA 

to verify the continued effectiveness of the parameter monitoring program at WIPP. Inspection 

activities included an examination of monitoring and sampling equipment both on and off site, 

and in the underground. EPA also reviewed numerous sampling procedures and measurement 

techniques and verified implementation of an effective quality assurance program (see the 

document list in Attachment B of this report). 

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of three EPA staff. Three members of the State of New 

Mexico Environmental Department observed the inspection: Thomas Kesterson, Steve Holmes 

and Cody Johnson. Jerry Fox and Chris Timm of Pecos Management Services also observed 

inspection activities. 

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA 

Nick Stone Inspector EPA 

Tom Peake Inspector EPA 

 Numerous DOE staff and contractors participated in the inspection; below is a partial list. 

DOE/Contractor Participants

Rick Salness Dave Speed 

Joel Siegel Dave Kump 

Rey Carrasco Stan Patchet 

John VandeKraats Art Chavez 

David Hughes Mansour Akbarzadeh 

Larry Madl 

4.0 Performance of the Inspection 

The inspection began on Tuesday, July 22, 2008, with an opening meeting (COB-A2008-

S1a, -S1b) where changes in the parameter monitoring programs since the previous inspection 

were discussed by site staff (COB-M2008-I1 to -I8). On July 23, 2008 the inspection continued 

with interviews and demonstrations of various aspects of each parameter monitoring area. On 

July 24, 2008 the EPA inspector examined the database(s) used to store Delaware Basin 

parameters and the WIPP Waste Information System (WWIS) waste computer database system. 

The underground, where geomechanical measurements are taken, was also inspected. The 
inspection closeout meeting was held on July 24, 2008 in Carlsbad New Mexico (Sign-in sheet 

COB-A2008-S1a). 

 The EPA inspector reviewed three fundamental areas to verify continued implementation 

of the DOE parameter monitoring program during the pre-closure phase: 1) written plans and 

procedures, 2) quality assurance procedures and records, and 3) results of the monitoring 

program in the form of raw data, intermediate reports, and final annual reports, if appropriate. 

The inspection checklist in Attachment A provides details of these inspection activities. 

The EPA inspector reviewed various activities to verify effective procedure 

implementation. The inspector observed a demonstration of the WWIS and reviewed the 

Delaware Basin Drilling Surveillance Program, Groundwater Monitoring Program, and the 

Geomechanical Monitoring Program. 

4.1 Monitoring of Geomechanical Parameters

 DOE committed to measure four geomechanical parameters in the CCA: creep closure, 

extent of deformation, initiation of brittle deformation, and displacement of deformation features 

(Table 2). WIPP has four programs that supply information for these four parameters: the 

geomechanical monitoring program, the geosciences program, the ground control program, and 

the rock mechanics program. These programs are documented in the WIPP Geotechnical 

Engineering Program Plan, WP 07-01 (COB-M2008-E). The results of the geotechnical program 

are reported in the Geotechnical Analysis Report for July 2006 - June 2007, DOE/WIPP-08-

3177, Volumes 1 and 2 (COB-M2008-A1 and -A2). 

Table 2 - Geomechanical Parameter and Values Measured to Confirm Them 

Monitor Parameters Confirmed by Measuring Related Procedure(s)

creep closure and stresses convergence measurements WP 07-EU1301 

 borehole extensometers WP 07-EU1303 

 WP 07-EU1304 

 WP 07-EU1308 

extent of deformation borehole extensometers WP 07-EU1301 

 borehole observations WP 07-EU1303 

 WP 07-EU1305 

 WP 07-EU1308 

initiation of brittle fracture mapping WP 07-EU1301 

deformation borehole observation WP 07-EU1303 

 WP 07-EU1001 

displacement of deformation geologic mapping WP 07-EU1301 

features comparison WP 07-EU1303 

 WP 07-EU1001 

-From DOE/WIPP 08-3177 (COB-M2008-A1), Volume 1, Section 1.4 

 Geomechanical staff manually measured convergence values in the underground (Figure 

1, Vertical Convergence Measurement) and the inspector examined the results documented in 
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field data forms. After taking the measurements the inspector observed staff inputting these data 

into the computer database (COB-M2008-S42 to S49). The inspector found that procedures are 

adequate for proper measurements: procedures are implemented adequately; documents and field 

data forms are controlled; and data is adequately checked, using check prints when necessary, to 

assure adequate quality. 

 

4.2 Monitoring of Hydrological Parameters

 DOE committed to measure two hydrological parameters 

in the CCA: Culebra groundwater composition and changes in the 

Culebra groundwater flow direction. Related parameters are 

measured and documented in the WIPP environmental 

monitoring program. These programs are documented in the 

WIPP Groundwater Monitoring Program Plan, WP 02-1 (COBM2008-C). Results of this program are documented in the WIPP 

Site Environmental Report for 2006, DOE/WIPP 07-2225 (COBA2008-C). This document describes the groundwater monitoring 

program and reports results for the previous year. 

 

 During the 2008 inspection the EPA inspector requested 

information about changes in the program since last year. The 

opening meeting presentation noted that two new Culebra wells 

were drilled and 2 wells were plugged since last year (COBM2008-I2a). The current well monitoring network consists of 47 

Culebra, 11 Magenta, 3 dual Culebra/Magenta completions, 1 

Dewey Lake, 2 Bell Canyon, and 20 shallow Santa Rosa/Dewey 

Lake wells. Besides examining the Site Environmental Report 

for 2006 the inspector examined flow direction maps, well 

location maps, water level measurements, and water chemistry 

data (COB-M2008-S24, -S40, -S41, and –S51) during the 2008 

inspection. The inspector found the hydrological monitoring 

program to be improving and adequate. 

4.3 Monitoring of Waste Activity Parameters

 DOE committed to monitor the activity of waste emplaced in the CCA. This parameter is 

part of the extensive database collected for each container shipped to WIPP and is stored in the 

WIPP Waste Information System (WWIS). The WWIS is a software system that screens waste 

container data and provides reports on the Transuranic (TRU) waste sent to WIPP. The 

requirements for the WWIS are discussed in the WIPP Waste Information System Program and 

System Data Management Plan, WP 08-NT.01 (COB-M2008-H2). DOE yearly reports waste 

activity information in the Annual Change Report Table 3 (DOE/WIPP 07-3317; COB-M2008-

Pa, -Pb). 

Vertical Convergence Measurement 
 WWIS staff demonstrated that the WWIS can receive data and that the WWIS can 

generate needed reports. The inspector obtained copies of the Nuclide Report (COB-M2008-

W1) and WWIS Shipment Summary Reports (COB-M2008-W2 and -W3). The inspector 

verified that DOE tracks and annually reports the waste activity at WIPP. 

4.4 Monitoring of Drilling Related Parameters

 DOE committed to measure two drilling related parameters in the CCA: the drilling rate 

and the probability of encountering a Castile brine reservoir. These parameters are measured as 

part of the Delaware Basin Drilling Surveillance Plan, WP 02-PC.02 (COB-M2008-G). This 

surveillance program measures and records many parameters related to drilling activities around 

the WIPP site. The results of the surveillance program are documented annually in the Delaware 

Basin Monitoring Annual Report, 

DOE/WIPP 07-2308 (COB-M2008-

M). 

 The inspector reviewed the 

drilling surveillance database, 

examined drilling rate changes, and 

permitted and active injection wells 

while interviewing staff. The 

inspector received and reviewed Texas 

and New Mexico well database 

ACCESS files and maps of oil and gas 

wells around WIPP, (Figure 2, Oil and 

Gas Wells Around WIPP) (COBM2008-D1 to -D3). The inspector 

verified that DOE tracks and reports 

the drilling rate and the number of 

Castile brine encounters near WIPP 

and reports results annually.

4.5 Monitoring of Subsidence Parameters

 DOE committed to measure subsidence at the WIPP site. This parameter is documented 

as part of the WIPP Underground and Surface Surveying Program, WP 09-ES.01 (COB-M2008-

B). DOE performs subsidence surveys at the site annually during pre-closure operations. The 

results of this program are reported annually in the WIPP Subsidence Monument Leveling 

Survey – 2007, DOE/WIPP 08-2293 (COB-M2008-F). 

 Subsidence staff demonstrated the Office Procedure (Section 2 of WP 09-ES4001: COBM2008-N) to the EPA inspector which describes the steps taken to process raw field survey data 

and to calculate final surface elevations published in their annual report (COB-M2008-S62 to -

S64). The inspector examined the procedure, Subsidence Software Installation and Checkout 

Oil and Gas Wells Around WIPP (Red Dots) 
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Form/Report (COB-M2008-S60), used to qualify computer software to support the subsidence 

program. The inspector confirmed that the computer code is qualified appropriately using hand 

calculations (COB-M2008-S61). DOE demonstrated that the subsidence parameter is measured 

and reported yearly. 

5.0 Summary of finding, observation, concerns, and recommendations.

 Based on program documents, interviews, and field demonstrations during the inspection, 

EPA concludes that the monitoring program covers the ten monitoring parameters required by 

EPA’s 1998 Certification Decision. This inspection determined that the monitoring, sample 

collection, and sample/data analysis procedures were complete and appropriate; that staff were 

adequately trained and implemented the procedures adequately; and that appropriate quality 

assurance measures are applied. EPA continues to find that DOE has maintained adequate 

parameter monitoring during the past year and has the procedures and requirements in place to 

sustain their program into the next year. EPA has no findings or concerns. 
Attachment A: Inspection Plan and Checklist 

WIPP Monitoring Inspection Plan 

40 CFR 194.42 for the year 2008

Purpose: Verify that the Department of Energy (DOE) can demonstrate that the Waste Isolation 

Pilot Plant (WIPP) is monitoring the parameter commitments made in the documentation to 

support the EPA’s certification decision, in particular CCA, Volume 1, Section 7.2, Table 7.7 

and Appendix MON. This inspection is conducted under the authority of 40 CFR 194, Section 

21. 

This inspection is part of EPA’s continued oversight to ensure that WIPP can, in fact, monitor 

the performance of significant parameters of the disposal system. 

Scope: Inspection activities will include an examination of monitoring and sampling equipment 

both on and off site, and in the underground. A review of sampling procedures and measurement 

techniques may be conducted. Quality assurance procedures and documentation for each of 

these activities will also be reviewed. 

Focal Areas of This Year’s Inspection: 

- What has changed in the monitoring program this past year? 

- What documentation and procedures have changes? 

- Update the monitoring program and results for the past year. 

- Have any monitoring parameters changed, and have any action limits been achieved? 

Location: This inspection will be held at the WIPP facility location twenty-six miles south east 

of Carlsbad, New Mexico and the surrounding vicinity as needed. 

Duration: The EPA expects to complete its inspection in two days. Each day will begin with an 

opening meeting at 8:00 a.m. and end before 5:00 p.m. with a closeout session. 

Expected Date: Week of July 21, 2008. 

Documents For Review: Just like past years provide latest versions of any documentation 

and/or procedures related to your monitoring program as soon as possible. 
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Monitoring Commitments – July 2008 Geomechanical Parameters

# Question Comment (Objective Evidence) 

SAT = Satisfactory

Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Creep Closure; 

b) Extent of Deformation; 

c) Initiation of Brittle Deformation and 

d) Displacement of Deformation Features 

during the pre-closure phase of operations as 

specified in the CCA part of the geomechanical 

monitoring system? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Geotechnical Engineering Program 

Plan, (WP 07-01: COB-M2008-E), 

documents plans to measure, report, and the 

QA requirements related to these activities. 

Section 3.0 of WP 07-01 documents the 

geomechanical monitoring program and 

records the activities associated with this 

program. Section 4.0 of WP 07-01 

documents the quality assurance 

requirements for these activities. 

WIPP site staff discussed changes to the 

program during the past year (COB-M2008-

I6). Staff demonstrated the adequacy of the 

program and that the program produces 

satisfactory results (COB-M2008-S42 to 

S49). They showed samples of remote 

measurements, sample plots, and staff 

preformed underground manual 

measurements of convergence (Photos 2008-

07-23_Annual Inspection 00116 to 00121). 

The inspector toured underground and 

reviewed the computer system and databases 

used to collect and process recorded data. 

Results of this program are documented 

annually in the Geotechnical Analysis Report 

for each reporting period (DOE/WIPP 08-

3177; COB-M2008-A1 and -A2). 

The inspector verified that the geomechanical 

parameters continued to be appropriately 

monitored by DOE. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

geotechnical investigations are reported 

annually? (CCA, App. MON, Page MON-10) 

WP 07-01, Section 3.2 requires that analysis 

be performed annually and results are 

published in the annual geotechnical analysis 

report (DOE/WIPP 08-3177). 

SAT 
Monitoring Commitments – July 2008 Hydrological Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Culebra Groundwater Composition; 

b) Change in Culebra Groundwater Flow 

Direction 

during the pre-closure phase of operations as 

specified in the CCA part of WIPP’s 

groundwater monitoring plan? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Groundwater Monitoring Program Plan, 

WP 02-1 (COB-M2008-C) documents plans to 

measure, document, report, and the QA 

requirements for these activities. WP 02-1 

records the activities associated with this 

program (Section 4), methods used (Sections 5 

and 6), data analysis (Section 7) and reporting 

requirements (Section 8). Section 11.0 of 

WP 02-1 documents quality assurance 

requirements. 

WIPP site staff discussed changes to the 

program over the past year (COB-M2008-I2a). 

Staff also explained computer code contouring 

techniques used to develop maps to find flow 

direction in the Culebra and compared results 

for years 2003 to 2007 (COB-M2006-S40 to –

S41). Site staff are developing a new 

procedure WP 02-EM1025 (COB-M2008-

S24) that will standardize potentiometric 

surface development. Site staff discussed 

groundwater composition measurements 

(COB-M2008-I2c). Site staff also discussed 

the shallow water well program (COBM2008-S20 to -S23). 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App MON, 

Page MON-22) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

groundwater monitoring program are reported 

annually? (CCA, App. MON, Page MON-22) 

Results are published annually in the WIPP 

Annual Site Environmental Report for 2006 

(DOE/WIPP 06-2225: COB-A2008-C). 

SAT 
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Monitoring Commitments – July 2008 Waste Activity Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Waste Activity? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Waste Information System Program and 

Data Management Plan (WP 08-NT.01: COBM2008-H2, Section 6.0) describes how the 

WWIS is used to measure and store waste 

activity information. WWIS User’s manual 

(DOE/CBFO 97-2273: COB-M2008-O) 

documents procedures used to gather, store, 

and process waste activity information. Table 

3 of the Annual Change Report 2006/2007, 

(DOE/WIPP 07-3317: COB-M2008-Pb) 

updates waste activity information annually. 

WWIS staff discussed changes during the past 

year (COB-M2008-I7) and demonstrated the 

use of the WWIS and generated numerous 

reports (COB-M2008-W1 to W3). Such as the 

Nuclide Report which summaries isotopes 

emplaced at WIPP. These activities 

demonstrate that waste activity is adequately 

monitored. 

SAT

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? (CCA, App WAP, page 

C-30) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

waste activity parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 08-NT.01 Section 6, page 11 “Regulatory 

Reporting” documents that results are reported 

annually and DOE/WIPP 07-3317 verifies that 

results are published annually. 

SAT 
Monitoring Commitments – July 2008 Drilling Related Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Drilling Rate; and 

b) Probability of Encountering a Castile Brine 

Reservoir? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

The Delaware Basin Drilling Surveillance 

Plan, (WP 02-PC.02: COB-M2008-G), 

documents the program to measure, record, 

report, and the QA requirements for these 

activities. Section 7.0 of WP 02-PC.02 

documents quality assurance requirements. 

The Delaware Basin Drilling Database 

Upgrade Process (WP 02-EC3002: COBM2008-I) documents the process used to 

update databases with information from 

various commercial and state sources. 

Drilling rate and Castile brine encounter data 

are reported annually in the Delaware Basin 

Monitoring Annual Report (DOE/WIPP 07-

2308; COB-M2008-M) in Sections 2.5 and 

2.6. 

WIPP site staff discussed changes during the 

past year (COB-M2008-I1). They reported on 

brine encounters, drilling rate calculations, 

and provided maps of drilling activities near 

WIPP (COB-M2008-D1). They also provide 

the latest version of the Texas and New 

Mexico well databases (COB-M2008-D2 and 

-D3). They demonstrated that DOE is 

adequately monitoring these parameters 

through the Delaware Basin monitoring 

program. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App DMP, 

page DMP-9) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

drilling related parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting; App DMP, page DMP-9) 

WP 02-PC.02 Section 6.0 documents that 

results are reported annually. DOE/WIPP 07-

2308 verifies that these parameters are 

updated and reported annually. 

SAT 
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Monitoring Commitments – July 2008 Subsidence Measurements

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Subsidence measurements? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Underground and Surface Surveying 

Program (WP 09-ES.01: COB-M2008-B), 

documents the program used to measure, 

record, document, report, and the QA 

requirements for these activities. Subsidence 

Survey Data Acquisition Report technical 

procedure (WP 09-ES4001: COB-M2008-N) 

documents the process for acquiring 

subsidence data, updating the database, and 

publishing the annual subsidence report. The 

WIPP Subsidence Monument Leveling Survey 

- 2007 (DOE/WIPP 08-2293: COB-M2008-F) 

documents that DOE reports this parameter 

annually and the results of this program. 

Site staff demonstrated that procedures are 

adequately implemented when they showed 

how the raw field survey data collected is 

reduced to useful survey data and how annual 

results are calculated (COB-M2008-S62 to –

S64). This year the inspector examined the 

process and procedure used to qualify the 

computer codes used for the subsidence 

program (COB-M2008-S60, -S61). Site staff 

demonstrated that the computer codes used are 

appropriately qualified for use in the 

subsidence program. They demonstrated that 

subsidence is adequately monitored at the site. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

subsidence measurements are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 09-ES.01 Section 3.3.2 documents that 

results are reported annually. DOE/WIPP 08-

2293 demonstrates that results are published 

annually. 

SAT 
Attachment B: Documents Reviewed